SolarPower Europe has published their Position Paper with feedback on the amendment of the Renewable Energy Directive (REDIII), following up to their previous recommendations for REDII in May 2021. REGlobal presents an extract from the same.

Increase the EU’s renewable energy target to at least 45% renewable energy in final energy demand by 2030 (Article 3)

  • The renewable energy target proposed by the European Commission is insufficient to set the EU on a cost-efficient trajectory to deliver 55% GHG emission reductions and climate neutrality by 2050.
  • Increasing the EU’s renewable energy ambition is possible and will shield energy consumers from high energy prices, underpin the growth of a domestic solar manufacturing industry, and create over 1 million solar jobs in 2030.
  • The REDIII Impact Assessment solar capacity forecast falls significantly short of SolarPower Europe’s market forecasts. The Impact Assessment forecast a 479 GW capacity by 2030 whereas in a business-as-usual scenario, with no increase in the renewable energy ambition, we expect EU solar capacities to reach 588 GW by 2030. SolarPower Europe and LUT energy system modelling shows that under a 45% renewable energy target, 870 GW of solar would be installed in the EU, up from 660 GW under a 40% renewable energy target.

Introduce targeted amendments to improve strategic planning and facilitate rooftop PV deployment (articles 15 and 15a) and establish an appropriate enforcement strategy (non-regulatory)

  • Slow permitting of solar projects is putting at risk the deployment of the solar capacity required to put Europe on track of a 55% emissions reduction target by 2030.
  • SolarPower Europe welcomes the proposal for a review clause in article 15 on the rules on administrative procedures within one year of the entry into force of the REDIII. In addition to this, member states should be mandated to carry out strategic planning exercises (article 15) and must exempt rooftop solar from construction permits (article 15a).
  • Yet, the main challenge lies in implementation. The European Commission should come up with a true enforcement strategy on permitting. Member states must report on key performance indicators (KPIs) to track implementation of permitting rules. The upcoming guidelines to reconcile permitting with environmental and local communities’ interests and identifying best practices for member states should be published swiftly and disseminated at national level.

Maintain the strong definition of renewable hydrogen and Renewable Fuels of Non-Biological Origin (RFNBOs) (article 2) and ensure the industry and transport sub-targets only promote RFNBO uptake in hard-to-abate sectors (articles 22a and 25)

  • Overall, the Commission proposals ensured that only hydrogen produced from renewable sources contributes to the EU’s 2030 renewable energy targets.
  • We endorse the proposals in article 2(36) to update the definition of RFNBO and in article 7.1 to update the methodology to calculate RFNBO contribution to renewable energy targets.
  • Priority should be given to use renewable hydrogen in sectors where direct electrification is not cost-efficient and technically viable and where the use of renewable hydrogen has been identified as the “most suitable option”. The ambition of the sub-targets to use renewable hydrogen in industry (article 22a.1) should not be reduced. The RFNBO transport sub-target (article 25.1 (b)) should be reduced to 1.6% of the energy supplied to the transport sector. Decreasing the transport sub-target should not entail an increase in the industry RFNBO sub-target in article 22a.1. These targets should be accompanied by a renewable hydrogen support measures to bridge the current renewable hydrogen cost gap and unlock investment.
  • SolarPower Europe supports the Commission’s decision to set up a Union Wide database to trace liquid and gaseous renewable fuels and recycled carbon fuels. The scope of information on the fuels contained within this database should begin from production to consumption of the RFNBO.

Boost corporate procurement of renewables (article 15 and 19) and improve the Guarantees of Origin framework (article 19)

  • Requirements introduced in article 15.8 to promote the uptake of PPAs have a significant potential to accelerate private procurement of renewables across the EU, but they must be complemented by effective guidelines.
  • Requirements proposed in article 19.2 on member states to issue GOs to all renewable energy producers should be maintained.
  • The GO framework should be improved to require member states to timestamp GOs issued to energy producers and to provide additional details on the origin of electricity. This would enable improved carbon accounting and help corporates increase the impact of their investments based on potential decarbonization impact.

Leverage support schemes and tendering frameworks to promote the most sustainable renewable energy technologies (articles 3, 4 and 15)

  • While price should be the main criteria to drive the deployment of cost-efficient solar, national support schemes have a role to play in driving the deployment of the most sustainable technologies.
  • To ensure the coherence of the Single Market it is critical that member states apply EU regulatory requirements within their support schemes, in particular the methodologies and standards to be set in the PV Ecodesign and Energy Labeling measures.

Enhance the framework for mid-sized renewable energy systems (article 15a)

  • The potential for commercial and industrial (C&I) mid-sized rooftop solar (between 10 k Wp and 1 MWp) is significant but is not appropriately addressed within the existing framework.
  • The revision of the REDIII should provide specific provisions to facilitate the development of C&I renewable energy and storage projects. Member states should support innovative business models for mid-sized self-consumers and prosumers systems, by allowing them to self-supply renewable electricity through a direct line, exclude solar rooftop systems from construction permit requirements, allow on-site solar to be deployed beyond the award of building operational license when fulfilling rooftop mandates, and accelerate the development of frameworks which enable the monetization of renewable energy generation and storage.

Support proposals to accelerate renewable-based electrification and energy system integration (articles 3, 20a and 25)

  • The proposal to require member states set up frameworks to enable renewable electrification should be improved by highlighting additional barriers related to energy taxation, grid access, and the electrification of end-uses.
  • The proposed article 20a ‘Facilitating Energy System Integration’ could support small and mobile distributed assets add integrated within the energy system. Yet it requires targeted improvements to maximize its impact.
  • Solar power Europe fully supports the European Commission’s proposed requirement on member states to introduce a credit trading mechanism that includes renewable electricity under article 25(2) to meet their targets for renewable energy in transport. The scope of the credit exchange mechanism must be enlarged to include private charging stations rather than being limited to publicly accessible charging stations only. This would allow for a higher coverage of renewable electricity used for charging to be captured and valued under the credit system.
  • To maintain a level playing field between electricity and other energy options used in transport, it must be possible to account for 100% renewable electricity used in transport such as through a direct line or through PPAs.

The complete paper can be accessed here