Position papers

WindEurope Position Papers

See more Advocacy content in the Members Area such as National Energy & Climate Plans, Advocacy and Meeting reports.

• WindEurope response to ENTSO-E public consultation on Cyber-attack Classification Scale Methodology for the Network Code on Cybersecurity February 2025

  WindEurope provided feedback on the public consultation organized by ENTSO-E regarding the Cyber- attack Classification Scale Methodology on Network Code on Cybersecurity (NCCS).

  Under Article 37(8) of the Network Code for Cybersecurity (NCCS), the European Network of Transmission System Operators for Electricity (ENTSO-E) in cooperation with the EU DSO entity (DSO Entity) has developed a proposal for methodology for the cyber-attack classification scale.
  The document will help high-impact and critical-impact entities to assess whether a cyber-attack is reportable according to the NCCS by understanding the gravity level of a cyber-attack. The gravity of a cyber-attack is based on the potential impact and the severity of the cyber-attack. The potential impact is determined by the types of assets affected. The severity of the cyber-attack is estimated according to the position of an attacker in the attack chain.

  When high-impact and critical-impact entities assess the gravity of the cyber-attack as critical or high, they must share relevant information with their CSIRTs and competent authorities no later than four hours after assessing that the cyber-attack is reportable.

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• Recommendations for the Affordable Energy Action Plan February 2025

  In this paper WindEurope outlines key recommendations for the upcoming Affordable Energy Action Plan, focusing on the following priorities:

  1. Taxation to support electrification and renewables integration: align energy taxation with climate goals.
  2. Efficient grids and flexibility solutions: scale up investments in grid infrastructure and flexibility solutions like energy storage and demand response.
  3. Expansion of reliable renewable electricity supply: accelerate renewable deployment through stable regulatory frameworks, long-term electricity contracts, and investment incentives.
  4. Supporting communities hosting renewables: provide direct benefits to communities hosting renewable energy projects.
  5. Building a business case for industrial electrification: support industries transitioning to electrification through targeted financial mechanisms and by creating demand for green products.

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• WindEurope Position Paper on the EU Clean Industrial Deal December 2024

  As set out in the Draghi report, Europe is facing eroding competitiveness to a degree that starts to question the viability of our economic and social model. We are at a crossroads confronted with lagging innovation and incomplete Market integration undermining our ability to compete globally. The European Commission wants to tackle this situation is a new Clean Industrial Deal expected in February 2025. Accelerating renewables-based electrification will be central to delivering a cost-efficient transition to net zero. And wind can play a big part in delivering that shift. In this paper, WindEurope makes proposals to help industrial electrification, strengthen the European wind value chain and implement quickly the European Green Deal to strengthen Europe’s competitiveness.

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• WindEurope response to ENTSO-E Public Consultation on Cybersecurity Risk Assessment Methodologies for the Network Code on Cybersecurity December 2024

  WindEurope provided feedback on the public consultation organized by ENTSO-E regarding the cybersecurity risk assessment methodologies for the Network Code on Cybersecurity (NCCS).

  Under Article 18 of the NCCS, the European Network of Transmission System Operators for Electricity (ENTSO-E), in cooperation with the EU DSO Entity, developed methodologies for cybersecurity risk assessments. These methodologies address three levels: Union-wide, regional, and member state.

  Notably, no specific methodology is prescribed for risk assessments at the entity level, as entities are free to choose their own, provided it complies with Article 26 of the NCCS. The methodologies focus on assessing the impact of cyberattacks on the grid’s operational security, ensuring consistent risk evaluation across the levels defined in the NCCS.

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• Electricity grids: Deliver on the action plan November 2024

  In this position paper WindEurope outlines the five most urgent steps Governments must take now to implement the EU’s Grids Action Plan in order to unlock wind energy deployment and ramp up the direct electrification of Europe’s economy. The paper comes one year after the European Commission had proposed the Grids Action Plan.

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• WindEurope response to ACER consultation on Network Code Demand Response October 2024

  In May 2024, EU DSO Entity and ENTSO-E submitted their draft proposal to ACER of a new Network Code on Demand Response. Their proposal also included amendments to the three related electricity network codes: balancing, system operation, and demand connection. ACER consulted on their revised draft from September 5 to October 31. This document presents WindEurope’s response to the ACER stakeholder consultation on the draft Network Code.

  Apart from comments on articles such as flexible connection agreements and congestion management, our general comment is this draft Network Code fails to achieve the intended harmonization of market rules. It assigns the development of numerous methodologies to TSOs and DSOs and anticipates that most of the aspects requiring harmonization will be further defined in national Terms and Conditions or Methodologies. This approach undermines the purpose of the Network Code, as it relegates fundamental elements to a subsidiary process rather than addressing them comprehensively at the European level, which is essential for achieving effective market harmonization.

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• WindEurope response to European Commission consultation on forward markets September 2024

  This document presents WindEurope’s response to the stakeholder consultation by European Commission to seek stakeholder views on improving the current functioning of the electricity forward markets. This assessment is expected to lead to a revision of the Forward Capacity Allocation Guideline (FCA GL).

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• WindEurope response to ENTSO-E public consultation on Bidding Zone review September 2024

  Following the implementation of Commission Regulation (EU) 2019/943 (Electricity Regulation) and ACER decision No 29/2020 on alternative Bidding Zone configurations, all TSOs are conducting a common study on Bidding Zone Review (BZR). The main deliverables of the BZR study are: 1) a final report with an assessment of 22 indicators, and, 2) a joint recommendation to the governments of the involved Member States for the future configuration.

  This is the WindEurope response on the ENTSO-E public consultation on two out of the 22 indicators for assessing alternate bidding zone configurations.

  Key message is that reconfiguration of bidding zones today will bring more uncertainty for renewable projects and will rather slow down the energy transition owing to the uncertain effects. The biggest question is whether the bidding zone reconfiguration really will in fact help resolve congestion issues at all.

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• WindEurope response to European Commission consultation on anticipatory investments September 2024

  The Electricity Market Regulation mandates System Operators to adapt their network tariff methodologies to enable the monetisation of long-term – anticipatory – investments in their grids build-out, optimisation and flexibility. By Q1 2025, the European Commission will publish guidance to support Member States in identifying conditions under which they should be granting anticipatory investments in grid projects. Currently there is no common definition of “anticipatory grid investments” at EU level.

  In this context, the European Commission invited stakeholders to reply to a survey. In our response, along with other recommendations we propose the following definition for anticipatory investments:

  Anticipatory investments in electricity grid infrastructure are proactive, long-term investments made with a forward-looking approach beyond 10 years to ensure timely grid development that:

  • can deliver grid capacity underpinning national/EU energy and climate targets including announced national/EU targets for renewable energy deployment and electrification
  • realistically considers supply chain readiness and lead times
  • accounts for the cost of inaction in terms of climate and energy targets achievement paid by consumers and network users
  • accounts for costs and risks currently bore by network users such as generators and system operators

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• WindEurope recommendation for a wind energy data classification scheme September 2024

  This classification scheme is designed to facilitate the implementation of EU legislative frameworks, including the EU Data Act (EU 2023/2854) and the European Wind Power Action Plan. It establishes a structured approach to handling data, enhancing security, promoting collaboration, and ensuring regulatory compliance. The framework addresses challenges such as the lack of harmonized data standards, concerns over intellectual property, and inefficient data sharing, which hinder innovation and optimization in the wind energy sector.

  The classification introduces a four-tier system—Critical Data, Personal Data, Confidential Data, and Public Data—to strengthen security, improve data sharing, and ensure compliance across the wind energy sector.

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• WindEurope response to ACER public consultation on proposal for amendments to the Network Code on High Voltage Direct Current (NC HVDC) September 2024

  This document presents WindEurope’s response to the public stakeholder consultation by ACER in the process of amendments to the grid connection requirements for high voltage direct current systems and related power park modules (NC HVDC).

  WindEurope proposes explanatory comments, legal text modifications and articles on topics including but not limited to grid forming, the introduction of two new neutral terms in the NC HVDC: “isolated AC network” and “isolated AC network operator”, the consistency with the NC RfG, the integration of cyber-protected data exchange interface where relevant.

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• WindEurope response to ACER consultation on network tariff issues September 2024

  This document presents WindEurope’s response to the stakeholder consultation by ACER for collecting views on network tariff issues.

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• WindEurope position paper on electricity grids July 2024

  In November 2023 the European Commission launched the EU Action Plan for Grids to accelerate the build-out and modernisation of electricity grids. The recent reform of the EU electricity market design also includes many new and reinforced provisions for electricity grids and flexibility. The implementation of the provisions agreed at EU level and of the EU Action Plan for Grids will be critical. This position paper aims to set the wind industry’s priorities and give recommendations to guide this implementation.

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• Recommendations for the Delegated Act specifying a methodology for assessing GHG emissions savings from low-carbon hydrogen July 2024

  Only renewable hydrogen emits no greenhouse gas (GHG) emissions during production and counts towards meeting the EU renewable energy and decarbonisation targets. It is therefore crucial to differentiate the value of renewable hydrogen compared to low carbon hydrogen.

  WindEurope welcomes the specification in Article 9 of the recast EU Directive on gas and hydrogen markets that the LCH methodology will cover life cycle GHG emissions and will consider indirect emissions, including the treatment of emissions due to hydrogen leakage, methane upstream emissions and downstream carbon capture rates. WindEurope emphasises the need to establish transparent and robust system boundaries, within which all GHG emissions will be accounted for, including up-, mid- and down-stream emissions.

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• WindEurope feedback on recycling criteria in auctions July 2024

  The European Commission recommendation and guidance documents on renewable energy auctions recommends the Member States to use environmental and sustainability criteria as pre-qualification, award criteria or a combination of both. And recommends they should be quantitative whenever possible, for example on circularity and recyclability.

  The European wind industry strongly supports the introduction of sustainability-related non-price criteria in wind energy auctions in Europe. This section spells out the wind industry’s views on how governments should apply recycling and circularity criteria.

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• WindEurope position on responsible business conduct pre-qualification criteria in autions July 2024

  The European wind industry strongly supports the introduction of a prequalification criteria related to responsible business conduct in future renewable energy auctions, as requested in the Net-Zero Industry Act.

  The European Commission recommendation and guidance documents on renewable energy auctions recommends the application of existing legal requirements or adherence to national or European responsible business conduct codes.

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• WindEurope position on cyber and international data transfer pre-qualification criteria in national wind energy auctions July 2024

  The recent Wind Power Package and the design guidance for non-price criteria in renewable energy auctions advises that Member States incorporate pre-qualification standards related to cybersecurity and international data transfer in their wind energy auctions, aligning with EU regulations and international commitments. The Net Zero Industry Act will mandate these criteria for Member States when organizing auctions for technologies deemed strategic for achieving net-zero emissions.

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• WindEurope position on the resilience criterion in the Net-Zero Industry Act July 2024

  The Net-Zero Industry Act (NZIA) introduces mandatory non-price criteria for renewables auctions, requiring Member States to assess the resilience contribution of renewable energy projects.

  This paper outlines WindEurope’s position on implementing the resilience criterion. WindEurope emphasizes the necessity for a technology-specific approach due to varying supply chain complexities, and advocates for an alignment across Member States to avoid market fragmentation. The paper suggests a standardized list of key components for assessing resilience and highlights the importance of avoiding penalization for dependencies where alternatives are not viable. Furthermore, it recommends periodic assessments of resilience criteria and alignment of geographical scope, including exemptions for countries with significant integration with the EU.

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• Position of WindEurope on pre-qualification and non-price award criteria in auction July 2024

  Following the entry into force of the Net-Zero Industry Act, the European Commission will adopt several implementing legislations to detail pre-qualification and non-price criteria in auction by March 2025. In this paper, WindEurope is sharing his position on how this design should be implemented.

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• End of life and repowering trends, and policy recommendations on repowering June 2024

  Repowering will be key to meeting Europe’s 2030 Climate and Energy security goals. It nearly triples the electricity output of a wind farm, while reducing the number of turbines. But projects fail to materialise. Based on current trends and market expectations we estimate very low volumes for repowering compared to industry expectations on the back of the improved permitting rules for repowering that are now in place. This position paper lines up the latest end of life and repowering trends and policy recommendations on how to promote repowering.

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• Recommendations for the European Hydrogen Bank’s second auction June 2024

  WindEurope welcomes the European Commission’s ambition to stimulate and support investment in renewable hydrogen production through the European Hydrogen Bank (EHB). The second auction of the European Hydrogen Bank will be launched by the end of 2024. Some changes to the Terms & Conditions of the second auction would help the scheme to unlock more competitive financial investment decisions to produce renewable hydrogen (RH2) and its derivatives in the EU.

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• WindEurope recommendations for the National Energy and Climate Plans on industrial electrification June 2024

  Member States have to submit their final National Energy and Climate Plans (NECPs) by 30 June 2024. As per drafts plans, only six put forward a target for the share of renewable energy in industry.

  WindEurope held a workshop on industrial electrification with the European and national public authorities and the industry on 16 April 2024. The workshop highlighted the importance of aligning energy and climate policies with industrial decarbonisation goals and infrastructure planning.

  These recommendations include specific policy measures and incentives which would enable industrial electrification focusing on the following elements:

  1. Strategies for use of renewables-based electricity in industry;
  2. Uptake of industrial process heat solutions;
  3. Taxation of electricity, tariff structure and time-differentiation;
  4. Power and Heat Purchase Agreements;
  5. Network planning;
  6. Demand side flexibility, and
  7. Funding and finance.

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• The European wind industry’s five asks for the next five years May 2024

  EU Elections 2024
  Wind energy is 20% of the electricity consumed in Europe. The EU want it to be 35% by 2030. And over half by 2050.

  Wind is cheap. And the more we have of it, the less energy we need to import.

  What’s more, the turbines in Europe’s wind farms are made in Europe.
  So it’s a strategic industry. It enhances our energy security and national security.

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• WindEurope’s response to the public consultation on design elements of renewable energy auctions March 2024

  This is WindEurope’s response to the European Commission’s public consultation on design elements of renewable energy auctions.
  The Net-Zero Industry Act that request Member States to include non-price prequalification and award criteria to 30% of their renewable energy auction and the Wind Power Package recommends to government to apply them to wind energy auctions. This answer lay down the main principles that the European Commission and national governments shall include in the upcoming guidance and secondary legislation.

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• WindEurope’s response to public consultation on Renewables Acceleration Areas March 2024

  This is WindEurope’s response to the European Commission’s public consultation on Renewables Acceleration Areas. Europe is not permitting enough new wind farms to meet the huge demand in renewables. Nor is it permitting them fast enough. According to Art 15 of the revised Renewable Energy Directive Member States need to designate so-called Renewables Acceleration Areas. If implemented properly and under the strict condition that no resources are diverted from permitting projects in other areas, Renewables Acceleration Areas may be one of the tools that can help to speed up permitting.

  It is positive that Member States are encouraged to actively think where to deploy renewables and not only to consider spatial constraints to renewables deployment. Dedicated renewables areas as acceleration areas can mainly be positive when such areas have already undergone a strategic environmental assessment. However, when done incorrectly the designation of Renewables Acceleration Areas could slow down the expansion of wind significantly. This response outlines what factors need to be considered in the designation of these areas.

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• Discussion paper on lifecycle assessments in auctions December 2023

  This discussion paper captures the ideas of the wind industry on the possible role of lifecycle assessments in wind energy auctions. The paper outlines what lifecycle assessments are and why they do not meet the principles that WindEurope identified for non-price criteria. There are also practical concerns on the relevance of lifecycle assessment-based criteria due to how auctions are run. Finally, the paper spells out several action the wind industry will take to improve the procedures for lifecycle assessments to increase comparability.

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• WindEurope’s response on the draft Network Code for Cybersecurity November 2023

  This paper presents WindEurope΄s response to the public consultation, organised by the European Commission, on the Network Code for Cybersecurity. WindEurope makes explanatory comments and gives the sector’s recommendations on topics including – but not limited to – risk assessments methodologies, involvement of stakeholders in the procedure, national compliance with the proposed network code and creation of a mapping matrix of threat intelligence and vulnerabilities.

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• WindEurope response to public consultation on draft of the new Network Code Demand Response November 2023

  This document presents WindEurope’s response to the public stakeholder consultation by EU-DSO entity and ENTSO-E on the first draft of new Network Code Demand Response. This network code covers key topics including but not limited to flexibility, congestion management and voltage services, non-firm connection agreements, voltage control using reactive power, distribution network development plans, and data exchange requirements for all grid users (generation, demand, and storage). WindEurope remarks that this first draft does not fulfil the purpose of a Network Code. Where a Network Code text is expected to detail the technical implementation of higher-level EU regulations and support the relevant authorities in the process, the high-level and vague text used fails to provide any meaningful guidance.

  WindEurope is part of the network code Drafting Committee that can review and give feedback to the NC DR Development Committee and hence will continue working on the improvement of the draft network code.

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• WindEurope statement on PFAS restriction October 2023

  In April 2023, following recommendations from five Member States, the European Chemicals Agency (ECHA) tabled a proposal to restrict the use of per- & polyfluoroalkyl substances (PFAS) in Europe. PFAS are a class of thousands of substances that are widely used in industrial and domestic applications. In the media they have been dubbed ‘forever chemicals’. Many PFAS are used in closed industrial applications with a limited impact on the environment. This includes several use cases in the energy sector.

  However, not all PFAS are the same and they can have very different environmental impacts. Indeed, some PFAS constitute significant long-term health and environmental hazards and can rightly be described as ‘forever chemicals’. But others are not bio-accumulative and break down into non-hazardous compounds after 30 years.

  Before a restriction is put in place the functionality, criticality, and availability of suitable alternatives should be assessed for each specific PFAS use. In addition, a possible restriction on PFAS should not contain retroactive measures and must be aligned with the EU’s wider climate and energy goals.

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• WindEurope response to final ACER public consultation on proposal for amendments to the Network Code Requirements for Generators (NC RfG) September 2023

  This document presents WindEurope’s response to the third and final public stakeholder consultation by ACER in the process of amendments to the Network Code requirements for generators (NC RfG). WindEurope makes explanatory comments and proposes legal text modifications on topics including but not limited to grid forming, active power forced oscillations, some key definitions such as power generating module, voltage and frequency, significant modernization, compliance simulation and general requirements for power park modules.

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• Key elements for offshore wind auction design September 2023

  Today Europe has 32 GW of offshore wind power capacity. Governments have set targets for more than 150 GW by 2030.
  We welcome this ambition and will do all that we can as an industry to deliver them. To that end, National Governments and the EU must rapidly implement the measures we need to drive accelerated offshore wind deployment. Europe must go from installing 3 GW/year today to at least 20 GW/year by the end of this decade. Dedicated policies to support scaling up the offshore wind supply chain are vital in this regard.

  This paper outlines the key regulatory options and market incentives that will allow the offshore wind sector to scale up while maximising value for Governments and societies.

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• Power grids: from bottleneck to accelerator of the energy transition September 2023

  The EU wants to install around 30 GW of new wind energy every year between now and 2030. Last year it only installed half of that. Delayed grid reinforcement and connections are among the main bottlenecks to the timely installation of new wind energy projects. But Europe cannot reach its energy and climate targets without investments in new manufacturing capacities for grid equipment. Europe’s grid equipment supply chain – substations, transformers, cables, switchgear – is not big enough today. It can produce up to 1,900 km of offshore cables a year today – Europe needs up to 3,200 km by 2030. The same is true for offshore substations. Today Europe can produce only 5 offshore high-voltage direct current (HVDC) substations a year. This needs to grow to 20 substations by 2030.

  This one-pager lays out WindEurope’s recommendations on how governments, national regulatory authorities, TSOs and DSOs can ramp up necessary grid investments and accelerate grid connection of renewables in line with Europe’s climate targets.

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• WindEurope’s position paper on the Electricity Market Design targeted reform May 2023

  The EU just raised its Renewable Energy target by 2030, from 32.5% to 42.5%. For wind, this means doubling the annual rate of development, to 31 GW p.a. However, all wind energy indicators were flashing red in 2022: Europe only invested €17bn in new wind in 2022, down from €41bn in 2021, and the lowest since 2009; Final Investment Decisions were taken for only 10 GW and not a single one in commercial scale offshore windfarm; Turbine orders were down 47% year on year.

  The co-legislators must urgently restore certainty for renewables in Europe.

  The European wind industry supports the targeted approach proposed by the European Commission. Because it strikes the right balance on the regulatory framework necessary to make investments happen, namely:

  • It allows investors to use all contractual forms for power supply generation: Contracts-for-Difference, Power Purchase Agreements, merchant investments.
  • It removes national revenue caps for inframarginal generators thus acknowledging their pure emergency nature, and pre-empting further disruption to market signals.
  • It doesn’t allow retroactive changes to support mechanisms for renewable energy investors, in line with the EU Renewable Energy Directive.

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• WindEurope’s position paper on the EU Green Deal Industrial Plan May 2023

  The EU has a big challenge ahead. It needs to double the rate of wind deployment to deliver on its new energy security strategy REPowerEU by 2030. But investments in wind energy were sharply down in 2022 and the permitting situation for wind energy projects is still not what it is supposed to be.  This is making the situation for Europe’s supply chain more precarious at a time when it should be ramping up instead. The gap in volume ambition vs supply chain capabilities is particularly acute for offshore wind. Europe also lacks a robust response to rising competitive pressures from the US and China in the global race for renewable energy investments.

  As things stand, the European Commission’s legislative proposals for a Green Deal Industrial Plan will not be sufficient to ensure Europe avoids a reliance on non-European clean technologies in its energy transition. The European wind energy industry calls on the Member States and the European Parliament to amend the proposals by:

  • Ensuring renewable energy auctions recognise European supply chains’ contribution to ‘resilience’ thanks to clear and actionable non-price criteria;
  • Removing the rule allowing auctioning authorities to opt-out of applying non-price criteria in renewable energy auctions;
  • Adding pre-qualification criteria, on cybersecurity and due diligence;
  • Increasing the size and amending the scope of EU Innovation Fund;
  • Clarifying the 36 GW annual target for wind turbine manufacturing in Europe covers the whole wind value chain. 

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• WindEurope’s position on grid forming capabilities March 2023

  With the increasing share of variable renewable energy, power system stability challenges are evolving and discussions to address them are gathering momentum. Large rotating generators such as fossil-fuel based generation, nuclear and hydropower inherently provide inertia. However, the EU Green Deal and REPowerEU set the EU target for deployment of renewable energy up to 45% by 2030. This means that converter-based renewable energy generators such as wind and solar PV will have to displace a large share of synchronous generators in operation today. With larger share of variable renewables, general system stability measures are needed to uphold secure operation of the power system. Converter-based generators may be able to contribute to system inertia and maintain system stability by acquiring certain advanced capabilities called grid forming.

  This position paper suggests a framework on how these grid-forming capabilities should be defined, developed, and funded. It is structured in three parts: recommendations for the technical framework, market design aspects and necessary regulatory changes.

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• WindEurope’s response to the European Commission’s public consultation on the EU Electricity Market Design reform February 2023

  In March 2023 the EU Commission will table its legislative proposal for a revision of the EU Electricity Market Design to enable electricity consumers to benefit from the low costs of renewable power.

  The EU Electricity Market Design reform should:

  • Prioritise building a future-proof energy market design fit for renewable energy by mid-century. The short-term challenges linked to high energy prices would be addressed more efficiently with better and faster implementation of the existing EU renewable energy acquis.
  • Confirm investment certainty in renewables and cement Articles 4 and 6 of the 2018 Renewable Energy Directive which provide visibility on volumes and support schemes’ design.
  • Respect investors’ decision-making on renewable investments by letting them make use of all available contractual forms for power supply procurement e.g. Contracts for Difference, Power Purchase Agreements, merchant investments.
  • Do not perpetuate the emergency measures on power market interventions and revenue caps on inframarginal generation beyond their original end date of June 2023.
  • Keep short-term wholesale markets based on marginal pricing and the merit order while designing climate-compatible long-term adequacy mechanisms.
  • Clarify grid connection rules for renewables and prioritise electricity grid build-out.

  Read the consultation response

• WindEurope priorities for the EU legislative proposal on Electricity Market Design December 2022

  Over the past months National Governments have intervened on Energy Markets to address very high energy prices resulting from the Ukraine war and to support European families and businesses. Europe has so far failed to propose a joined-up policy response to the energy crisis which can undermine the very fundamentals of the internal energy market. Beyond the context of the present crisis, the transition to climate neutrality requires a regulatory framework that makes electrification the natural choice for industry and households, and passes on the benefits of renewable electricity generation to all consumers.

  In this context, the European Commission is going to present a legislative proposal to adapt the EU Electricity Market Design in Q1 2023.  The European wind industry calls for a Market Design that:

  1. sends the right investment signals to deploy wind at scale;
  2. guarantees energy security;
  3. ensures a cost-effective management of a fully decarbonised energy system.

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• WindEurope response to ACER public consultation on proposals for amendments to the Network Code Requirements for Generators November 2022

  This document presents WindEurope’s response to the second stakeholder consultation by ACER in the process of amendments to the Network Code requirements for generators. The comments and text proposals have been made including but not limited to the topics of energy storage, significant modernisation, compliance verification, LFSM-U response simulation, active power forced oscillations and grid forming.

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• The EU Raw Materials Act – WindEurope’s contribution to the European Commission consultation November 2022

  As announced by Commission President Ursula von der Leyen in its Annual State of the Union in September, the European Commission is working on a legislative proposal to boost autonomy and resilience for key raw materials. WindEurope has contributed to the Commission’s public consultation to provide our industry’s priorities. To succeed in its green transition, Europe needs to significantly increase its renewable energy capacity, and in particular to reach 510 GW of wind energy installations by 2030 (as compared to 190 GW today). Manufacturing wind turbines and components requires stable, secure supply and cost-competitive supply of raw materials such as concrete, iron, and steel that make up more than 90% of the mass of a turbine, including the foundation. In addition, aluminium, chromium, copper, manganese, molybdenum, nickel, and rare earth elements (e.g., neodymium, dysprosium, praseodymium) are used in wind turbine components. For most of these materials the local supply is under constraint and imports are subject to duties and other restrictions. The new EU Raw Materials Act can help address some of the challenges faced by the European wind supply chain and ensure it can deliver cost-competitively the objectives set by REPowerEU and the long-term European decarbonisation goals.

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• WindEurope suggested amendments to F-gas regulation October 2022

  WindEurope welcomes the European Commission’s proposal on a new regulation on fluorinated greenhouse gases that will ensure the gradual phase-out of SF₆ in electrical switchgear. But the proposed SF₆ phase-out must be done on a timely and realistic manner to ensure the supply chain can scale up production of all necessary SF₆-free solutions.

  The phase-out of SF₆ must also not undermine the safe operation of existing grid infrastructure. Retroactive measures will reduce the safety and reliability of the power grid, create additional supply bottlenecks, and slow down the deployment and connection of new wind farms.

  We therefore recommend policymakers to amend the proposed F-gas regulation by:

  • Setting a single and clear threshold of 1,000 Global Warming Potential for high-voltage electrical switchgear to support a competitive market of low impact SF₆-free equipment.
  • Adjusting the definition of ‘placing on the market’ to acknowledge the long lead-time of projects in the energy sector, most notably grid development projects.
  • Allowing exemptions for spare parts and components necessary to maintain existing electrical infrastructure.
  • Including technology maturity and market availability as evidence criteria for possible exemptions.

  Read our suggested amendments

• WindEurope’s position paper on Renewable hydrogen August 2022

  The EU has prioritised renewable hydrogen as part of REPowerEU, its energy response to the Ukraine war. REPowerEU sets a target of 20 million tonnes of renewable hydrogen to be consumed in the EU by 2030, half of which would be produced domestically.

  To deliver on these ambitions, the EU must set a clear and actionable definition of renewable hydrogen, guarantee a level playing field between domestic production and imports, target the right end uses (aviation, shipping, parts of industry), and develop and finance infrastructure accordingly. This is key to scaling up renewable hydrogen towards competitiveness this decade.

  The following position paper recaps WindEurope’s renewable hydrogen-related positions on the Renewable Energy Directive, the Delegated Act on Renewable Fuels of Non-Biological Origin, the Carbon Border Adjustment Mechanism, and the ‘gas package’.

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• WindEurope response to ACER public consultation on the policy paper on the revision of the Network Code Requirements for Generators and Network Code Demand Connection June 2022

  This document presents WindEurope’s views on the areas that ACER suggests for amendments in the two Network Codes as well as on a list of additional major areas that should not miss the opportunity of being reviewed, based on the experience gained from the implementation of the Network Codes across the EU since some years now, and being adjusted to evolving needs and more ambitious EU decarbonisation targets.

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• Industry recommendations on accelerating permitting for wind energy May 2022

  On 18 May 2022, the European Commission published its “REPowerEU Action Plan”: a set of initiatives that will help the European Union to wean itself off Russian fossil fuel dependency by fast forwarding renewables build-out. Crucially, the REPowerEU Action Plan acknowledges the need for wind energy permitting to be “drastically accelerated”. The Commission therefore tabled a new legislative proposal on renewables permitting, and presented recommendation and guidance to Members States for simplifying processes.

  In addition to the European Commission’s steer, the European wind industry is sharing with national Governments a full list of measures they can additionally take to simplify and accelerate permitting for renewables. These include for instance applying common sense spatial planning rules, streamlining judicial frameworks to maximum 2 legal appeals, or applying the principle of “positive silence’ to all renewable energy projects.

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• WindEurope position on non-price criteria in auctions April 2022

  The allocation of support schemes to wind is determined by State-run auctions.  This is a requirement under the EU Renewable Energy Directive (Article 4) and the EU State aid policy.  It has been a long-standing practice in EU and national regulations that auction winners are decided solely on the basis of the price they offer for procuring electricity – the so-called ‘price-only’ rule where the cheapest bid wins.  However, more and more EU Governments have been and continue experimenting with non-price criteria in their auction design, notably in offshore wind.  And the new EU State aid rules, applicable as of January 2022, allow EU Member States to rank the bids in an auction with non-price criteria for up to 30% of the total score should they wish to do so.

  This paper sets out the initial views of the European wind industry on the design of non-price criteria in auctions that can best support the EU’s long-term decarbonisation goals and the short-term objectives of decreasing Europe’s independence on Russian fossil fuels through renewables “made in Europe”.

  We recommend that non-price criteria in wind energy auctions:

  • Complement, but do not duplicate, existing policy instruments
  • Are clear, objective, comparable, easy to assess / measure / monitor
  • Do not create additional administrative or management costs
  • Build upon the wind industry’s strengths and incentivise incremental innovation
  • Are matched up by equal and coordinated policies in adjacent economic sectors and supply chains
  • Prioritise three categories of criteria:
    • Sustainability & Biodiversity
    • System integration & Innovation
    • European supply chain development & benefits to communities

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• WindEurope response to the European Commission’s public consultation on accelerating renewables Permitting and PPAs April 2022

  Wind energy will play the biggest role in providing clean and competitive power for the EU to become climate neutral in 2050. The current geopolitical situation is only accelerating this trend: the European Commission’s REPowerEU communication increases the wind energy installation target for 2030 by 30 GW. But slow and cumbersome permitting processes for renewable energy projects remain the key bottleneck to the EU’s Climate & Energy, and energy security goals.

  In this response we outline recommendations for simplifying the permitting for new and repowered wind energy projects that the Commission should include in its upcoming EU Permitting Guidance. These touch upon the administrative approval processes, site selection, grid connection, legal challenges, and the Commission’s role in overseeing compliance.

  We also spell out recommendations for removing remaining regulatory barriers for the uptake of renewable Power Purchase Agreements (PPAs).

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• WindEurope position on Market Design: driving investments towards a climate-neutral and energy secure Europe April 2022

  Europe is committed to becoming climate neutral by 2050. This requires ramping up wind capacity from 190 GW today to 1,300 GW driving the renewables-based electrification of our economy. The current geopolitical situation and resulting energy crisis put into even sharper focus the need to accelerate the transition to home-grown zero-carbon energy. This paper recommends the required adjustments to the energy market design to

  1. send the right investment signals to deploy the needed wind volumes
  2. guarantee energy security
  3. ensure a cost-effective management of a fully decarbonised energy system.

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• WindEurope Statement: More renewables means huge investments, so don’t tamper with market rules March 2022

  The expansion of renewables requires huge levels of new investment. This in turn requires regulatory stability. Europe’s electricity market rules provide such stability. To tamper with them, e.g. by allowing governments to change the rules on how prices are set, would remove that stability and freeze investments.

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• WindEurope Statement: Ukraine and beyond – energy policy is security policy March 2022

  The European wind energy community is deeply saddened by the invasion of Ukraine. As an industry that has companies, partner associations and colleagues operating in Ukraine, we stand in solidarity with the people of Ukraine. A rapid expansion of wind and other renewables is now key to increase Europe’s energy security.

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• European wind energy supply chain struggling, Green Deal at risk February 2022

  To reach its 40% renewable energy target for 2030, the EU needs to build 30 GW of new wind a year. But it built only 11 GW in 2021 and is set to build only 18 GW a year over the next five years. These low volumes undermine the Green Deal. And they’re hurting Europe’s wind energy supply chain. In a letter to Commission President Ursula von der Leyen WindEurope CEO Giles Dickson and the CEOs of the five European wind turbine manufacturers Enercon, GE, Nordex, Siemens Gamesa and Vestas highlight that the European wind energy supply chain is in not in good health.

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• A cybersecurity framework fit for wind energy January 2022

  The Network Information Security (NIS) Directive is currently under revision – foreseen to conclude by the end of 2021 – and the Network Code for Cybersecurity (NCCS) is currently under development and foreseen to be in force by the end of 2023. Considering these regulatory developments, this paper highlights specific cybersecurity needs that should be shaping upcoming security rules for wind farm owners and operators and for wind turbine and component manufacturers. It also suggests best practices and existing international standards to be considered in the design of such requirements.

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• WindEurope response to Ireland’s ORESS1 draft terms and conditions December 2021

  This letter presents WindEurope’s support to Wind Energy Ireland’s response to the Public consultation on the draft Terms and Conditions of the First Offshore Competition under the Renewable Electricity Support Scheme (ORESS 1). The RESS scheme will be crucial to deliver the first phase of offshore wind projects as part of the country’s 5 GW target by 2030.

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• Scaling up Floating Offshore Wind towards competitiveness November 2021

  Today 113 MW operate using floating foundations and have shown outstanding performance, including the highest capacity factors in the wind sector. The time has come for the technology to move to commercial scale.

  By 2050 floating wind could make up as much as a third of all offshore wind capacity. If national governments deliver on time their ambitions and announced plans, Europe will see 7 GW of floating wind by 2030. WindEurope believes that building at least 7 GW by 2030 in Europe would bring down the cost to €53-76/MWh. Europe can only meet these volume and cost targets if the right policies are in place.

  Europe today is a leader in floating wind technology worldwide and scaling up will only widen the social and economic benefits that offshore wind offers. To this end Governments, policymakers, industry, financing institutions and all stakeholders need to work together to develop this framework.

  This paper sets out industry views on the policies that National Governments and European Institutions need to take to help develop commercial floating wind farms.

  We call on the EU and National Governments to:

  1. Review National Energy and Climate Plans in line with the EU’s increased climate and energy targets and allocate areas for floating wind through Maritime Spatial Plans;
  2. Set technology-specific auctions for floating offshore wind including schedules, frequency, volumes, evaluation criteria and combine these auctions with remuneration mechanisms that stabilise revenues;
  3. Tackle financing costs through institutions (i.e., the European Investment Bank, etc.) acting as guarantor for large floating wind projects by assuming specific risks.
  4. Make floating grid connections (i.e., floating wind substations, dynamic export cables, landing points, etc.) a top priority for EU research and TSOs by working on solutions that will bring electricity to shore.
  5. Facilitate industrialisation of the supply chain, ports, and other mass-production infrastructure that are specific to floating wind.

  The paper also gives an overview on floating wind policy in eight European countries.

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• Setting the course towards climate neutrality – WindEurope position on the ‘Fit for 55’ package – updated version October 2021

  The European Green Deal requires an acceleration of the rate of expansion of onshore and offshore wind. A 25-fold increase in offshore wind capacity and an even bigger increase in GW in onshore wind capacity. Member States have now agreed to ratchet up the EU 2030 greenhouse gas emission target from 40% to at least 55% to deliver the Green Deal. This will trigger an upward revision of the EU’s 2030 renewable energy target from 32% today to 38%-40% according to the European Commission’s Impact Assessment.

  This means the EU wind energy capacity would need to be 433-452 GW by 2030 (361-374 GW onshore and 73-79 GW offshore) for 38% and 40% targets respectively. This is almost a threefold increase on the 179 GW installed today. And 90 GW more than what EU-27 pledged in their 2030 National Energy & Climate Plans.

  The EU built 10.5 GW of new wind energy capacity in 2020 and is expected to install 15 GW per year in the period 2021-2025. The EU needs to build 18 GW per year over 2021-30 to deliver the existing 2030 EU renewable energy target and 27 GW per year to deliver the higher target foreseen by a 55% greenhouse gas emission reduction by 2030.

  The benefits of an accelerated buildout will be significant. The EU wind energy sector supports 300,000 jobs, generates €37bn to EU GDP and €5bn in local taxes pa. It operates 248 factories across the EU. Each new wind turbine installed in Europe contributes €10m of economic activity. Onshore and offshore wind are the most cost-competitive sources of new power generation in most of Europe.

  But current policies will not deliver these numbers – neither on volumes, nor on economic benefits. Higher targets are necessary but not sufficient. Europe needs stronger delivery, monitoring, and enforcement measures to ensure 2030 is a steppingstone towards a climate neutral energy system.

  This paper sets out WindEurope’s priorities for the EU’s ‘Fit for 55’ legislative package. It is an updated version of our position paper from March, following the publication of the package on 14 July.

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• WindEurope response the EU suggested action plan for digitalising the energy sector September 2021

  WindEurope’s feedback to “Action plan on the digitalisation of the energy sector”, published by the European Commision , aiming at developing a competitive market for digital energy services and digital energy infrastructure.

  Our suggestion is to also include these focus areas in the action plan:

  • Need for commonly used data taxonomy and standards
  • Strategies to address skill gaps.
  • Focusing on the safety and well-being of energy staff.
  • Sustainable digitalisation.

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• WindEurope response to the UK Office of Gas and Electricity Markets on Offshore Transmission Network Review: Changes intended to bring about greater coordination in the development of offshore energy networks. September 2021

  This paper presents WindEurope’s response to Ofgem consultation on the Offshore Transmission Network Review (OTNR). The purpose of the consultation is to increase coordination, design, and delivery of offshore transmission infrastructure in the UK and neighbouring countries to deliver the UK’s offshore wind targets to 2030 and beyond.

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• WindEurope response to Ministry of Petroleum and Energy of Norway on white paper August 2021

  This letter presents WindEurope’s response to the public consultation on the white paper that sets the framework for the development of offshore wind in Norway. This includes recommendations for the two areas Utsira Nord and Southern North Seas II for a total 4.5 GW of offshore wind capacity.

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• WindEurope response to Public Consultation on the Draft of the Roadmap for the Development of Offshore Wind and Ocean Energies in Spain August 2021

  This paper presents WindEurope’s response to Minister for the Ecological Transition and the Demographic Challenge (MITECO) consultation to the Draft Spanish Offshore Wind Roadmap. The response reiterates our previous recommendations for the elements missing in the current draft.

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• WindEurope’s response to the European Commission’s consultation on the new Guidelines on State aid for climate, environmental protection and energy 2022 August 2021

  The EU’s climate neutrality requires 1,300 GW of wind power by 2050 and a doubling of the annual wind energy installation rates. EU State aid rules are key to creating the conditions for a cost-effective transition to a climate neutral economy. This consultation response outlines the recommendations of the European wind industry on the post-2021 State aid provisions that support an accelerated deployment of wind energy and continued cost reductions.

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• WindEurope response to ENTSO-E consultation about options for the design of European Electricity Markets in 2030 June 2021

  This paper presents WindEurope’s response to ENTSO-E consultation about options for the design of European Electricity Markets in 2030. Our focus is on renewables’ and consumers participation in wholesale markets, the design of Day-Ahead, Intra-Day markets and Balancing markets, congestion management, locational pricing and local flexibility markets, market design to ensure adequacy, capacity mechanisms, renewables’ financing and ancillary services.

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• How to build a circular economy for wind turbine blades through policy and partnerships June 2021

  The wind industry is committed to achieve the full recyclability of our turbines in line with the EU’s Circular Economy Action Plan and the ambitions of the EU Green Deal.

  So the wind industry is calling for a Europe-wide landfill ban on decommissioned wind turbine blades by 2025. This means the industry commits to re-use, recycle or recover 100% of decommissioned blades. This landfill ban would accelerate the development of sustainable recycling technologies for composite materials.

  The position paper further highlights four pillars of action to achieve full recyclability:

  • Increasing funding on research and development (R&D) for evaluating and scaling-up diversified blade recycling technologies (with a focus on industrial upscaling and commerciailsation);
  • Incentivising the use of recycled composite materials in new products;
  • Increasing funding on R&D for the development and use of new (recyclable) blade materials; and
  • Establishing a European cross-sectorial platform (including all composite waste producing sectors) and sharing good practice.

  The wind industry will develop an industry roadmap further detailing the steps required to accelerate wind turbine blade circularity. This roadmap will focus on four workstreams:

  • implementing the landfill ban,
  • achieving full recyclability of existing blades in the future,
  • making future blades fully circular and
  • engaging with other sectors.

  It will require commitment from policy makers, other composite users and recovery and recycling players to make these commitments a reality.

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• NIS Directive – WindEurope’s recommendations for the adopted act on the “Proposal for a Directive of the European Parliament and of the Council on measures for a high common level of cybersecurity across the Union” March 2021

  This paper summarizes WindEurope’s recommendations for the European Commission’s modernisation proposal of the Directive (EU) 2016/1148 on Security of Network and Information Systems (NIS Directive). The recommendations focus on the need:

  • to further specify the type of “essential” and “important” entities of the energy and electricity sectors targeted by the suggested measures
  • to recommend the wide application of international standards developed for OT and IT security of distributed renewable energy assets and their technologies

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• Setting the course towards climate neutrality – WindEurope position on the ‘Fit for 55’ package March 2021

  The European Green Deal requires an acceleration of the rate of expansion of onshore and offshore wind. A 25-fold increase in offshore wind capacity and an even bigger increase in GW in onshore wind capacity. Member States have now agreed to ratchet up the EU 2030 greenhouse gas emission target from 40% to at least 55% to deliver the Green Deal. This will trigger an upward revision of the EU’s 2030 renewable energy target from 32% today to 38%-40% according to the European Commission’s Impact Assessment.

  This means the EU wind energy capacity would need to be 433-452 GW by 2030 (361-374 GW onshore and 73-79 GW offshore) for 38% and 40% targets respectively. This is almost a threefold increase on the 179 GW installed today. And 90 GW more than what EU-27 pledged in their 2030 National Energy & Climate Plans.

  The EU built 10.5 GW of new wind energy capacity in 2020 and is expected to install 15 GW per year in the period 2021-2025. The EU needs to build 18 GW per year over 2021-30 to deliver the existing 2030 EU renewable energy target and 27 GW per year to deliver the higher target foreseen by a 55% greenhouse gas emission reduction by 2030.

  The benefits of an accelerated buildout will be significant. The EU wind energy sector supports 300,000 jobs, generates €37bn to EU GDP and €5bn in local taxes pa. It operates 248 factories across the EU. Each new wind turbine installed in Europe contributes €10m of economic activity. Onshore and offshore wind are the most cost-competitive sources of new power generation in most of Europe.

  But current policies will not deliver these numbers – neither on volumes, nor on economic benefits. Higher targets are necessary but not sufficient. Europe needs stronger delivery, monitoring, and enforcement measures to ensure 2030 is a steppingstone towards a climate neutral energy system.

  This paper sets out WindEurope’s priorities for the EU’s ‘Fit for 55’ legislative package.

  Read the position paper

• WindEurope’s answer to the European Commission roadmap on the Hydrogen & Gas Markets Decarbonisation Package March 2021

  WindEurope believes that a rapid renewables-based electrification is the most cost-effective way to decarbonise our economy and reach climate neutrality by 2050. The direct use of this renewable electricity should be prioritised where it is the most cost-effective and energy efficient decarbonisation pathway. Renewable electricity should also be used to produce renewable hydrogen in activities which otherwise cannot reduce CO₂ emissions, such as the hard-to-abate sectors.

  WindEurope welcomes the European Commission’s (EC) combined roadmap and inception impact assessment on the Hydrogen & Gas Markets Decarbonisation Package, and calls for it to:

  • Foster renewable hydrogen in the hard-to-abate sectors;
  • Ensure the development of a competitive European hydrogen market; and
  • Accelerate the deployment and reinforcement of cost-efficient energy infrastructure.

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• Making wind farms and the power system more interoperable: Focus on data exchange March 2021

  This position paper looks into current data exchange obligations and practices between wind farms and System Operators across Europe, the ongoing implementation of the relevant regulation (Key Organisational Requirements, Roles and Responsibilities (KORRR) relating to Data Exchange, System Operations Guideline) and the wide use of recommended standards. The KORRR methodology leaves a lot of flexibility to National Authorities for the implementation of rules which is helpful for addressing system specific needs. However at this implementation stage much stronger harmonisation effort and technical guidance are needed at EU level to ensure a cost-effective management of the energy system, to enable interoperability and flexibility and to account for legacy systems in operation.

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• WindEurope’s response to ENTSO-E stakeholder consultation on “Connection Network Codes revised Implementation Guidance Documents – November 2020 January 2021

  This report presents WindEurope’s response to ENTSO-E stakeholder consultation on “Connection Network Codes revised Implementation Guidance Documents November 2020”. The revised Implementation Guidance (IGD) documents cover important aspects for the national implementation of Network Codes such as parameters of non-exhaustive requirements, frequency ranges and compliance verification including compliance testing and use of equipment certificates.

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• The revision of the Energy & Environment State Aid Guidelines – WindEurope response to the European Commission consultation January 2021

  WindEurope welcomes the possibility to provide input to the revision of the Environment and Energy State Aid Guidelines (EEAG). State aid rules are of utmost importance for the development of the wind energy sector as they represent the tool used by the European Commission to assess the compatibility of national support mechanisms for renewable energy with internal market rules.

  Aligning the European State aid policy with the Green Deal objectives means for the European Commission to:

  • Ensure revenue stabilisation mechanisms like two-sided Contracts for Difference or sliding feed-in premiums are applied by Governments
  • Continue to support technology-specific auctions
  • Ensure Governments provide long-term visibility on wind energy volumes in auctions
  • Ensure corporate Power Purchase Agreements and market-based support mechanisms (such as Contracts for Difference) coexist as revenue stabilisation mechanisms.
  • Ensure Guarantees of Origin are given to all renewable energy produced
  • Ensure industrial and commercial consumers transition to an electricity-based energy supply
  • Ensure that the guidelines factor in the contribution of renewable-based electrification
  • Ensure the EEAG reflect the contribution of renewable hydrogen in delivering climate neutrality
  • Provide a level-playing field between fossil fuel and electricity taxes

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• WindEurope response to ENTSO-E Consultation on the TYNDP 2020 “Power system needs in 2030 and 2040” report and accompanying documents January 2021

  This report presents WindEurope’s response to ENTSO-E stakeholder consultation of the TYNDP 2020 “Power system needs in 2030 and 2040” report and some of its accompanying documents (“Power system needs 2030 briefs at PCI corridor level” report, “The inertia challenge in Europe: present and long-term perspective” report, “System dynamic and operational challenges” report).

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• WindEurope feedback to the “draft Taxonomy Delegated Act” January 2021

  WindEurope welcomes the draft Commission Delegated Regulation supplementing Regulation (EU) 2020/852 on the definition of the economic activities that could be considered substantially contributing to climate change mitigation or adaptation, while not significantly harming the other environmental objectives.

  Wind energy is generally well captured in the draft Delegated Act, recognising its positive impact to mitigate climate change in line with the EU Green Deal objectives. However, we would like to suggest some changes in the screening criteria in sections 3.1 and 4.3 of Annexes I and II, outlined in page 3 of this response. These would better reflect the higher expectations that investors, Governments, and society have on wind energy.

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• Industry Principles for Supply Chain Sustainability January 2021

  This document contains the guiding principles for sustainability in the wind energy supply chain. The Industry Principles reflect an aspirational benchmark for industry behaviour including its relevant business partners in the supply chain. They are comprehensive set of principles taken from different companies’ supplier codes of conduct and internationally accepted standards. The Principles have a voluntary character for adoption. They represent the first building block for further work to develop and adopt an industry-wide approach for assessing, controlling and monitoring supply chain sustainability. The document has been produced by the WindEurope Sustainability Working Group which continues to develop such approach. This document does not replace individual company codes of conduct.

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• 8 “to dos” for Governments to deliver the expansion of onshore wind needed for the Green Deal November 2020

  Europe wants to be climate neutral by 2050. And onshore wind will play a central role in that. According to the European Commission‘s decarbonisation scenarios it will be a quarter of Europe’s electricity consumption by 2050. That requires a 4-fold increase in the volume of onshore wind capacity between now and then. And full delivery of the EU 2030 Climate & Energy objectives. Here are the European wind industry 8 policy recommendations for Governments on how to deliver that.

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• A renewed trade policy for a stronger Europe – WindEurope’s response to the EU public consultation November 2020

  Global supply chains are a source of strength for the European wind industry. With production facilities all over the world it makes sense for European manufacturers to rely on global suppliers from a flexibility, competition and cost perspective. This contribution responds to the questions posed by the European Commission in its consultation note published on 16 June 2020. The results of the consultation will feed into a new EU trade strategy that is expected to be published in early 2021.

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• WindEurope response to the European Commission public consultation on the revision of the Energy Taxation Directive October 2020

  WindEurope welcomes the European Commission public consultation on the revision of the Energy Taxation Directive. We believe The ETD should support renewables-based electrification, primarily direct and then indirect electrification, but also renewable based hydrogen produced via electrolysis powered by wind and solar for the so-called “hard to abate sectors” (e.g. maritime, aviation, heavy industry etc.)

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• WindEurope’s feedback on the suggested EC Companion Guide for technical requirements for connections to offshore HVDC grids in the North Sea September 2020

  This document presents WindEurope’s view on the Companion Guide, a non-binding document that has been suggested as the main deliverable of the ongoing EC study on “Technical requirements for connections to offshore HVDC grids in the North Sea”, deployed by Tractebel. The goal of this study is to propose a voluntary set of technical guidelines – presented in the Companion Guide – for offshore hybrid projects by identifying the need for harmonization on the national implementation of the EU Network Codes between the various Member States and potential technical barriers not covered by the existing Network Codes, and by implementing/clarifying the relevant regulation when this would be applied for offshore hybrid projects.

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• WindEurope response to UK’s Marine Energy Call for Evidence September 2020

  This paper presents WindEurope’s response to the UK Department for Business, Energy and Industrial Strategy (BEIS) on the Call for Evidence on the potential of marine energy projects in Great Britain. Today offshore wind is one of the cheapest, most scalable and reliable renewable energy technologies not only in the UK but across Europe. And as larger turbines and wind farms move projects deeper into the sea, floating offshore wind will deliver projects where bottom fixed foundations have limitations.

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• WindEurope feedback on the revision of the Renewable Energy Directive September 2020

  WindEurope strongly supports the new target of at least 55% Greenhouse Gas (GHG) emission reduction by 2030 as an urgent measure to comply with the Paris Agreement and its ambition to limit global warming to 1.5°C. Reaching this target is crucial to avoid postponing the bulk of efforts to the post-2030 period which would create a risk of missing the 2050 climate-neutrality objective.

  To ensure the optimal deployment of renewable energy technologies and grasp all the benefits they bring along, it is fundamental for the EU and its Member States to provide regulatory stability, incentives and long-term visibility to investors. Well-designed and implemented policies remain critical to unlock the necessary investments in renewable technologies for delivering the EU Climate & Energy objectives. This means providing clear information on timeline, volumes and budget of the pipeline of renewable energy installations. It also means overcoming barriers to renewable energy deployment such as long and complex permitting processes that today represent the biggest bottlenecks to wind and other renewable energy installations. It means planning ahead how to electrify with renewables buildings, industrial processes, and the transport sector.

  The Renewable Energy Directive will be critical to delivering on the EU’s climate and energy targets and should reflect the increased ambition on greenhouse gas emissions reductions to 2030.

  Check our key asks for a revision of the Directive that supports the 55% GHG emission reduction target by 2030.

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• Making the most of Europe’s grids: Grid optimisation technologies to build a greener Europe September 2020

  Given the major role that wind and solar will play in the EU power system, this position paper identifies specific grid optimisation technologies and their contribution to maximising grid capacity use thus allowing for more wind integration in the short and in the long term, and presents a set of policy recommendations that would allow their wide deployment in Europe.

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• Response to Inception Impact Assessments Revision of the Directive on the promotion of the use of energy from renewable sources and of the Directive on energy efficiency September 2020

  The Electrification Alliance welcomes the initiative by the European Commission to review the Renewable Energy Directive and the Energy Efficiency Directive to allow a cost-efficient integration of renewables in all energy end uses, to increase demand-side flexibility and system efficiency. And the Alliance recommends the following actions for a successful revision of the Renewable Energy and Energy Efficiency Directives:

  1. Adopt an upwards revision of the EU’s 2030 renewable and energy efficiency targets to support the increased 2030 greenhouse gas emissions target, including an update of the sectoral target for the use of renewable energy in heating
  2. Prioritize direct electrification of all end-use sectors combined with energy demand reduction and the deployment of renewable electricity sources, as the most cost-effective way to decarbonise the EU
  3. Ensure that administrative procedures support the development of renewable energy projects to successfully meet the EU renewable energy target
  4. Enhance demand-side flexibility across all sectors to smartly manage an energy system with large shares of renewables and to reduce unnecessary grid investments
  5. Ensure the Primary Energy Factor supports increased system efficiency delivered by electrification in end-use sectors
  6. Create a Clean Energy Package Implementation Platform to promote best practices in Member States’ decarbonisation strategies and share technical guidance
  7. Renewable-based indirect electrification could play an important role to decarbonise “hard to abate” sectors such as heavy industry, aviation, and shipping, where direct electrification may be less cost effective

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• WindEurope feedback on the roadmap & inception impact assessment on the revision of the Energy Efficiency Directive September 2020

  Decarbonising the economy and reaching carbon neutrality by 2050 require reducing resources demand – through energy efficiency, circular economy, or lifestyle/behaviour changes as well as technology options to decarbonise the energy supply – like fuel-switching, renewable energy sources.

  To this end, WindEurope calls for the roadmap and the inception impact assessment of the European Commission on the Energy Efficiency Directive revision to:

  • Be aligned with the European Green Deal and the EU Recovery Plan and to recognise the role of renewable electricity in the decarbonisation process; and
  • Revise the value of the Primary Energy Factor to trigger the use of electricity where and when it is most efficient option.

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• Response to the public consultation on the Renewed Sustainable Finance Strategy August 2020

  This document sets out WindEurope’s response to the European Commission’s consultation on the Renewed Sustainable Finance Strategy. The Sustainable Finance Strategy is being designed to channel capital towards sustainable investments, encourage consideration of sustainability and long-term risks into risk management strategies and improve transparency of green investments.

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• Response to the EIB consultation on the Climate Bank Roadmap 2021-2025 August 2020

  This document sets out WindEurope’s response to the European Investment Bank’s consultation on their 2021-2025 Climate Bank strategy. The consultation seeks to provide guidance to the EIB on how they can best achieve their ambitions over the period 2021-2025 and transition to the European Climate Bank.

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• WindEurope response to the European Commission roadmap on Sustainable and Smart Mobility Strategy July 2020

  The European Union is at the forefront of international efforts to combat climate change. The European Green Deal has set ambitious targets: climate neutrality by 2050 & reducing transportrelated greenhouse gas emissions by 90% by 2050. Transport is the only sector in Europe in which emissions have increased in the last decades. Today, transport emissions represent more than 25% of Europe’s greenhouse gas emissions. And European transport needs are expected to grow by 2050, hence the urgency to tackle this issue.

  WindEurope welcomes the European Commission roadmap on the Sustainable & Smart Mobility Strategy and calls for this Strategy to:

  1. Boost the development of zero-emission vehicles and to be aligned with the European Green Deal & Recovery Plan
  2. Foster the necessary infrastructure for the uptake of zero-emission transport
  3. Factor in consumers acceptance and incentives to achieve zero-emission mobility

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• WindEurope response to targeted consultation on TEN-E Regulation revision July 2020

  This paper is WindEurope’s position for the revision of the Trans-European Networks for Energy (TEN-E) Regulation. The Regulation is an important document for the wind energy sector as it lays down the rules for the identification of Projects of Common Interest (PCIs) which are eligible for funding under the Connecting Europe Facility.

  To align with the 2030 and 2050 decarbonisation commitments, the TEN-E will need to broaden its scope and allow for more electricity infrastructure categories. A new category for offshore wind hybrid projects is a good example as these projects combine both transmission and generation elements, linking two or more countries and providing a platform for coordination between them. The links between countries mean that power can be used where it is most needed. This makes the energy system more efficient, allowing to trade energy from where it is cheaper, increasing the use of the infrastructure and reducing the overall environmental footprint. Furthermore, the new regulation should address the better enforcement of the ‘special’ permitting status for PCIs. Furthemore, making the right choices for the future of Europe’s energy infrastructure lies within the governance process to choose and support the right infrastructure projects/PCIs. WindEurope calls for a more active role of the demand side, an independent technical expert body which would provide an evidence-based opinion and guidance on energy scenarios and a stronger oversight of the European Parliament on the final list of PCIs.

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• WindEurope response to consultation on elements to draft the Spanish Offshore Wind Roadmap July 2020

  This paper presents WindEurope’s response to Minister for the Ecological Transition and the Demographic Challenge (MITECO) consultation on the elements to be included in the draft Spanish Offshore Wind Roadmap. The recommendations include:

  • Setting an timetable of auctions with dates, volumes and ceiling prices
  • Provide support mechanisms
  • Reserve grid access and coordinate with transmission infrastructure
  • Simplify administrative process and use one-stop shop
  • Evaluate long term objectives to 2040 and 2050 according to EU targets

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• WindEurope response to the consultation on the EU Climate and Energy Ambition for 2030 July 2020

  Our key asks are:

  • At least 55% GHG emission reduction target by 2030. Pursuing this target will avoid postponing the bulk of climate & energy efforts to the post-2030 period;
  •  This translates into a renewable energy target higher than the current 32% by 2030;
  • The new target should be enshrined in the Renewable Energy Directive and Governance Regulation.

  Setting higher EU targets is important to drive the transition, but to make investments happen robust measures and policies need to be implemented at Member States level:

  • The National Energy and Climate Plans are ‘investment brochures’ that should spell out ambitious policies and provide long-term visibility to the renewable energy sector;
  •  Technology-specific auctions are crucial to provide certainty to investors and well-designed premiums are essential to reduce the cost of capital. Two-sided Contracts for Difference are the best model, paired with corporate renewable Power Purchase Agreements where applicable. The revision of the Energy & Environment State Aid Guidelines should fully support it;
  •  Short and simplified permitting for new and repowered wind and other renewable energy installations is crucial to unlock renewable energy investments;
  • Renewable-based direct electrification is essential to decarbonisation. Direct electrification in most of industry, transport and buildings should come first. Indirect electrification via renewable hydrogen will have a key role to play in decarbonising hard-to-abate sectors;

  Read our full response

• Wind industry commitments on community engagement June 2020

  This position paper summarises WindEurope’s strong commitment to working with local communities across Europe.  It outlines three guiding principles that the wind industry commits to follow as a model of best practice for good community engagement:

  • early, transparent and comprehensive information and communication;
  • direct engagement of key local actors and activation of the local economy; and
  • highlighting how communities will benefit from the investments being made.

  These principles should apply at every stage of a project, from site selection and pre-application, planning, construction to operation and decommissioning. This document will be the base for the Secretariat’s narrative to demonstrate the industry’s commitment to working with communities and to showcase the benefits and local added value the wind industry creates.

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• The EU Offshore Renewable Energy Strategy June 2020

  This position paper outlines WindEurope’s priorities for the Offshore Renewable Energy Strategy being prepared by the European Commission and to be in launched October 2020. According to the European Commission, Europe needs between 230 and 450 GW of offshore wind capacity by 2050, making it a pillar in the energy mix together with onshore wind and other renewables. Achieving such volumes requires a European coordinated approach given the challenges industry and Governments face in delivering such a huge increase in offshore wind capacity.

  The paper sets out the key actions for the EU to make this happen.

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• Response to the public consultation on the Renewable Energy Financing Mechanism June 2020

  This paper sets out WindEurope’s response to the European Commission’s consultation on the draft Implementing Regulation of the Renewable Energy Financing Mechanism. The Mechanism, whose legal basis is in the Governance Regulation, has the double purpose of filling the gap in case the EU is not on track with the achievement of the 32% renewable energy target by 2030, and of boosting the deployment of renewable energy projects in Europe. If well designed and implemented, the Mechanism is an important instrument to reach the 2030 – and 2050 – European climate and energy targets.

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• WindEurope feedback to the inception impact assessment on the revision of the guidelines for trans-European energy infrastructure (TEN-E) June 2020

  WindEurope welcomes the European Commission’s feedback period on the inception impact assessment for the revision of the guidelines for trans-European energy infrastructure (TEN-E). Our 8 key recommendations are the following:

  Long-term vision

  1. Revise the TEN-E regulation making sure that it is fully in line with the EU’s 2030 and 2050 decarbonisation commitments;
  2. Align the TEN-E revision with a revised Ten-Year Network Development Plan (TYNDP) governance;

  Scope

  3. Include a category for offshore hybrid projects;
  4. Increase the deployment of smart grids and smart sector integration;
  5. Ensure the TEN-E revision includes clear eligibility criteria for renewable gases and gas infrastructure repurposing/retrofitting;

  Implementation

  6. Further simplify permitting procedures;
  7. Ensure ex-post monitoring of selected projects;

  Financing

  8. Align the TEN-E revision with EU financing mechanisms.

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• WindEurope answer to the European Commission roadmap on the Hydrogen strategy June 2020

  Renewable-based electrification is the most cost-effective way to reach climate neutrality by 2050. The direct use of this renewable electricity whenever is available and wherever is possible, across all sectors of the economy (especially in the easy-to-abate-sectors), should be prioritised. Renewable electricity should be used to produce zero-carbon gases and fuels such as hydrogen, only where necessary, in activities which cannot reduce CO₂ emissions otherwise (e.g. the hard-to-abate sectors).

  The Hydrogen Strategy is an important strategy to deliver decarbonisation, especially in the hard-to-abate sectors. WindEurope welcomes the European Commission roadmap on the Hydrogen Strategy and calls for the Strategy to:

  • Prioritise and accelerate renewable-based electrification as the most cost-efficient way to decarbonise;
  • Foster renewable hydrogen in the hard-to-abate sectors; and
  • Accelerate the deployment and reinforcement of a cost-efficient energy infrastructure

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• WindEurope answer to the European Commission strategy for smart sector integration June 2020

  WindEurope welcomes the opportunity to reply to the EC roadmap on Smart Sector Integration Strategy and calls for the Strategy to:

  • Exploit the benefits and synergies of smart sector integration;
  • Accelerate renewable-based electrification as the most cost-efficient way to decarbonise;
  • Foster indirect electrification in the hard-to-abate sectors; and
  • Support a cost-efficient energy infrastructure development and reinforcement.

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• WindEurope feedback to ENTSO-E workstream proposal for the development of multi-vendor HVDC systems and other Power Electronics Interfaced Devices May 2020

  This document sets out WindEurope’s response to ENTSO-E’s proposal for a workstream on the development of multi-vendor HVDC systems and other Power Electronics Interfaced Devices.

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• Contribution from the Electrification Alliance on the Smart Sector Integration Strategy May 2020

  The Electrification Alliance welcomes the initiative by the European Commission to set out a comprehensive strategy for smart sector integration, which, we believe, can greatly contribute to a “green” and “digital” recovery from the COVID-19 crisis. Enhanced smart sector integration is mostly a matter of making electrification work. Direct electrification must be the top priority of the Strategy as we must ramp up rates of direct electrification from today’s 24% to at least 50% by 2050. Investing in power grids and in the technologies and supply chains that will deliver climate neutrality must be central to the EU’s plan for a speedy and future-proof recovery.

  Here are the 5 priorities of the Alliance for a successful roadmap on the Smart Sector Integration Strategy:

  • Prioritise direct electrification, as it is the most cost-effective way to decarbonise the EU economy
  • Enhance demand-side flexibility across all sectors to smartly manage an energy system with large shares of renewables and reduce costs for grid extension
  • Accelerate the deployment of a smart and climate-resilient electricity grid infrastructure
  • Revise the Energy Taxation Directive to ensure that all energy sources can compete on an equal footing, promote clean innovative technologies and ensure competitive energy costs in Europe
  • Allow renewable-based indirect electrification to play a key role for “harder to abate” sectors

  Read the joint letter

• WindEurope contribution to the EC Strategy for Smart Sector Integration May 2020

  WindEurope welcomes the opportunity to provide comments to the European Commission on the its Smart Sector Integration Strategy.Renewable-based electrification is the most cost-effective approach to reach climate neutrality by 2050. The direct use of this renewable electricity whenever is available and wherever is possible, across all sectors of the economy (especially in the easy-to-abate-sectors), should be prioritised. Renewable electricity should be used to produce zero-carbon gases and fuels, only where necessary, in activities which cannot reduce CO₂ emissions otherwise (e.g. the hard-to-abate sectors).
  It would be an important strategy to deliver decarbonisation and other important objectives pursued in energy policy such as security of supply and affordability. One of the major enablers of sector coupling is the conversion of power-to-gas.

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• Joint letter from the European renewable energy industries on permitting for new renewables investments May 2020

  Getting the permitting of renewables investments right will be critical to deliver the European Green Deal. Permitting for new and repowered renewable energy projects remains today too complex to unlock the scale of renewable energy capacities required to kick start the European economy post COVID-19 and to meet Europe’s 2030 & 2050 energy & climate targets. The European renewable energy industries called on the European Commission to ensure Member States 1) transpose and enforce the new EU rules on simplified permitting for 2030; 2) beef up administrative and human resources to process permit applications and 3) ensure the industry can deploy the most efficient technology available for a specific site.

  Read the joint letter

• WindEurope response to the European Commission consultation on the priority list for the development of Network Codes and guidelines on electricity for the period 2020-2023 and on gas for 2020 (and beyond) May 2020

  WindEurope welcomes the European Commission consultation on the priority list for the development of Network Codes and guidelines on electricity for the period 2020-2023. Our response is structured in three areas:

  1. Network Code on Cybersecurity
  2. Network Code on Demand Side Flexibility
  3. Other electricity Network Codes and guidelines

  As power systems across Europe are becoming more digitised, the need to address their cybersecurity and thus protect our security of supply is becoming urgent. A cybersecurity Network Code should be a priority for 2020-2023.
  Cybersecurity being a borderless issue, any new requirement should not only address cross-border power lines, but power networks in general.

  A Network Code on Demand Side Flexibility should also be a priority for 2020-2023 to ensure the energy transition is not impeded by the lack of Demand Side Flexibility. We consider that the timeline proposed by the European Commission is realistic. Nevertheless, the
  work must start as soon as possible accepting that it will unlikely be completed before 2022.

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• WindEurope response to the European Commission roadmap on the Alternative Fuels Infrastructure Directive (AFID) May 2020

  WindEurope welcomes the European Commission roadmap on the inception impact assessment on the Alternative Fuels Infrastructure Directive. The wind power sector has a key role to play in the energy transition supplying half of Europe’s electricity by 2050.

  The revision of the Alternative Fuels Infrastructure Directive is an opportunity for Member States to boost their alternative fuels infrastructure targets and support the restart of the EU’s economy after the COVID-19 crisis, as well as to ensure Europe reaches carbon neutrality by 2050.

  To this end, WindEurope calls for the inception impact assessment of the European Commission on the AFID to:

  • Be aligned with the European Green Deal and the EU Recovery Plan;
  • Foster the development of the necessary infrastructure for the uptake of zero-emission transport; and
  • Factor in consumers acceptance and incentives to achieve zero-emission mobility.

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• WindEurope response to the future content and implementation of the LIFE programme (2021-2027) April 2020

  WindEurope welcomes the inclusion of market uptake activities, currently funded under the Energy Challenge of Horizon 2020, to continue under the LIFE programme, in a Clean Energy Transition sub-programme.

  However, we are concerned that the proposed changes to the funding rules will prevent important stakeholders from participating in cross-border EU market uptake projects. We believe the ideal LIFE programme would have the breadth of the 2007-2013 Intelligent Energy Europe Programme and the co-financing rates and efficient online procedures of the ‘Horizon’ programmes (2014-2020 and 2021-2027).

  Regarding co-financing rates, those of the next generation LIFE risk being substantially lower compared to those of Horizon which offers 100% of direct costs plus 25% to cover indirect costs. Under LIFE 2021-2027 beneficiaries would only be eligible to a co-financing rate of 60% for direct costs and 7% for indirect costs. That means they would have to find the additional 40% from other sources. If this materializes, participation in future Coordination and Support Actions (CSAs) would become financially unattractive (or even unviable) unless the CSA topic perfectly aligns with the pre-existing strategies of the individual partners in the consortium.

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• WindEurope response to the European Consultation on the Revision of the Energy Taxation Directive April 2020

  WindEurope welcomes the European Commission’s consultation on the revision of the Energy Taxation Directive. Energy taxation can give clearer price signals to support decarbonisation and the energy transition. The revision of the Energy Taxation Directive is an opportunity for Member States to push for renewable based electrification and to ensure Europe reaches both, its 2030 renewable targets and carbon neutrality by 2050.

  WindEurope calls for the revised Energy Taxation Directive to:

  1. Be aligned with the European climate and energy goals,
  2. Provide a level-playing field for renewable electricity, and
  3. To factor-in new technologies such as storage and renewable hydrogen

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• Response to the ENTSO-E draft methodologies and common rules for cross-border participation in capacity mechanisms March 2020

  This document sets out WindEurope’s response to the ENTSO-E methodology proposal on cross-border participation in capacity mechanisms requested by the Clean Energy Package (Electricity Regulation). The current methodology proposal reduces the incentives to build and operate interconnectors and reduces the possibility for capacity to offer their availability in other markets.

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• Response to the public consultation on the Modernisation Fund March 2020

  This document sets out WindEurope’s suggestions for the functioning of the Modernisation Fund and represents the wind industry response to the recent European Commission consultation on the topic. The Modernisation Fund is established under Art.10d of the ETS Directive.

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• Response to the public consultation on the ETS State Aid Guidelines March 2020

  This document sets out WindEurope’s response to the European Commission’s expert consultation on the revision of the State Aid Guidelines in the context of the Emission Trading Scheme (ETS). By regulating electricity cost compensation for EU undertakings, these Guidelines are particularly important in the context of electricity sourcing and corporate renewable Power Purchase Agreements.

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• WindEurope response to the consultation on the Climate Law February 2020

  WindEurope strongly supports the adoption of a Climate Law enshrining the objective of delivering a climate neutral European economy by 2050. The EU has a critical role to play in setting the course for decarbonisation at home as the basis for its global leadership on climate action. The Climate Law is crucial as it creates a commitment that will bind the EU beyond the current political mandate, setting a clear direction of travel for the next 30 years.

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• Putting industrial leadership in wind energy at the heart of the European Green Deal December 2019

  Europe’s wind energy sector is strategic for the EU economy. It is instrumental to our energy security, to our climate objectives, and to our long-term economic success. This paper presents the policies that are needed for wind energy to deliver on the European Green Deal. These need to work in harmony to support market scale, plug the green investment gap, support the EU wind industry’s global supply chains, and refocus EU Research & Innovation and skills funding.

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• Wind-to-X October 2019

  This paper sets out WindEurope’s position on how to achieve net-zero emissions. It puts forward the renewable-based electrification as the most cost-effective approach to reach climate neutrality. It stresses: the direct use of this renewable electricity whenever is available and wherever is possible across all sectors in the economy and the use of this renewable electricity to produce zero-carbon gases and fuels where necessary in activities which cannot reduce CO₂ emissions otherwise.

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• Response to ACER’s public consultation on the future regulatory framework for gas in Europe September 2019

  This paper sets out WindEurope’s response to the Agency for the Cooperation of Energy Regulators (ACER) consultation on “The Bridge beyond 2025”. It presents the wind industry views on the future regulatory framework for gas in Europe, including on sector coupling

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• Response to the public consultation on the implementation of Horizon Europe September 2019

  This paper sets out WindEurope’s and ETIPWind’s response to the European Commission’s consultation on the strategic planning of Horizon Europe, the EU’s research & innovation framework programme for 2021-2027. It presents the wind industry views and recommendations on the strategic priorities of the programme that will sustain cost reductions, boost the competitiveness of the European wind industry and accelerate a renewables-based electrification of hard-to-abate sectors.

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• Response to the public consultation on the Strategic Planning of Horizon Europe September 2019

  This paper sets out WindEurope’s and ETIPWind’s response to the European Commission’s consultation on the implementation of Horizon Europe, the EU’s research & innovation framework programme for 2021-2027. It presents the wind industry views and recommendations for a fit-for-purpose funding programme that will help improve wind energy technology and applications and support existing European supply chains.

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• Response to the public consultation on the State Aid Guidelines for Environment and Energy July 2019

  This paper sets out WindEurope’s response to the European Commission’s expert consultation on the revision of the 2014 State Aid Guidelines for Environment and Energy and the General Block Exemption Regulation. It presents the wind industry views and recommendations for a post-2020 European state aid policy that will help deliver the private investments in wind energy necessary for the fulfilment of the EU 2030 climate and energy objectives.

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• 5 ways the European Commission can strengthen wind project through the Innovation Fund July 2019

  On 3 July WindEurope hosted a workshop with the European Commission on the recently created Innovation Fund (IF). The event served to collect project ideas from the wind energy industry and to discuss key sector-specific issues with regard to the selection and management of future projects under the Fund. This paper collects the takeaways from the event and summarises the wind energy input to design elements for the first call of proposals in 2020.

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• Future system needs and role of grid-forming converters July 2019

  This paper presents WindEurope views on the need and implications of deploying grid-forming converters in the power system. The paper presents the challenges faced by transmission system operators that today manage large share of variable renewables and discuss their current approaches. WindEurope takes a view on the challenges to develop grid-forming converters, both from the technical aspects and the cost implications.

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• Renewable Hybrid Power Plants: Exploring the benefits and market opportunities July 2019

  This paper explores the benefits and market opportunities for Hybrid Power Plants (HPPs). WindEurope proposes a set of definitions for clearly establishing HPPs in the regulatory framework, identifies a number of common challenges for their development in different countries and presents a set of policy recommendations for accelerating their market uptake.

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• Industry position on how offshore grids should develop June 2019

  The paper provides insights on the state of play of how offshore wind farms are connected to the grid and provide recommendations on how the multitude of initiatives and ideas over the last 10 years could come together and accelerate the pace of grid infrastructure build out.

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• Response to the public consultation on the EIB energy lending policy April 2019

  This paper sets out WindEurope’s response to the consultation of the European Investment Bank (EIB) on a new Energy Lending Policy to help deliver the investment required to support the EU 2030 energy and climate policy.

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• Renewables system integration – a system wide approach to cost and value December 2018

  This paper discusses the traditional approaches to estimate costs associated with managing variable renewable energy sources and proposes a different way to address the analysis of system costs and benefits of power systems with increasing shares of renewable energy.

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• Guidance on Electricity Trading and Carbon policies in the event of No Deal Brexit October 2018

  The UK Government issued guidance on the trading of electricity and on meeting climate change requirements (including carbon policies) in the event there is no deal between the UK and the EU-27 on Brexit. These documents include a set of recommended actions for stakeholders.

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• Floating offshore wind energy: a policy blueprint for Europe October 2018

  Floating offshore wind (FOW) is a fast-maturing technology with the potential to cement Europe’s leadership in renewables globally. European companies are the pioneers as they lead three quarters of the 50+ FOW projects at different stages of development worldwide today. Floating offshore wind can extend the frontiers of innovation in renewable energy technologies, however dedicated policies are needed to make it a European success story.

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• Recommendations on an enabling investment framework for wind June 2018

  Fighting climate change requires Europe to step up its efforts in decarbonising its energy system by 2050. This paper outlines how the investment framework should look like in the next decade to deliver the significant investments required to decarbonise Europe’s economy, while ensuring the price of wind energy decreases for consumers.

  It concludes the following:

  • Forward contracting of wind energy (auctions, visibility on volumes) is critical to maintain a competitive industrial base and deliver cost reduction;
  • Revenue stabilisation mechanisms (CfD, FiP) must strike the right balance between investors’ need for certainty and lower costs for society;
  • Diversification of revenue streams (GOs, PPAs, ancillary services) will help reducing further the price of wind energy;
  • Long-term structural reform (carbon pricing, grid investments, overcapacity, electrification) need to be implemented to improve the efficiency of the power system;
  • Merchant investments may already materialise in some Member States by 2020, where market conditions are favourable, but they are more the exception than the new normal,

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• WindEurope/EEX joint paper on electricity market design March 2018

  European Energy Exchange and WindEurope welcome in a joint statement the adoption of the European Parliament’s position on the Electricity Directive and Regulation. Our organisations call now on policymakers to make the right choices in the upcoming trilogue negotiations. The reform of Europe’s electricity markets will be a success if the following elements are ensured: the phase-out of regulated prices, the recognition of future and forward markets, the grandfathering of priority dispatch and balancing regimes for existing renewables installations, a stable framework for bidding zones review and stricter rules governing on the introduction and the design of capacity mechanisms.

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• Offshore wind energy in the North Sea November 2017

  The North Seas Energy Forum brings together representatives of the public, private and non-governmental sectors from the Northern Seas countries to discuss challenges and opportunities for regional cooperation in energy topics, particularly for the deployment and use of offshore wind energy.

  In the context of the second stakeholder forum meeting on 29th November 2017 at WindEurope’s Conference & Exhibition in Amsterdam, this paper brings together the industry position across many technical topics in order to inform participants and consolidate the key messages to communicate to policy makers.

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• Wind energy and on-site energy storage November 2017

  Co-locating wind energy and storage technologies could offer many benefits: It could reduce the amount of curtailed electricity at times of grid congestion or system instability. It could help maintaining generation schedules communicated to system operators, thereby reducing imbalance charges and avoiding penalties for not fulfilling the performance committed to the system. It could enable wind power to provide a wider range of ancillary services, such as frequency containment reserve (FCR), improve reactive power provision and even black start capability. In small power systems with stability issues, storage can support wind farms to reduce ramp rates, smoothing out electricity generation.

  WindEurope’s paper discusses the possible functionalities of co-located wind energy and storage projects using examples from key ongoing projects. It uses information from WindEurope’s online database of co-located projects developed specifically to improve the industry knowledge. Approximately 400 MW of co-located projects have been identified globally, with three quarters of them already operational.

  WindEurope presents a number of policy recommendations to improve the market design for all storage projects and specifically for co-located ones. As industry gains more experience developing such projects, WindEurope will disseminate lessons learned on regulatory frameworks and incentive schemes.

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• Renewable Power for All: a call for an environmentally beneficial electrification and multi-sectoral integration September 2017

  Fighting climate change, air pollution and delivering the Paris Agreement commitments requires replacing fossil fuels by renewables within the power sector and beyond. As large amounts of competitive renewable electricity are today available, a rapid electrification of the most carbon intensive energy uses is the best and most efficient way to decarbonise and grow Europe’s economy.

  The following measures would help drive the decarbonisation and energy efficiency of the Transport, Heating and Colling sectors, thanks to the uptake of wind energy, and should be prioritised as part of current and forthcoming discussion on EU legislation:

  • A downward revision of the PEF for electricity so non-combustible renewables have a PEF below 1;
  • An increase of the fuel suppliers obligation in the Renewable Energy Directive to 10%;
  • Stringent post-2020 CO₂ standards for cars in line with the Paris Agreement on climate;
  • Stronger requirements regarding the deployment of charging points for electric vehicles;
  • A revision of the Energy Taxation Directive that avoid favouring fossil fuels where electricity could also be used.

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• EU RES associations position on dispatching regime July 2017

  The draft report published by Dr. Karins MEP proposes crucial changes to the current dispatching regime for generating installations using renewable energy sources. With this letter, the renewable energy industry wishes to emphasize three major elements that need to be considered by the rapporteur and the members of the ITRE committee when revising the dispatching regime for renewables.

  The following considerations are key for maintaining investments in renewables, and giving Europe a chance to fulfil its climate change targets and remain world number one in renewables.

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• Financing wind energy beyond 2020 July 2017

  The Clean Energy Package foresees an EU level financing framework to help the Union deliver on its collective binding target of renewable energy in final energy consumption (Art 3.4 of the recast Renewable Energy Directive). This financing facility could support and incentivise countries to deliver on their national plans and avoid any potential gaps in the target.

  In the absence of legal binding renewable energy national targets, there is a need to incentivise Member States to deliver on the collective commitment by providing them with tools that attract investors to their markets. This paper elaborates on the main risks that investors will face in the post-2020 renewable energy context, and propose solutions at EU level to address the potential gap between available finance for renewables and deployment needs to meet the EU’s 2030 targets

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• Unlock demand-side flexibility for European consumers, innovation and the climate June 2017

  WindEurope and the IDEAS platform (*) call on Members of the European Parliament and energy ministers to unlock the potential of demand-side flexibility in Europe. This resource not only benefits and empowers consumers, but also enables the integration of ever larger shares of renewables in the power system at least cost. The Clean Energy Package should address current market failures and set fair rules that will allow this take-off, such as: creating functioning wholesale markets, allowing consumers and third parties to value their flexibility and tackling the structural overcapacity of generation in Europe. Not delivering this risks affecting the Europe Union’s competitiveness, undermining its decarbonisation efforts as well as its opportunities for jobs and growth.

  (*) IDEAS is an informal stakeholders’ platform that contributes to the development and implementation of European policies and initiatives to drive the deployment of flexible demand-side resources in support of the EU’s goals in energy and climate, security of supply and competitiveness.

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• Repowering and lifetime extension: making the most of Europe’s wind energy resource June 2017

  As every energy technology, wind energy assets have an end to their operational lifetime. A significant proportion of the installed EU wind fleet will come to the end of its lifetime between 2020 and 2030. These decommissioned wind energy assets will not count for the delivery of the EU 2030 renewable energy target.

  This paper seeks to align approaches on repowering across the EU in line with the proposed post-2020 renewable energy regulatory framework. The repowering provisions in the Clean Energy Package would guarantee that Member States are able to harness a higher share of wind energy at the best wind sites to the benefit of European consumers by 2030.

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• Higher renewable energy ambition required to avoid deployment slowdown June 2017

  The Clean Energy for All Europeans package proposed by the European Commission in November last year suggests a European binding target of at least 27% renewable energy by 2030. This target’s lack of ambition translates to a slow-down in renewable energy deployment after 2020. Going below a target of 35% would mean that, over the next decade, Europe installs less new renewable energy capacity than in the current one, putting its competitive edge at risk. We therefore urge MEPs to support a binding target of at least 35% as being the bare minimum to keep momentum going in this fast-growing industry and ensure Europe reaps the economic benefits resulting from a sustained renewable energy deployment.

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• Reviving wind markets and delivering on our 2030 objectives March 2017

  A reliable European renewable energy strategy is needed to create a business case for wind energy beyond 2020. WindEurope welcomes the spirit of the European Commission’s proposals for a new Governance Regulation and a recast Renewable Energy Directive. But it considers that Member States and the European Parliament should raise ambition towards a collective EU renewables target of at least 35% to make full use of the economic potential the energy transition offers.

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• Building a European energy market fit for the energy transition March 2017

  WindEurope believes the legislative proposals for a revised electricity market design offer a unique chance to provide the industry with a predictable investment framework, to create fairer market conditions for all energy sources, and to seize the opportunities that come with a decentralised energy system. Getting the market design right today will determine whether the energy transition in Europe is achieved in the most cost-effective manner.

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• WindEurope views on the TSO-DSO coordination – Enabling flexibility from distributed wind power March 2017

  Europe’s power system is undergoing a profound change. Most of the new generation capacity is being connected to distribution networks. Distributed generation could provide valuable services today to the system but some market design features impede the delivery of these services to the market.
  Utilising the services from distributed generation would lead to lower system costs (i.e. through higher competition). Additionally, optimising the use of flexibility resources could reduce the amount of curtailed wind and solar power, saving tax-payers money and maximising the use of carbon-free sources.

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• Make green electricity markets work for consumers and energy transition March 2017

  At least 15 million European households are willing to actively support the transition towards a cleaner energy supply. They have already opted for a green electricity tariff with a 100% renewable fuel mix. This demand could be leading to increased investment in additional renewable installations and, aside from national support schemes, be another way to boost renewable energy generation.

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• Manufacturers call on European institutions to strengthen EU industrial strategy February 2017

  92 trade associations have signed a Joint Declaration in the run-up to the Competitiveness Council calling on the EU to strengthen its industry strategy.

  European Commission President Jean-Claude Juncker marked the reindustrialisation of Europe as a priority to ensure the EU remains a competitive global power as other countries including China, India and the USA step up their industrial policies. WindEurope together with European trade associations from other manufacturing sectors calls on the European Commission to:

  • reaffirm its commitment to reaching the target of 20% of GDP from industry, with an ambitious and realistic timeline;
  • adopt an Action Plan to tackle the challenges that the industrial sectors face, in the framework of a Communication that would include concrete steps and milestones; and
  • commit to implement this Action Plan in a timely manner and regularly report on progress.

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• Creating a business case for wind after 2020 January 2017

  The investment climate in the European power sector is deteriorating. Projects become riskier and struggle to attract affordable capital owing to a lack of visibility on their long-term revenues. This is particularly relevant for wind energy projects, which require large upfront investment and are highly sensitive to financing conditions.

  This paper explains how revenue stabilisation mechanisms, complemented by spot market signals, can help mitigate risk while reducing the decarbonisation costs borne by final consumers. It also explores the potential of commercial long-term contracts (PPAs) between wind power producers and corporations, which are currently on the rise in Europe.

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• The potential of energy sector integration November 2016
  • Sector integration is a win-win for the European energy system and a boost for the wider economy.
  • Sector integration is technically and economically feasible today.
  • Regulatory barriers must be removed to realise full potential.

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• Associations call on Commission President Juncker to make EU market fit for renewables October 2016

  The continuation of the energy transition and, in particular, the continued cost-effective integration of renewables in the energy system require an appropriate market framework. The Commission’s upcoming legislative proposals on market design need to adjust market rules to flexible renewable energy generation.

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• 11 companies call for investor protection in EU September 2016

  While the industry acknowledges the need to adjust regulatory frameworks over time to respond to declining technology costs and market developments, retroactive changes are a misguided answer and erode investor confidence in the EU energy infrastructure sector where costs are sunk from the moment of the investment and there is very limited ability to improve profitability thereafter. Accordingly, investors in the space have no choice but to expect long-term regulatory stability for renewable energy plants. Thus any regulatory change should be concerted, non-retroactive, non-discriminatory, and avoid any legal gaps that would undermine investor certainty.

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• Wind energy: backbone of the EU global leadership in renewables September 2016

  The European Commission’s President Jean-Claude Juncker has pledged in 2014 to make the EU’s the “world number one in renewables”. Wind energy is set to be the backbone of the EU’s global leadership in renewables as it will provide the largest contribution – 23,9% – to the 2030 EU-wide renewable energy target. Global leadership requires proactive industrial, innovation and trade policies that sustain a vibrant home market. This paper aims to input to the Energy Union Integrated strategy for research, innovation and competitiveness, the European Union’s trade agenda and the upcoming legislative package on renewable energy and market design.

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• Implementation guidelines for the network code requirements for generators July 2016

  In May 2016, ENTSO-e developed and published the European network code on requirements for generators. It provides a large number of not fully defined requirements and specifications. In many cases, these non-exhaustive requirements lead to ambiguity on the technical performance needed, as well as to uncertainty on the regulatory framework for implementing the new set of rules, which will apply as from May 2019.

  The present document aims at facilitating the implementation of the European network code by providing the views and expertise of the wind industry sector on the technical issues of fault ride through and reactive power capability.

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• Associations say EU law must hold Member States to account on renewables ambition July 2016

  In October 2014, 28 EU Heads of State agreed that a binding target for renewables should be set at EU level to meet their collective climate and energy ambition. Since then, the European Parliament has consistently backed a binding renewable energy target for 2030, most recently in June 2016.

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• System adequacy June 2016

  The EU power sector faces an investment dilemma owing to overcapacities and old infrastructure and the new to quickly reduce emissions in the power sector. A proper assessment on the future system adequacy has to happen before introducing regulatory mechanism that incentivise investments on additional capacity. WindEurope shows in this position paper the benefits for member states if they chose a coordinated regional approach, which is based on probabilistic methods that account for the contribution of variable renewable energy sources.

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• Priority dispatch and curtailment June 2016

  Making the market fit for renewables requires additional efforts on curtailment rules and priority dispatch provision. The latter has been instrumental in bringing wind power growth to covers 11.4% of the EU’s total electricity consumption today. Current discussions on its removal and the possibility to apply retroactive changes undermine investors’ confidence, which could slow down the agreed energy transition. WindEurope explains the market design conditions necessary to provide a level playing field to wind generators and eventually reduce curtailments.

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• Repowering June 2016

  WindEurope expects up to 76GW of installed wind energy capacity to reach the end of their operational life between 2020 and 2030. Repowering allows harnessing more wind power whilst preserving jobs for local communities. The position paper lays out how member states can incentivise repowering, alongside greenfield projects, to help meet the 2030 targets cost-effectively.

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• Industry statement: Making the EU ETS relevant after the Paris Agreement June 2016

  Despite adopting measures such as backloading, the Market Stability Reserve (MSR) and an increased Linear Reduction Factor (LRF), the surplus of allowances will continue to depress the market in the short to medium term, keeping ETS ineffective as a robust carbon price signal until late into the 2020s. We, a group of companies involved across the energy sector, urge you to use the current revision of EU ETS to deliver the required low carbon investment signals to meet the long term objective agreed in Paris.

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• Balancing May 2016

  Safe energy supply also depends on a balancing the electricity system. A number of generation and demand options offer balancing services today. From a technical point of view, wind power plants could already contribute to these services but in most cases the markets are not well-suited for the participation of renewable energy technologies. This is why WindEurope has developed the industry’s “ten commandments” for better procurement rules and pricing system. As a general principle, all generators should have the right – but not the obligation – to participate as well as receive adequate remuneration.

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• Renewables associations call for strong national plans on Energy Union May 2016

  The EU renewable energy sector welcomes the development of integrated national plans and reports as part of the governance of the Energy Union but stresses that streamlining of planning and reporting obligations should not come at the expense of detailed and good quality data. National plans for the post-2020 period should be based on standardised, binding templates enshrined in legislation to ensure the cost-effective delivery of the 2030 EU renewables target. The European Commission should also pursue an active political dialogue with Member States to make sure that concrete national commitments and enabling policies for renewables are in place in due time.

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• Renewables associations call on EC to model higher RES targets May 2016

  To maintain global leadership in renewables, Europe should now make a firm and resolute commitment to a flourishing and vibrant domestic renewable energy market by 2030. The European renewables industry calls on the European Commission to factor in higher renewable energy ambition in the post-2020 Renewable Energy Directive.

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• Principles for an effective Innovation Fund April 2016

  To become the world’s number one in renewable energy technologies, it is vital for the EU and its member states to bolster leading technologies in Europe’s renewable energy industry through strong industrial and innovation policies. The new Innovation Fund should build on the lessons learnt from the NER 300 to further boost investments in innovative and sustainable energy technologies.

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• WindEurope’s position on the post-2020 Renewable Energy Directive April 2016

  A robust post-2020 renewables regulatory framework is key to securing the EU’s position as the world number one in renewables and maximising the benefits of wind deployment to the European economy. WindEurope believes that Member States will need to raise ambition towards a collective EU renewables target of at least 30% to match international competition and foster a vibrant home market sustaining the European wind industry’s competitive edge and technology innovation efforts.

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• WindEurope response to public consultation on “Streamlining planning and reporting obligations as part of the Energy Union governance” April 2016

  On 11 January 2016, the European Commission launched a public consultation on national planning and reporting obligations for the post-2020 period in the framework of the Energy Union governance regime. WindEurope calls for a reliable planning and reporting process that can provide early visibility on national 2030 renewable energy commitments and policies and ensure the cost-effective delivery of the binding EU renew¬able energy target.

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