EWEA Position papers
Before we were WindEurope, we were EWEA. Below you may find all position papers published before May 2016.
Joint declaration by a group of industry associations
The signatories of this declaration gather leading associations and industry groups with a clear stake in Europe’s energy policy. We share the conviction that only a flexible and dynamic energy system, making the best use of innovative and distributed supply and demand options, can ensure a cost-efficient and sustainable transition towards a decarbonised energy system.
EWEA Response to Public Consultation on a Renewable Energy Directive for the post-2020 period
On 18 November 2015, the European Commission launched a public consultation on a Renewable Energy Directive for the post-2020 period. The European Wind Energy Association calls for an ambitious post-2020 legislative package enabling the fulfilment of the binding EU renewable energy target for 2030 and capitalising on the EU’s first-mover advantage in wind energy.
Renewables industry calls for ambitious post-2020 legislative package
The European renewables industry calls on the European Commission to propose an ambitious post-2020 renewable energy package that fosters a vibrant home market with clear growth perspectives. This will allow the EU to regain its leadership in renewables in the face of rising international competition and will enable the cost-effective fulfilment of both the 2030 renewables target and the EU’s long-term decarbonisation objectives.
Effective Transition Signals: Position paper of the European Wind Energy Industry on the ETS post-2020 revision
The European Commission’s legislative proposal for the post-2020 revision of the ETS provides an opportunity to conduct a root and branch reform and realign it with Europe’s political ambition on climate change. A substantial reform and the creation of a trajectory towards robust and high carbon prices need to turn the ETS into an effective instrument that supports the drive towards renewable energy generation.
Design options for wind energy tenders
The Guidelines on State aid for environmental protection and energy 2014-2020 indicate an evolution towards tendering (competitive bidding) as a reference system for public support allocation to renewable generators from 2017. The proper design of tenders is of utmost importance to sustain wind energy’s growth path as wind is set to cover 23% of the EU’s electricity demand in 2030. In this document, EWEA aims to provide an overview of existing tender schemes and lessons learned from their implementation. EWEA hereafter outlines the considerations that national authorities need to take into account when setting up a tender system.
European power sector says YES to an ambitious global agreement at COP21 in Paris
Joint communiqué of European power sector stakeholders on COP21 to the Executive Secretary, Mrs Figueres, and to the 196 parties to the United Nations Framework Convention on Climate Change; copied to Mr Maros Sefcovic, Vice President for the Energy Union, European Commission and Mr Arias Canete, Commissioner for Climate Action and Energy, European Commission.
EWEA Response to Public Consultation on a New Energy Market Design
On 15 July 2015, the European Commission launched a public consultation on a new energy market design. The European Wind Energy Association’s response was developed on the basis of our June 2015 position paper on market design.
Joint reaction to the Electricity Market Design Consultation
The signatories of the present letter gather the leading associations, NGOs and industry groups from Europe’s energy sector. They share the common objective of promoting the prompt, affordable and green transition of Europe’s energy system. This is our joint reaction to the European Commission’s (EC) public consultation on the new electricity market design.
EWEA position paper on Balancing Responsibility and Costs of Wind Power Plants
There are growing concerns about the extent to which variable power production impacts power system reliability, efficiency, and the ability to balance the power supply and demand. These concerns include the persisting misconception that wind power is still exempted from balancing responsibilities across the EU and the balancing cost they induce overall on the power system. This prompts a discussion on the best ways of exposing wind power generators to balancing responsibility and their participation in balancing markets.
Renewables industry calls on Member States to deliver on 2030 target
The European renewables industry strongly supports the creation of a governance system for the Energy Union that will underpin the EU’s long-term decarbonisation objectives. In the absence of post-2020 national binding targets for renewable energy, the governance system of the Energy Union needs to be robust, duly enshrined in legislation and agreed upon in co-decision in order to provide a reliable regulatory framework and attract investments in renewables by 2030. In this joint position, the renewables industry outlines the key building blocks for a governance system that can deliver the 2030 renewable energy target cost-effectively.
EWEA response to consultation on EU Nature Legislation (Birds and Habitats Directives)
The mitigation of climate change and protection of nature and biodiversity are at the core of today’s environmental challenges. So far, the EU’s environment and climate policies have delivered substantial benefits. EWEA recognises the contribution of European nature and biodiversity legislation and underlines the importance of the Birds & Habitats Directive, which have proved to be the cornerstones for protecting nature conservation. EWEA recognises it is not the aim of these Directives to block the further development of wind power in Europe. However, through incomplete guidance, the lack of recognition of the impact of renewables on climate change mitigation, an inconsistent transposition into national law and over simplistic interpretation by governments, the Directives have blocked many projects.
EWEA-EFET-Eurelectric-Europex statement on Balancing Pilot Projects
While the four associations have been actively involved in the initiative of ENTSO-E and TSOs to run balancing pilot projects since its inception, stakeholder involvement in those projects remains problematic. Despite valuable efforts from the ENTSO-E Secretariat and the leaders of certain projects, market participants continue to feel that important decisions are being taken without having a proper view on what their impact will be, and without having any influence when different options are being considered. The attached statement proposes a number of avenues to improve the interaction between the Balancing Pilot Projects leaders, the ENTSO-E Secretariat, NRAs and market participants.
EWEA position paper on Market Design
In this paper EWEA puts forward its key priorities for power market design reform. Implementing these elements would help overcome two of the main problems investors are currently facing in the EU power sector: 1) depressed wholesale market price levels; 2) fading EU-coordination of energy policies. Importantly, EWEA proposes that phasing out of inflexible and carbon intensive power generation capacity must not be impeded through ill-designed capacity remuneration mechanisms. This must be accompanied by no-regrets measures to fix the energy-only market model to re-establish price signals as the core principles for new investments in generation capacity.
Meeting the 2030 renewable energy objective thanks to a robust governance system
The 2030 climate and energy package agreed by the European Council in October 2014 sets a binding EU-wide target for renewable energy of at least 27%. Meeting this target will be instrumental in driving down costs and help establish the EU as a global leader in renewables.
In the absence of national binding targets, guarantees need to be put in place regarding the commitments of Member States to renewable energy deployment. To this end, the European Commission should table a proposal for a robust and transparent governance system in 2015.
Joint Statement on the Energy Union – A Fresh Push for the Internal Energy Market
EURELECTRIC, Eurogas, EPIA and EWEA are pleased to see the new European Commission’s increased focus on energy issues. We hope this new momentum will reinforce policy in favour of a better functioning market and a positive investment climate for companies, as well as contribute to achieving a secure and affordable energy mix for a low-carbon economy. A competitively priced, secure and sustainable supply of energy is essential for economic growth, European competitiveness, and the well-being of millions of consumers across Europe.
Wind energy climate solutions in action – COP20 Lima
More than ever, swift action to fundamentally transform national energy systems and scale-up investments in renewable energy is essential. The power sector is the largest single contributor to global greenhouse gas emissions. Action here can make global emissions peak and, then, decline. While urging policymakers to act, the latest IPCC Synthesis Report has stated clearly that the technologies to decarbonise power systems are available. It also highlighted that it is cheaper and much more cost-effective to accelerate the energy transition instead of delaying action. Wind energy, the most efficient solution to emission reductions in the power sector, demonstrates that combining decarbonisation and economic growth is entirely feasible.
5 priorities for a European Energy Union
When six countries created the Coal and Steel Community more than 60 years ago, it marked a commitment by European governments to place common prosperity above national interests.
Today, European policy makers are facing an equally daunting and important challenge: the creation of a true European Energy Union in the era of climate change.
Developing a shovel-ready offshore grid in the North Seas – why public support is needed
This paper sets out why developing an offshore grid in the North Seas should be a key part of the European Commission € 300 billion public-private investment programme to revive the European economy.
The need for more emission-free and domestic energy supplies to counter climate change while increasing our security of supply and establishing a globally leading, innovative industry sector like offshore wind energy is clear. As the development of its key enabler, an offshore grid in the Northern Seas, faces various challenges, there is a rationale which justifies EU engagement, including financial instruments, to facilitate this major infrastructure project.
EWEA response on ACER public consultation on “European Energy Regulation: A bridge to 2025”
EWEA welcomes the ACER consultation and recognises it as a step towards the achievement of the goals outlined in the 3rd Liberalisation Package. The wind industry’s objective is to be competitive in a fully liberalised electricity market, and to deliver the benefits of wind energy in the most affordable way for consumers. Investments made possible by stable legislative frameworks help drive down costs, will enable on-going cost reduction and, ultimately, remove the need for specific incentives. Well-functioning electricity markets and adequate infrastructure are the key priorities for the European wind industry.
Regretfully, emphasis on concrete actions to achieve progress often seems to be missing in the ACER consultation document. Instead, the focus is put on alleged market distortions by national RES support mechanisms, lack of balancing responsibilities and priority dispatch provisions without any further contextualisation.
2030 EU Climate and Energy Framework: How Europe can maximise its benefit from wind energy
Wind energy will play a key role in meeting the EU’s objectives of economic growth, affordable energy, decarbonisation, competitiveness and energy security. It is therefore critical that the post-2020 climate and energy framework allows Europe’s wind industry to reach its full potential. This paper sets out the European Wind Energy Association’s views on how to optimise wind energy’s role in the post-2020 framework and maximise its benefits.
To this end, the European Wind Energy Association sets out proposals in three key areas:
- Electricity markets and infrastructure
- Post-2020 renewable energy framework
EWEA position paper on 2030 interconnectivity objectives
The European Wind Energy Association welcomes that the Commission is proposing to increase the EU’s power interconnectivity target by 2030 as part of its energy security strategy. EWEA believes, nonetheless, that a headline target of 15% – up from the 10% that was supposed to be reached in 2005 – is insufficient to fully address the EU’s interconnectivity challenge.
Instead, a more detailed country and region-specific determination of interconnectivity deficits should be considered. In addition, the Commission should promote a more tangible infrastructure objective as opposed to a revised generic interconnectivity level and make use of a firm benchmark, such as the full achievement of the next PCI or TYNDP list of electricity infrastructure projects by 2030.
EWEA Position on the Market Stability Reserve for the EU Emissions Trading System
The European Wind Energy Association welcomes the legislative proposal to establish a Market Stability Reserve for the EU Emissions Trading System as a structural measure to address the imbalance between demand and supply in the ETS. A properly functioning Market Stability Reserve can make the ETS more resilient to events that disturb the supply-demand balance, including macro-economic shocks and a large inflow of international credits. The mechanism is a first step to create scarcity in the carbon market while at the same time ensuring predictability.
EWEA position on priority dispatch of wind power
In mature markets with high penetration levels of wind power, future regulatory frameworks and power market design can consider increased exposure of wind generators to market risks, including progressively phasing out priority dispatch and/or developing a more market-price responsive mechanism in mature markets with high penetration levels of wind power. However, this requires a level playing field: a fully transparent, fair and well-functioning power market.
Wind energy, as a variable renewable energy source, should benefit from priority dispatch until such a level playing field is achieved.
EWEA response to ENTSO-E consultation on 2030 visions
EWEA welcomes the ambition of ENTSO-E to aim for a 2030 planning horizon in the upcoming 10-year network development plan (TYNDP) in 2014, as a bridge between the European energy objectives for 2020 and 2050. However, in this consultation response we call for changes as the ENTSO-E 2030 visions document still falls short of meeting EU renewable energy and climate objectives and respective plausible scenario development.
EWEA response to ENTSO-E methodology for a cost-benefit analysis for electricity grid developments
With this consultation response EWEA aims to provide its views with regards to a sound and exhaustive methodology for a cost benefit analysis (CBA). EWEA considers this as crucial to evaluate and plan future grid projects, in particular taking a broader view on criteria for assessing wind energy integration and socio-economic aspects of a candidate project.
Answer to EC consultation on the 2015 International Climate Change Agreement
Following the failure to agree to a meaningful post-Kyoto agreement the EU climate and energy framework should be decoupled from the international climate negotiations for a number of reasons.
Proposal for a directive establishing a framework for Maritime Spatial Planning and Integrated Coastal Management
(Joint statement between WWF and EWEA)
WWF and the European Wind Energy Association (EWEA) welcome the European Commission’s proposal for a Directive establishing a framework for Maritime Spatial Planning (MSP) and Integrated Coastal Management (ICM).
EWEA position on the review of the Environmental Impact Assessment Directive
EWEA welcomes the review of the Environmental Impact Assessment Directive (EIAD) as it introduces a number of incremental improvements and simplifications to the current EIA process without weakening the environmental protection provided by the Directive. The wind industry supports streamlining of EU and national permitting procedures, as administrative barriers are the main cause for significant delays that push up the cost of wind energy, with no additional benefits for the environment or wildlife.
EWEA position on the Commission proposal for a Directive establishing a framework for maritime spatial planning and integrated coastal management
EWEA position on the Commission proposal for a Directive establishing a framework for maritime spatial planning and integrated coastal management.
EWEA briefing paper on the European Commission communication: “Making the internal energy market work”.
EWEA briefing paper on the European Commission communication: “Making the internal energy market work”.
Read the briefing paper.
EWEA response to EC public consultation
EWEA response to the public consultation on generation adequacy, capacity mechanisms and the internal market in electricity.
Open letter EWEA-EPIA letter to ENTSO-E on the Network Code on “Requirements for Generators”
Joint EWEA and EPIA position paper on key technical concerns and proposed solutions urging ENTSO-E, together with ACER and the European Commission to undertake the necessary changes in the ENTSO-E Network Code requirements for generators ahead of the Comitology process.
EWEA and EPIA main concerns and proposals for solutions on ENTSO-E Network Code for Requirements for Grid Connection
Joint EWEA and EPIA position paper on key technical concerns and proposed solutions urging ENTSO-E, together with ACER and the European Commission to undertake the necessary changes in the ENTSO-E Network Code requirements for generators ahead of the Comitology process.
EWEA response to the EIB’s energy lending policy consultation
The EIB should see wind energy as not only a solution to climate change and a way to improve energy security, but also a way to boost economic growth and competitiveness.
EWEA position paper – Offshore wind power: a European industry that deserves a European industrial strategy
EWEA position on the backloading proposal – Delaying auctions is a first step but a permanent solution must be found
EWEA position on the backloading proposal – Delaying auctions is a first step but a permanent solution must be found.
Joint letter on CEF by EWEA, Europacable, and Eurelectric
Letter urging EU Member States and the European Parliament to safeguard the proposed 9.1 billion euros for energy infrastructure in the Connecting Europe Facility in the discussions on the future Multi-Annual Financial Framework of the EU.
Letter: Draft Network Code on Requirements for Grid Connection applicable to all Generators
EURELECTRIC, together with associations VGB Powertech, EWEA, EPIA, Geode and Cedec, remain unconvinced by the latest changes to the draft Network Code on Requirements for Grid Connection applicable to all Generators, submitted by ENTSO-E to EU regulatory agency ACER in July 2012. In this open letter to ACER, the stakeholders therefore ask for more time to adequately review the changes proposed.
EWEA response to the ACER consultation on the Framework Guidelines on Electricity Balancing
The cost efficient integration of large amounts of wind energy depends, to a great extent, on the technical and market rules for balancing the power system. In particular, balancing variable sources of energy depends on performing this activity in an integrated European-wide market, beyond national borders or control zones. Therefore, the development of a pan-European Network Code establishing cross-border balancing services and harmonising rules for their procurement and provision is of huge importance.
EWEA briefing on the European Commission’s Renewable Energy Strategy
EWEA briefing on Horizon 2020 proposal.
Supporting the North Sea offshore grid development – Assessment and recommendations
Offshore grid development combined with onshore network reinforcements is a sine qua non condition for offshore wind development. It is critical to the deliverability of the European 2020 energy and climate targets.
EWEA response to the ENTSO-E first official 10-year network development plan
This document introduces and summarises the response of the European Wind Energy Association (EWEA) to the public consultation on the ENTSO-E first official 10-year network development plan (TYNDP). While this TYNDP contains numerous improvements in comparison with the Pilot TYNDP in 2010, such as a prioritisation of projects of pan-European significance rather than a sheer compilation of regional development plans and the inclusion of the 2020 RES targets in the scenarios, there are still various points which require clarification in this official version of the TYNDP.
EWEA public consultation response to the ENTSO-E network code for Requirements for Grid Connection applicable to all Generators
This document introduces and summarises the response of the European Wind Energy Association (EWEA) to the public consultation on the ENTSO-E draft Network Code for Requirements for Grid Connection applicable to all Generators (NC).
This letter summarises the main points of concern of EWEA with the NC, namely:
Need for more clarity in formulation of the NC
Lack of justification and cost-benefit analysis
Key technical concerns:
Excessive reactive power requirements
Unclear fault-ride-through specifications
Compliance should be robust and pragmatic
Simulation models: lack of specification and insufficient IPR protection
Offshore PPM requirements are insufficiently future-proof
Uncertainty about future code drafting at national level and about the NC maintenance procedures
EWEA response on DG Energy public consultation on the governance for the European day-ahead market coupling.
EWEA response on DG Energy public consultation on the governance for the European day-ahead market coupling
While details with regards to market design on day-ahead as well as on the intraday timeframe are tackled, any upcoming governance guideline should provide a binding basis for defining the responsibilities of the actors and entities involved in the market integration process and the interaction between them. Next to working out network codes framing the respective market design provisions together with the governance guideline, a proper implementation of this regulatory framework at Member State level is key.
Market integration efforts are on track on the day-ahead timescale, but hardly any progress has been made towards more integrated intraday markets across the EU. The uptake of functioning intraday markets is crucial for the efficient integration of large amounts of wind energy and for cost-efficient system operation in general. What is potentially missing and should be addressed are more detail and prescription on how and by when the market design and governance provisions should be implemented in practice by the Member States, TSOs, energy regulators and power exchanges in order to achieve full market integration by 2014.
EWEA response on CEER public consultation on non-harmonised RES support schemes
EWEA hopes that this consultation will help improve today’s rather lopsided discussion on the liberalisation of the power sector which at times attributes market distortions almost exclusively to the regulatory frameworks for the promotion of RES. This debate fails to acknowledge that RES power generation is disadvantaged compared to conventional power sources such as oil, gas, coal and nuclear power sources, which were developed and introduced through state subsidies and levies on electricity bills. Broadening this discussion to all obstacles on the way to achieving a single European market would help assess the impact of increased RES uptake in European power markets.
EWEA briefing on Horizon 2020 proposal
EWEA briefing on Horizon 2020 proposal.
EWEA response to the Energy Roadmap 2050
EWEA response to the Energy Roadmap 2050
Towards European grid connection requirements: Challenges and opportunities for wind power
The drafting of a European Network Code for the connection of generators (NC) launched within the Third Liberalisation Package is an opportunity for ENTSO-E to deliver a guiding document with a pan-European approach that ultimately will lead to a harmonised set of grid connection requirements in all member states. This would serve, in a cost-effective way, the needs of the system and make the best out of capabilities for system support from wind power plants. As a directly affected stakeholder, EWEA was in dialogue with ENTSO-E during the development of the draft NC. From this position EWEA has identified several shortcomings related both to the contents and structure of the draft NC as to the further deployment of the legislative process in which this NC is embedded.
Therefore, with the present paper, EWEA puts forward recommendations both on the NC and the surrounding regulatory processes at EU and national level which – when taken up by the relevant stakeholders – should facilitate an effective harmonisation of grid code requirements for wind power in all Member States. This harmonisation can be regarded as one of the essential preconditions to achieving the foreseen high penetration levels of wind power in a cost-effective way with due regard to power system stability.
EWEA response to the ACER Framework Guidelines on Capacity Allocation and Congestion Management
EWEA welcomes the timely uptake of the Framework Guidelines on Capacity Allocation and Congestion Management for Electricity (FG CACM) by ACER shortly after the draft FG on the same topic by ERGEG and hereby provides its view on this matter, as the deployment of renewables, particularly wind power, and the integration of European electricity markets, are mutual drivers. However, EWEA has concerns with regards to the consistency with existing EU legislation, in particular on priority access or guaranteed access and dispatch for renewable electricity as stipulated in European Directive 2009/28/EC. In view of these legal requirements in the Renewable Energy Directive EWEA urges ACER and ENTSO-E to proceed with electricity market integration on a basis that does not jeopardise the deployment of renewable electricity necessary to deliver Europe’s agreed decarbonisation objectives.
EWEA response on the EU public consultation paper on the Europe 2020 project bond initiative
EWEA believes that wind energy should be specifically mentioned as a sector with its own allocation need, in particular offshore projects. Furthermore, the associated grid investments needed to facilitate Europe’s 2020 renewable energy commitments are sufficiently large to warrant their own category. The investments needed in offshore grid infrastructure alone are €32 billion according to the EC communication on energy infrastructure priorities for 2020 and beyond. Given the scale of European investments in offshore wind projects as identified by EWEA of approaching 150 GW of projects which have been announced, there is a demand for capital to bring these projects into operation. In EWEA’s view the additional targeting of European offshore wind projects and according grid infrastructure as a recipient of this envisaged bond funding will attract more capital into the offshore market in addition to other means given the perceived confidence the Member States are placing in this market as outlined in their NREAPs and its objectives to install over 43 GW offshore wind power capacity by 2020.
EWEA response to the ACER consultation on the Framework Guidelines on Electricity Grid Connection
EWEA welcomes that the ACER Framework Guidelines contains improvements in its structure, as the previous categories in the ERGEG Pilot Framework Guidelines such as “distributed generation” are now deleted. However, there is still a lack of a clear indication with regards to the handling and criteria for classification of the different generation types in the Network Code. In general ACER should make ENTSO-E in these Framework Guidelines strive for the highest possible level of clear and systematic specifications in the network codes in order to ensure a practical and unambiguous application.
EWEA response on the EU public consultation on permit granting procedures
Long and complicated permitting and planning procedures are a main bottleneck for building new transmission lines. There is inadequate coordination between Member States on cross-border infrastructure both on the planning and licensing levels. The upcoming TEN-E revision should in this respect not only alleviate investments in bilateral interconnectors but also put forward an appropriate planning and regulatory framework when multiple projects are clustered into regional schemes. EWEA agrees with the view that the set-up of one central authorising body within each Member State in charge of cross-border projects is worth exploring. This would avoid delays during the authorisation procedure and speed up implementation in general. EWEA believes that by this means planning procedures would be streamlined to ensure a faster and more reliable permitting scheme including binding deadlines for all involved authorities.
EWEA response on priority list for the development of network codes for 2012 and beyond
EWEA agrees with most elements stated in the current priority list for the development of network codes by the European Commission. In addition, EWEA considers it useful to have a dedicated network code outlining binding rules on provision, procurement, trading and governance of ancillary services. Moreover, EWEA urges ENTSO-E to strive for the highest possible level of clear and systematic specifications in the network codes in order to ensure a practical application by system users throughout Europe.
EWEA response to the ENTSO-E consultation on the Scenario Outlook and System Adequacy Forecast 2011-2025
EWEA welcomes this consultation as an appropriate measure of ENTSO-E to complement the bottom-up scenarios in the previous pilot 10-year network development plan (TYNDP) and ensure consistency with the 2020 RES targets in the upcoming official version of this plan in March 2012. This is crucial as any European generation adequacy outlook and resulting network projects in Europe should factor in this EU objective as the achievement of the 2020 RES targets must not be undermined by inadequate grid enhancements. EWEA calls in particular on ensuring robustness of the top-down scenarios by taking into account EWEA market expectations for wind power growth in the EU by 2020 as an additional margin in the top-down scenarios. Furthermore, EWEA therefore calls on ENTSO-E to develop and utilise a harmonised method for wind power capacity credit assessment in European generation adequacy forecast and the upcoming TYNDP, in order to properly evaluate the contribution of wind power to system adequacy.
EWEA response on the Future Role of the Regional Initiatives
EWEA agrees with the European Commission when stating that Electricity Regional Initiatives (RIs) should collectively pursue the target of full market coupling across the EU by 2015, as outlined in the target model for market integration as developed by the ERGEG Ad hoc Advisory Group (AHAG) and discussed at the Florence Forum. EWEA advises therefore the European
Commission to launch an initiative based on Article 12.3 of the Electricity Regulation (714/2009) redefining the geographical area covered by each regional cooperation structure within the context of a broader process of reform of the RIs. Together with the ongoing construction and planning of new subsea interconnectors and current market coupling activities according to the target model, an upcoming integration of the France-UK-Ireland region with the Central-West region, the Central-West region with the Northern region, as well as the Baltic region with the Northern region seem reasonable.
2050: Facilitating 50% Wind Energy – Recommendations on transmission infrastructure, system operation and electricity market integration
This paper gives a set of recommendations to prepare for the development and planning a future European power system. The recommendations cover both most urgent changes to alleviate severe shortcomings which already now hamper the large scale integration of wind energy and a range of advice which will be necessary to further ensure a smooth transition to a power system with the bulk of electricity demand covered by wind energy in the long run up to 2050. More precisely, the recommendations in this paper cover the following aspects:
• Conceptual and operational aspects of future power systems : proper flexible low carbon generation mix – interacting with a more responsive demand side
• The challenge of providing adequate network infrastructure
• Electricity market design for large-scale wind power
• Institutional and regulatory framework
• Research and Development
Finally, roles and responsibilities of the main stakeholders in the power sector are outlined to illustrate the required level of cooperation to carry out the stated recommendations.
EWEA Position on measures to introduce further quality restrictions on the use of credits from industrial gas projects in the Emission Trading System
Article 11a § 9 of the revised Emission Trading System (ETS Directive 2003/87/EC) gives the European Commission the power to restrict the use of credits from certain Clean Development Mechanism (CDM) project types in the ETS. EWEA strongly believes that the EU should make use of that possibility in the case of credits from CDM projects reducing industrial gases:
a) To ensure economically efficient emission reductions;
b) To ensure environmental integrity of the CDM;
c) To reduce emissions with highest sustainable development co-benefits;
d) To continue promoting sustainable projects in developing countries;
e) To maintain a high carbon price, necessary to motivate change in the EU;
f) especially since other solutions exist to reduce industrial gases emissions.
EWEA response on the ERGEG consultation on the Pilot Framework Guidelines on Electricity Grid Connection
In this response, EWEA wishes not only to address the listed questions for consultation, but also to express its observations on the overall structure and scope of the Pilot framework guideline, particularly in view of the process ongoing in parallel on the Pilot Network Code. It has been stated clearly by stakeholders such as the European Commission as well as by ENTSO-E that the framework guideline and network code priorities for 2011 should be based on the need to ensure secure network operation, the integration of RES and market integration, and on the other hand on enough clarity and consensus between the relevant stakeholders on goals and methods. In this context, EWEA fully supports the priority work on the “pilot” framework guideline and network code on grid connection with a special focus on wind generation, and welcomes the ambition to complete this work by early 2011.
EWEA response on the consultation on the ENTSO-E second annual Work Programme 2010-2011
EWEA welcomes the ENTSO-E consultation on its second annual work programme as required under the third Liberalisation Package and recognises it as a step towards the achievement of the goals outlined in this crucial piece of EU legislation. We believe that this consultation will bring additional benefits with regard to the quality of the final deliverables foreseen in the third Package, in particular network codes and the Ten-year network development plan (TYNDP). The TSOs have set up ENTSO-E prior to the full implementation of the third Package in March 2011 with a dedicated organisational outline and responsibilities as well as an ambitious first work programme. EWEA wishes to express its ongoing support to ENTSO-E in this early start and for the demanding tasks it has set itself, which will require stakeholders to work
closely with ENTSO-E. This will facilitate progress on the issues of most interest to EWEA, particularly the pilot code on grid connection with special focus on wind generation and the TYNDP.
EWEA response to Public Consultation: Towards a new energy strategy for Europe 2011-2020
EWEA welcomes the public consultation on a new Energy Strategy for Europe 2011-2020 given that Europe faces tough challenges over the coming years: climate change, depleting indigenous energy resources, increasing fuel and carbon costs and the threat of supply disruptions.
Key issues for the new Energy Strategy:
1. A strong focus on implementing agreed policies
– Implement the 2009 Renewable Energy Directive
– Implement the 3rd internal energy market package
2. Full integration in the longer term perspective
3. Priority areas for the future strategy
– Modern integrated grids
– Making progress towards a low-carbon energy system
– Leadership in technological innovation
– A strong and coordinated external energy policy
– Protecting the EU citizens
EWEA response to the European Wind Integration Study
A consortium of Transmission System Operators (TSOs) carried out the European Wind Integration Study (EWIS) from 2007 to 2009, financed by the European Commission, and provided the final draft report at the beginning of December 2009. The study was published in April 2010.
The overall aim of EWIS is to examine how best to accommodate wind generation on a large scale up to 2015, from the perspective of European TSOs. With this paper, EWEA aims to highlight the key results from the study and provide a first assessment of its conclusions.
EWEA Position on greenhouse gas reductions
EWEA welcomes the Communication from the Commission and urges Council and European Parliament to agree to 30% domestic GHG reductions by 2020, in order to maintain Europe’s technological and industrial leadership in renewable energy technologies, particularly wind power, in a rapidly growing global market. EWEA is disappointed that the Communication falls short of recommending an immediate unilateral EU move to 30% reduction given that the Communication highlights numerous benefits of moving to 30%…
EWEA Response on the CEER call for evidence on Generation Adequacy Treatment in Electricity
EWEA welcomes the CEER call for evidence as European legislation has not been prescriptive and explicit in the way generation adequacy should be established. In the absence of a proper regulatory framework to establish liquid and efficient electricity markets it is therefore required that all relevant stakeholders deliberate on a more detailed approach to address generation adequacy needs in the IEM.
European Regulators, together with investors in new capacity, the European Commission, and Member States, should continue to acknowledge the contribution of wind generation to Security of Supply in Europe. Wind energy provides a domestic energy source, which is not only fossil-fuel free, but also free from any economic risk emerging from fuel and carbon price volatility as experienced in the recent years. The key advantage of wind power over conventional technologies is that investors have control over generation cost for the life time of the plant: mean site wind speed and the cost of a fully installed wind plant are known from the outset. European Energy Regulators should therefore recognise that the apparently higher wind energy costs have to be compared with the opportunity to plan the economic future of Europe on the basis of known and predictable costs.
EWEA response to the ENTSO-E consultation on the first draft of the Community-wide Ten-Year Electricity Network Development Plan
The swift achievement of deliverables outlined in the 3rd Package is of utmost importance as network developments must be carried out in good time in order to integrate large amounts of wind power, and other renewable energy technologies. When envisaging penetration levels of 34% renewable electricity by 2020, an early release of this ‘Pilot’ 10 Year Network Development Plan (TYNDP), followed promptly by an updated TYNDP incorporating the National Renewable Energy Action Plans, is crucial to reach this target. By 2020, most of the EU’s renewable electricity will be produced by onshore wind farms. Europe must, however, also use the coming decade to prepare for the large-scale exploitation of its largest indigenous resource, offshore wind power. Europe’s 2020 targets would not be achievable in an economical way if mayor transmission projects were not built, or were significantly delayed.
EWEA response on the ERGEG Position Paper on Smart Grids
Several factors require the significant upgrade of transmission and distribution
networks, and the ERGEG paper on Smart Grids addresses most of these challenges. The main challenge at distribution level is a modernisation of networks to adapt to the new realities where generation is implemented closer to demand and where there is a need and opportunity thanks to technical developments for improved end-user participation and massive demand-side response. Technical innovations are enabling the creation of micro grids which under certain critical circumstances (for example during a serious fault at transmission level) would be able to disconnect from transmission network and still satisfy consumer demand in a reliable way. In EWEA’s opinion, this modernised distribution level is the main area for using the terminology Smart Grids.
EWEA response on the ERGEG consultation on the draft advice on the Community-wide Ten-year Electricity Network Development Plan
ENTSO-E’s ongoing work on the first draft of the Ten-Year Network Development Plan (TYNDP) and the present ERGEG consultation document will ensure an early development of a first TYNDP during the interim period of the 3rd Liberalisation Package which is urgently needed. Time is of the essence in grid development in order to meet the 2020 targets. By 2020, most of the EU’s renewable electricity will be produced by onshore wind farms. Europe must, however, also use the coming decade to prepare for the large-scale exploitation of its largest indigenous resource, offshore wind power. Next to the actual grid development plan, the European Regulators advice on the TYNDP and its implementation will be crucial to achieve a joint European approach to overcome planning and administrative barriers for infrastructure, lack of public acceptance of such infrastructure, lack of economic incentives for TSOs to invest and finally to ensure fair and unbiased access to the grid for wind power installations and other renewables.
EWEA response on the ENTSO-E Research & Development Plan EUROGRID 2020
EWEA welcomes the ENTSO-E document «Research and development plan – EUROGRID 2020″ as a significant step forward in implementing the third liberalization package. The proposed R&D programme contains key elements for the integration of large quantities of renewable electricity in the European system by 2020, particularly wind power, and is therefore also key for the implementation of the renewable Energy Directive (2009/28).
EWEA believes that in addition to facilitating the 2020 European system, the proposed R&D programme must form the basis for the transformation of the present European power system into a 2050 renewable-based power system.
EWEA response on the CEER Consultation on regulatory aspects of the integration of wind generation in European electricity markets
This consultation is a good starting point for feedback on electricity market and network access arrangements for wind energy as well as touching upon the urgent issue of an offshore supergrid. The deployment of renewables, particularly wind power, and the integration of European electricity markets, are fundamentally linked, and should not be approached as two separate topics. Moreover, it provides an instructive overview of how wind power generation is currently treated within national network, market and regulatory frameworks across Member States.
EWEA hopes that the consultation conclusions could be used as input with regard to the final deliverables foreseen in the 3rd Package, in particular network codes and framework guidelines on network access and electricity markets.
EWEA response on the ERGEG Draft Strategy Paper: Role of the Regional Initiatives
The creation of a more integrated European energy market is of utmost importance for the wind energy sector. For an efficient integration of wind energy into the European energy network, transmission capacity is essential, but this factor alone is not enough. Along with an adequate physical infrastructure, integrated electricity markets and rules are required that lead to an efficient allocation of these transmission lines that takes into account generation from variable and decentralised generation sources, such as wind power. EWEA acknowledges that Regional Initiatives (RIs) will play a role in the path towards a single electricity market and hereby provides its view on this matter, as the deployment of renewables, particularly wind power, and the integration of European electricity markets are mutual drivers.
Next to existing intergovernmental initiatives, such as the “North Seas Countries’ Offshore Grid Initiative”, there are currently seven RIs, created in a voluntary manner by the European Regulators. These RIs have now gained a legally binding character with the adoption of the 3rd Liberalisation Package.
A Strategy for the way forward of these RIs is therefore needed to set the overall direction of market integration and point out how and when these different RIs could converge into a single market in the future.
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