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Sending
the right
signals?
The European Commission’s
energy and climate package
has set the stage for
massive growth in
renewable energy.
But, asks Coralie
Laurencin, has it
done enough
to convince
investors?
On 23 January, the European
Commission unveiled its proposed
renewable energy directive, which aims
to deliver a dramatic increase in the proportion
of the EU’s primary energy supply derived from
renewable sources. But will the directive deliver?
Ultimately, it will be down to the private
sector to provide the renewable energy capacity
required and, in turn, to the investor community
to provide the necessary capital. In
recent years, the financial sector has demonstrated
its appetite for renewable energy projects
and, if policy-makers follow through on the
signals they have given, it will continue to support
the increase of renewables capacity in Europe.
But delivering the EU’s goals depends on
member state governments providing the required
long-term investment signals to persuade
investors and equipment suppliers that support
for renewable energy will be long-lasting.
The directive, part of the EU’s package of
proposed regulations to tackle climate change, is
intended to help member states deliver their
target of 20% of energy coming from renewables
by 2020.This compares to an expected
9–10% in 2010, falling short of the previous 12% target, largely due to insufficient progress in the
renewable heating sector. The key points of the
directive are:
National targets for EU member states based
on past renewables growth and GDP per capita
levels. As a result, western European states typically
have more ambitious targets than their
Eastern European counterparts. Interim targets
for 2011, 2013, 2015 and 2017 have also been
defined, and member states are required to report
on their progress. A country that has fallen behind on an interim target will have to inform
the Commission of the tools it plans to use to
make up for its delay.
National action plans must be provided by
member states to the Commission by 2010 detailing
the targets for each of the renewable sectors:
electricity; heating and cooling, and biofuels.
The directive sets an EU-wide minimum target
for biofuels of 10% of all petrol and diesel consumption
by 2020.
Internal EU flexibility is provided in meeting
national targets. Renewable energy generators
in those member states that comply with their
interim targets will be allowed to export Guarantees
of Origin (GoOs) to other EU states –
effectively transferring that quantity of renewable
power to count towards the importing
country’s target. Each country will be permitted
to limit both imports and exports of GoOs. In
the event that a country has opened its borders
to GoO exports, the renewable plant exporting
its GoOs will receive the support payment of
the country to which it is exporting, rather than
of its country of origin.
The system is open to imported renewables
credits. The directive proposes that production
coming from renewable energy plants outside
the EU can count towards member state targets
provided that the electricity from these
plants is exported into the EU.
One of the disappointments of
the text for the renewable energy
industry is that there are
no sanctions for member states
failing to meet their 2020 targets; instead, the
Commission is relying on careful monitoring of
progress (requiring reporting on interim targets)
and incentives (member states ahead of
their targets may allow exports of GoOs) to encourage
compliance.
The debate has shifted in the past year.
After the 2007 Spring Council meeting, when
heads of state signed up to ambitious EU-wide
targets on renewables, greenhouse gas emissions
and energy efficiency, member states were
concerned with the magnitude of the targets.
However, in the run-up to the publication of the
directive in January 2008, discussion centred on
the flexibility clauses.
Initially, the Commission favoured the creation
of a fully fledged trading market, where renewables
projects could export their GoOs to
the most attractive support systems, creating competition among countries to provide the
best renewable energy incentives. While countries
could, in theory, prevent foreign projects
from benefiting from their support tariffs, in
practice they would be forced to open their
borders for imports and exports of GoOs if
they fell behind their interim targets.

A few countries – led by Spain and Germany
– opposed this. So, instead, the Commission
chose to create a system where the
transfer of certificates was possible for countries
on a voluntary basis, as long as they exceeded
their interim targets.
The current trading proposal will not lead
to massive changes in the existing system. It is
unlikely that states on track with their 2011 and
2013 targets will feel comfortable about opening
their borders for the export of GoOs, in
case they miss later targets. It is likely that the
traded market for GoOs will therefore not see
large volumes, and renewables support will likely
very much remain a national affair.
Undoubtedly, the scale of the 20%
target and the gap that needs to
be filled are clear signals that significant
investment in all renewable
sectors is needed out to 2020. However,
what is required to deliver this investment are
similarly clear signals from governments that
they plan to create policies to meet the targets
and address the non-financial issues that hinder
renewables growth.
According to the EU’s initial calculations, renewables
should provide roughly 35% of electricity
demand in 2020, up from 19% in 2010. So
far, only Germany, Denmark and Spain have
managed to increase their renewables capacity
significantly; the challenge will be to get all EU
states to do the same by 2020. Wind and biomass,
whose technologies are expected to remain
among the cheapest of renewables, are
most likely to fill this gap. In this scenario, biomass
capacity could grow to 49GW in 2020
from 6.1GW in 2006, and wind to 165GW from
48GW over the same period. This implies annual
capacity growth of 9% for wind – which is
less than half the current growth rate – and 16%
for biomass, which is much higher than the current
rate. The need for investment on an EU-wide
level is very clear and now EU countries
must step up to the challenge and reinforce national
support schemes.
There are signs that such policy reinforcement
is under way. While the targets are still
regarded as being extremely ambitious, governments
have adopted a constructive attitude and
are focusing on the options for implementation:
In December 2007, the German government
proposed changes to its renewables law (EEG)
with a target of 30–35% of electricity coming
from renewables by 2020.
The UK is targeting a significant increase in
renewable electricity production: up to 40% of
electricity in 2020 could come from renewables,
from 4.6% in 2006. The government’s proposal
to create bands in the existing Renewable Obligation
(RO) is a step in this direction: it is aiming
to stimulate offshore wind by doubling the
number of tradable RO certificates offshore farms earn per megawatt hour, and is similarly
incentivising other nascent technologies.
In France, the government is expected to
produce in the very near future proposals on
how to increase renewable energy penetration
after last summer’s government-convened
stakeholders’ meeting on climate change.
While policy-makers have a good handle on
how to develop financial support for renewables,
investors continue to be concerned about
the non-financial issues that plague renewables
development. These include planning, grid connection
and access, and administrative hurdles.
Some 3GW of UK projects are held up either
in planning enquiries or awaiting grid connection,
illustrating just how important these hurdles
have become. Similarly, the notoriously
lengthy administrative process in France has
slowed installed capacity growth. The directive
stipulates that national action plans detail how
member states plan to address barriers such as
grid connection and planning and administrative
procedures, and propose advice on these topics.
However, it makes no specific requirements on
any of these issues.
Essentially, the current trading proposals
provide regulatory certainty. However, there is
one large uncertainty looming for investors, as
the renewables directive now will be discussed
throughout 2008 by EU member states, via the
Council of Ministers, and by the European Parliament.
Some stakeholders will take this opportunity
to challenge the current flexibility provisions.
The current proposal only allows trading
of certificates by projects in countries which
have exceeded their interim targets. Because
the targets are high, this is likely to limit the volume
of traded certificates. Those countries that
had hoped to import credits to comply will be
forced to increase renewable energy capacity at
home instead. As a result, several states which
feel that their renewable resources are too low
to meet their target, or that their resources are
very expensive to exploit, may be tempted to
lobby for increased flexibility.
They would like to see reversion to previous
drafts of the directive: whereby member
states would have to open their borders for import
and export of certificates at any time, and
those states that are behind on their targets
would have to open their support systems to
imports. A plant producing in Country A would
be allowed to sell its GoOs to Country B and
reap the support payment of country B, without
having to export the associated power.
Stakeholders in favour of a full-fledged trading
market believe that this will allow for compliance
costs to be brought down.
However, reverting to this proposal would
be counter-productive and damage, rather than
increase, investor certainty. In practice, a trading
system layered on top of national support
systems will increase the complexity of the regulatory
risk for investors. It may also lead member
states to take pre-emptive measures; initially,
some states may choose to reduce the level of
their support schemes to prevent a rush of
GoOs coming their way. Conversely, countries
with mature renewable support systems and
lower payments for renewable energy production
could see their production flee to countries
which offer more attractive returns. Finally,
a trading system placed on top of national measures
will not deliver a uniform price for GoOs,
preventing the development of financial instruments
based on this price.
However, we believe that flexibility, and relatively
low-cost compliance, will nonetheless be
available under the system as proposed. Because
the targets were defined according to GDP per
capita, they are relatively easier for Eastern European
states, where a large part of the EU’s
biomass resource is located. The flexibility could
favour Eastern Europe by encouraging strong
renewable energy development, and GoO exports
from these countries. Exporting renewable
energy certificates provides the exporting
states with the benefits of the production of
clean power – the creation of a renewable energy
industry, and emissions reductions that
would count under the EU Emissions Trading
Scheme (ETS) – without the costs.
Taken together, we believe the climate
and energy package offers a coherent
set of policies. As well as the renewables
directive, it includes the
directive on Phase III of the EU ETS, which targets
a 20% reduction of the EU’s emissions by
2020 (rising to 30% if an international climate
agreement is reached). The EU is also seeking a
20% improvement in energy efficiency by 2020.
These targets mutually reinforce each
other. Any underachievement of the renewables
or energy efficiency targets is designed
to translate into an increase in the carbon
price, which in turn reduces the additional cost
of investment in renewables and energy efficiency
projects, as the electricity price would
rise. Estimates indicate that failing to achieve
the renewables targets would add an extra 600
million–900 million tonnes of carbon dioxide
over the 2012–20 period; this burden would
fall on the EU ETS, increasing the carbon price
for players in that market.
This interaction is an additional security for
investors; if the policies developed by member
states do not send the required signals for investment
in renewables, the carbon market will
provide them.
Coralie Laurencin is associate at Climate Change
Capital, a London-based boutique investment bank.
E-mail: claurencin@c-c-capital.com
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