Policy Department Renewable Technologies

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Policy Department A: Economic and Scientific Policy ____________________________________________________________________________________________ generation in both transmission and distribution network and facilitating access to networks and removing barriers that could prevent access for new market entrants and of electricity from renewable energy sources (Art. 36(d) and (e)). According to the Regulation 713/2009/EC, the Agency for the Cooperation of Energy Regulators (ACER) monitors access to the network including access of electricity produced from renewable energy sources (Art. 11(1)). Once ACER is operational it will develop Framework Guidelines and Network Codes together with the European Networks of Transmission System Operators (ENTSOs, one for electricity and one for gas) that can be made binding through comitology. Network connection and third party access are examples of the issues that will be addressed with the abovementioned codes. This should help the connection of RES to the networks. Shortcomings and policy challenges Gas is well suited as a balancing power for some of the intermittent RES, at least for the time being. Recently the gas prices have dropped radically due to demand destruction in the industrial sector and electricity generation. If the 3rd package provisions boost competition, increase the efficiency of the sector and encourage new entry into the market, this will improve the competitive position of gas as a fuel input to the electricity sector and can potentially discourage renewable electricity generation. However according to the Commission this impact “is expected to be very small” [SEC 2007 1179]. Also, gas is an important source to produce hydrogen - at least in the transition until RES can deliver. In this sense, lower gas prices could even contribute to reducting GHG emissions. For electricity generators using renewable energy sources, long-term strategies from governments are of utter importance to provide certainty investments in renewable projects. Similarly, permitting processes and procedures need to be as short and streamlined as possible. As regards DSOs, they have a dual key role. First, they need to assist the deployment of decentralized RES-power plants and their integration into the distribution grid. This requires the extension of ‘smart grids’. Second, the DSOs are facilitating the emergence of ‘smart’ electricity retail markets by introducing smart grids and smart metering systems. However, industry organizations like Eurelectric have called for a change in the current financing model that the NRAs apply on the DSO activity. The model of simply driving down costs does not leave room for the capital expenditure needed to adapt the network to the new requirements. According to a Eurelectric study, a majority of the studied DSOs had a lower return on invested capital than their weighted average cost of capital, meaning the DSOs destroy rather than create economic value [see also Eurelectric 2010]. Such a situation does not provide for investments in RES connection. Furthermore, it should be carefully studied how the costs of the extra distribution and transmission capacity required by renewable generation activities should be divided among the RE generators and the existing system users. The European Wind Energy Association (EWEA) is convinced that an upgraded and integrated grid will greatly benefit wind energy. However, at the same time the regulatory frameworks for interconnectors and offshore transmission vary greatly from country to country. There is a lack of legal certainty and the risk of stranded investments hinders the development of an offshore grid. EWEA thus calls for harmonization of electricity market and electricity transmission rules across Europe. Concerning harmonization, the above mentioned network codes introduced in the 3rd package should improve the situation when successfully made binding. However, it should be noted that the comitology procedure gives the member states full discretion to influence the contents of the codes and the final outcome may thus differ from the common position reached by the regulators and TSOs. IP/A/ITRE/ST/2009-11 & 12 80 PE 440.278

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