Special  Report Cohesion  policy  funds  
support  to renewable  
energy  generation  — has  
it achieved  good  results ?EN 2014  NO 06
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ISBN  978 -92-872-0396 -0
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Printed  in Luxembourg
EN 2014  NO 06
Special  Report Cohesion  policy  funds  
support  to renewable  
energy  generation  — has  
it achieved  good  results ?
(pursuant  to Article  287 (4), second  subparagraph , TFEU)
02
 Contents
Paragraph
 Glossary  and  abbreviations
I–VIII  Executive  summary
1–11 Introduction
1–3 Renewable  energy
4–6 EU policy  objectives  — the 2020 renewable  energy  target
7 Barriers  to renewable  energy
8 Financial  support  for renewable  energy  by the cohesion  policy
9–11 Shared  management
12–13 Audit  scope  and  approach
14–47 Observations
14–16 Audited  projects  delivering  outputs  as planned  …
14–16 The  overall  picture  is one  of well-planned  projects  delivering  according  to plan
17–21 … but encountering  some  difficulties  in implementation
17–21 There  is scope  for further  improvement  at all project  stages  — from  procurement  through  operations  to 
monitoring  and  evaluation
22–25 … and  results  not properly  measured  or projects  not attaining  their  energy  generation  targets  in 
the majority  of cases
22–23 RES  data  collection  and  reporting  can  be improved
24–25 Project  results  not always  achieved
26–31 The  principle  of cost-effectiveness  is not fully  considered  in planning  the RES  projects
26–27 Cost-effectiveness  — an important  objective  in EU spending
28–31 There  is scope  for an emphasis  on cost-effectiveness  at an early  stage
03 Contents
32–40 … and  there  is also  scope  for more  cost-effective  RES  generation  projects
41–47 Cohesion  policy  funds  having  limited  EU added  value  — the RES  projects  did not make  their  full 
contribution  to the EU’s  energy  objectives
48–54 Conclusions  and  recommendations
 Annex  I —  Overview  of Member  States’  progress  towards   
the 2020 RES  target
 Annex  II —  Cohesion  policy  (ERDF  and  CF 2007–13 ) funds   
allocation  to RES  and  selected  projects  2007–12
 Annex  III — List of audited  RES  generation  projects
 Annex  IV — Summary  evaluation  of RES  project  results
 Reply  of the Commission
Source : European  Court  of Auditors .
04
 Glossary  
and  abbreviations
CF: Cohesion  Fund
Concept  of cost-effectiveness : It concerns  the ability  or potential  of an audited  entity , activity , programme  
or operation  to achieve  certain  outcomes  at a reasonable  cost . Cost-effectiveness  analyses  are studies  of the 
relationship  between  project  cost  and  outcomes , expressed  as cost  per unit  of outcome  achieved1. The  concept  is 
also  emphasised  in the EU’s  financial  rules  (see  paragraph  6).
CO2: Carbon  dioxide
Deadweight : Deadweight  occurs  where  funding  is provided  to support  a beneficiary  who  would  have  made  the 
same  choice  in the absence  of aid. In such  cases , the outcome  cannot  be attributed  to the policy , and  the aid paid  to 
the beneficiary  has had  no direct  impact .
EIA: Environmental  impact  assessment
ERDF : European  Regional  Development  Fund
EU added  value : On a general  level , EU added  value  is the value  resulting  from  an EU intervention  which  is 
additional  to the value  that  would  have  been  otherwise  created  by Member  State  action  alone .
Feed-in  tariff  (FIT) : A policy  mechanism  designed  to accelerate  investment  in renewable  energy  technologies  by 
offering  long-term  contracts  to renewable  energy  producers , typically  based  on the cost  of generation  of each  
technology .
MS: Member  State
PV: Photovoltaic
RES : Renewable  energy  sources  — energy  from  renewable  non-fossil  sources , namely  wind , solar , aerothermal , 
geothermal , hydrothermal  and  ocean  energy , hydropower , biomass , landfill  gas, sewage  treatment  plant  gas and  
biogases :
 ο Geothermal  energy  means  energy  stored  in the form  of heat  beneath  the surface  of solid  earth .
 ο Biomass  means  the biodegradable  fraction  of products , waste  and  residues  from  biological  origin  from  
agriculture  (including  vegetable  and  animal  substances) , forestry  and  related  industries  including  fisheries  and  
aquaculture , as well  as the biodegradable  fraction  of industrial  and  municipal  waste .
 ο Solar  energy  means  radiant  light  and  heat  from  the sun harnessed  using  a range  of technologies  such  as solar  
heating , solar  photovoltaic  and  solar  thermal  electricity .
 ο Wind  power  means  the conversion  of wind  energy  into  a useful  form  of energy , such  as using  wind  turbines  to 
make  electrical  power .
 ο Hydro  energy  is the conversion  of kinetic  energy  derived  from  falling  and  running  water  into  electrical  energy .
1 ISSAI  3000: Standards  and guidelines  for performance  auditing  based  on Intosai ’s Auditing  Standards  and practical  experience .
05 Glossary and abbreviations 
RES  directive : Directive  2009/28/ EC of 23 April  2009  on the promotion  of energy  from  renewable  sources  and  
amending  and  subsequently  repealing  Directives  2001/77/ EC and  2003/30/ EC.
RES  2020  targets : Directive  2009/28/ EC on renewable  energy , to be implemented  by Member  States  by 
December  2010, set mandatory  national  targets  for all Member  States  so that  by 2020  the EU will achieve  a share  
of 20 % of energy  from  renewable  sources  in general  and  of 10 % in the transport  sector  particularly .
Measurement  of energy  units :
 οGW , MW , kW — Giga /Mega /Kilo  watt
 οGWh , MWh, kWh  — Giga /Mega /Kilo  watt  hour
 οkWp  — kilowatts-peak  — nominal  power  of the PV module
06
 Executive  
summary
I
This  audit  sought  to answer  the question  of whether  
good  results  had  been  achieved  by the two  most  
important  funding  sources  among  EU spending  
programmes  for promoting  renewable  energy  — the 
European  Regional  Development  Fund  and  the Cohe -
sion  Fund  (cohesion  policy  funds) .
II
Approximately  4,7  billion  euro  was  allocated  for 
renewable  energy  in the 2007–13  programming  
period . The  Court  examined  whether  funds  in that  
period  had  been  allocated  to well-prioritised , cost-
effective  and  mature  renewable  energy  generation  
projects  with  rational  objectives  and  to what  extent  
these  funds  had  achieved  good  results  in contribut -
ing to the EU 2020  target  for energy  from  renewable  
sources  (RES) .
III
The  Court  found  that  the 24 audited2 RES  generation  
projects  delivered  outputs  as planned . Most  of the 
audited  RES  projects  were  sufficiently  mature  and  
ready  for implementation  when  selected . There  were  
no major  cost  overruns  or time  delays  in the projects  
and  the RES  generation  capacities  were  installed  as 
planned  and  operational . No major  risks  to their  tech -
nical  sustainability  were  apparent .
2 The audit  results  were  derived  from  an examination  of 24 completed  
renewable  energy  generation  projects  from  nine  operational  
programmes  financed  through  the ERDF  or the CF in Malta , Austria , 
Poland , Finland  and the United  Kingdom . The projects  were  in the 
biomass , photovoltaic , solar  thermal  and wind  energy  sectors .IV
In one  third  of the audited  projects  the energy  
production  targets  had  been  achieved  (or almost  
achieved)  and  properly  measured . The  Court  found  
that  the overall  value  for money  of cohesion  policy  
funds  support  to RES  generation  projects  has been  
limited  in helping  achieve  the EU RES  2020  target , 
because :
 οcost-effectiveness  has not been  the guiding  princi -
ple in planning  and  implementing  the RES  genera -
tion  projects ; and
 οcohesion  policy  funds  had  a limited  EU added  
value .
V
In more  detail , the Court  found  potential  for improve -
ments  in the Member  States  covered  by the audit : 
some  procurement  processes  did not ensure  full trans -
parency , fairness  and  efficiency  in contractors’  selec -
tion ; preparation  was  insufficient  for effective  moni -
toring  and  evaluation ; programmes  did not explain  
how  the EU funds  could  contribute  cost-effectively  
to reaching  the RES  objectives ; cost-effectiveness  of 
measures  in different  RES  sectors  was  not always  con -
sidered  when  the budgets  were  earmarked ; and  the 
programmes  failed  to establish  performance  indica -
tors  for monitoring  and  evaluation .
VI
The  Court  concludes  that  improvements  are needed  
if funding  under  these  programmes  is to make  the 
maximum  possible  contribution  to achieving  the 
RES  2020  targets .
Executive summary 07
VII
Cohesion  policy  spending , in general , brings  benefits  
to the broader  economy , and  although  the direct  
measurement  of economic  growth  or job creation  — 
the overarching  aims  of cohesion  policy  — was  out-
side  the scope  of this audit , the Court’s  observations  
and  recommendations  are also  made  in the context  of 
these  policy  aims .
VIII
In view  of a likely  enhanced  use of EU funds  for pro-
moting  RES  in the 2014–20  programming  period , the 
Court  makes  the following  recommendations :
Recommendation  1
The  Commission , through  guidance  setting  for pro-
gramme  and  project  preparation  and  selection  as well  
as through  conditions  for making  funding  available  for 
RES  generation  investments , should :
 οensure  that  future  cohesion  policy  co-funded  RES 
programmes  are guided  by the principle  of cost-
effectiveness , including  the avoidance  of dead -
weight . Programmes  must  be based  on proper  
needs  assessment , prioritisation  of the most  
cost-effective  technologies  (while  not discriminat -
ing between  RES  sectors)  and  optimal  contribution  
to the EU RES  2020  target . Adequate  RES  genera -
tion  objectives  in relation  to the budget  as well  
as project  selection  criteria  with  a focus  on the 
cost-effectiveness  of the energy  generation  results  
(avoiding  over-compensation  of projects)  need  to 
be set;
 οpromote  the establishment  by the Member  States  
of a stable  and  predictable  regulatory  framework  
for RES  in general , along  with  smoother  procedures  
for the integration  of electricity  from  RES  into  the 
grid  networks .Recommendation  2
The  Member  States  should  establish  and  apply , based  
on Commission  guidance , minimum  cost-effectiveness  
criteria  which  are adapted  to the projects’  circum -
stances . They  should  also  enhance  the added  value  of 
cohesion  policy  funds  by improving  RES  project  imple -
mentation  as well  as monitoring  and  evaluation  and  
by building  a stock  of measured  data  about  energy  
generation  costs  in all relevant  RES  sectors .
08
 Introduction
Renewable  energy
01 
Energy  from  renewable  sources  (RES)  
is important  for improving  the secu -
rity of energy  supply  in the EU and  for 
reducing  the EU’s  dependence  on con -
ventional  (fossil)  fuels  and  imported  
energy , and  for reducing  greenhouse  
gas emissions . Electricity  and  heat  can 
be generated  from  a range  of resourc -
es, from  the sun (concentrated  solar  
power  or photovoltaic  power) , wind  
(onshore  or offshore) , water  (large , 
small  or micro  hydro) , earth  (geother -
mal  for electricity  or heat)  and  biomass  
(solid , liquid , landfill  gas and  biode -
gradable  fraction  of industrial  and  
municipal  waste , and  liquid  biofuels) .
02 
RES  also  have  an important  role  to play  
in reducing  carbon  dioxide  (CO2) emis -
sions  and  enhancing  environmental  
sustainability . Moreover , the develop -
ment  of RES  technologies  has a poten -
tial to boost  Europe’s  economy , indus -
trial  competitiveness  and  employment . 
RES  are expected  to be economically  
competitive  with  conventional  energy  
sources  in the medium  to long  term3.
03 
The  development  of renewable  energy  
is laid  out in the Article  194 (1) of the 
Treaty  on the Functioning  of the 
European  Union  in the context  of the 
establishment  and  functioning  of the 
internal  market  and  the need  to pre-
serve  and  improve  the environment .EU policy  objectives  — 
the  2020 renewable  
energy  target
04 
Already  in 1997, the EU had  declared  
a 12 % RES  target  by 2010. The  Council  
of the European  Union  (the  Council)  
set a binding  EU target  of 20 % in RES 
in gross  final  energy  consumption  
by 2020, based  on the Commission’s  
Renewable  Energy  Roadmap  which  
lays  down  a pathway  for mainstream -
ing RES  into  EU energy  policies  and  
markets  (see  Annex  I concerning  
the national  2020  RES  targets)4. The  
renewable  energy  directive  adopted  
in 2009  constitutes  a legally  binding  
framework  for the promotion  of RES 
until  20205:
 οApart  from  setting  the over -
all 20 % binding  target  for the EU 
and  binding  national  targets  of 
between  10 and  49 % by 2020  it im-
proves  the framework  for promot -
ing RES  electricity  (e.g. by introduc -
ing requirements  for the Member  
States  concerning  access  to the 
electricity  grid  and  simplification  of 
administrative  procedures) .
 οIt required  the Member  States  to 
develop  national  action  plans  that  
establish  roadmaps  for the devel -
opment  of RES  and  created  coop -
eration  mechanisms  between  the 
Member  States  to help  achieve  the 
RES  target  cost-effectively .3 COM( 2010 ) 639 final  
of 10 November  2010 
‘Energy  2020: A strategy  for 
competitive , sustainable  and 
secure  energy’ .
4 COM( 2006 ) 848 final  of 
10 January  2007 ‘Renewable  
Energy  Roadmap  — 
Renewable  energies  in the 
21st century : building  a more  
sustainable  future’ . 
5 Directive  2009/28/ EC of the 
European  Parliament  and of 
the Council  of 23 April  2009 
on the promotion  of the use 
of energy  from  renewable  
sources  and amending  and 
subsequently  repealing  
Directives  2001/77/ EC and 
2003/30/ EC (‘RES  Directive’)  
(OJ L 140, 5.6.2009, p. 16).
09 Introduction
05 
The  Member  States  are required  to 
ensure  that  their  share  of RES  equals  or 
exceeds  indicative  trajectories  to reach  
the RES  2020  target . They  must  report  
every  2 years  to the Commission  on 
implementation  of the directive  and  
progress  towards  their  individual  
targets . RES  measures  are to be intro -
duced  in a cost-effective  way6. The  
Commission  must  produce , by 31 De-
cember  2014, a progress  report  on the 
implementation  of the RES  directive7.
06 
In addition , the EU’s  financial  rules  
stipulate  that  the cost-effectiveness  
principle  must  be an important  deter -
minant  of public  spending  decisions8. 
Moreover , the European  Parliament  
noted  the need  to identify  the most  
cost-effective  RES  and  cost-optimal  
policies  for realising  the potential  
of RES9. According  to the Commis -
sion’s  latest  progress  report10 the EU’s  
RES  2020  target  will likely  be exceeded  
as a whole , whereas  not all Member  
States  were  on track  in 2012  to reach  
their  binding  national  targets , see 
Annex  I. Following  its Green  Paper  
in 2013, the Commission  laid  out initial  
considerations  for the Union’s  climate  
and  energy  policy  for the period  
from  2020  to 2030, proposing  a bind -
ing EU target  of 27 % for RES11.Barriers  to renewable  
energy
07 
Apart  from  exogenous  factors  (such  
as evolution  of energy  prices  or ac-
cess  to loans)  multiple  sector-specific  
obstacles  hamper  investments  in RES 
throughout  the Union  and  have  not 
yet been  eliminated  by the Member  
States  and  the Commission12:
 οInstitutional  and  legal  barriers , 
e.g. the priority  given  at EU level  to 
energy  issues  is not always  reflect -
ed at local , regional  and  national  
level  whereby  a lack  of clear  imple -
mentation  strategies  and  flexibility  
in the relevant  administrations  or 
the national  legal  regimes  as well  as 
unclear  legislative  and  contractual  
frameworks  standing  in the way  of 
promoting  RES; complex  authorisa -
tion  and  permitting  procedures  for 
planning , building  and  operating  
RES  installations  together  with  en-
vironmental  requirements  discour -
aging  project  promoters  to come  
up with  feasible  project  proposals  
(lack  of an effective  administrative  
system)
 οDifficulties  in integrating  RES  elec -
tricity  in the transmission  or distri -
bution  grids  (technical  problems , 
insufficient  infrastructure , discrimi -
natory  practices  preventing  grid  
access , distribution  of costs  among  
the grid  operators , government  
and  project  promoters  and  a lack  of 
measuring  of energy  generation)
 οNon-stable  or non-predictable  
promotion  and  incentive  regimes  
and  a lack  of information  for sup -
pliers , customers  and  installers  
hampering  the use of cost-effective  
technologies .6 Preamble  (9) and (41) to the 
RES directive .
7 Article  23(8)(c) of the RES 
directive .
8 Article  18(1)(h) of Commission  
Delegated  Regulation  
(EU)  No 1268/2012 of 
29 October  2012 on the rules  
of application  of Regulation  
(EU, Euratom)  No 966/2012 of 
the European  Parliament  and 
the Council  on the financial  
rules  applicable  to the general  
budget  of the Union  (OJ L 362, 
31.12.2012, p. 1).
9 European  Parliament  
Resolution  of 21 May  2013: 
Current  challenges  and 
opportunities  for renewable  
energy  in the European  
internal  energy  market  
(2012/2259 (INI)) .
10 COM( 2013 ) 175 final  of 
27 March  2013 ‘Renewable  
energy  progress  report’ .
11 COM( 2013 ) 169 final  of 
27 March  2013, Green  
Paper  ‘A 2030 framework  
for climate  and energy  
policies’ . COM( 2014 ) 15 final  
of 22 January  2014 ‘A policy  
framework  for climate  and 
energy  in the period  from  
2020  to 2030 ’.
12 See, for instance , 
COM( 2012 ) 271 final  of 
6 June  2012 ‘Renewable  
Energy : a major  player  in the 
European  energy  market’ , 
and its 2010  and 2012 
biannual  progress  reports , 
COM( 2011 ) 31 final  of 
31 January  2011 and 
COM( 2013 ) 175 final  of 
27 March  2013. See also  
reports  by European  RES 
industry  associations  
(European  Renewable  Energy  
Council  (EREC)  and its member  
organisations) , particularly  
‘Analysis  of deviation  and 
barriers , 2013 report’ , by EREC , 
www .keepontrack .eu/
publications .
10 Introduction
Financial  support  for 
renewable  energy  by the  
cohesion  policy
08 
Cohesion  policy  instruments  — the 
European  Regional  Development  Fund  
(ERDF)  and  the Cohesion  Fund  (CF)  — 
are the most  important  funding  source  
among  the EU spending  programmes13 
for promoting  renewable  energy . 
While  during  the 2000–06  program -
ming  period  only  600  million  euro  
had  supported  projects  in this sec-
tor, approximately  4,7  billion  euro  
was  allocated  to renewable  energy  
in the 2007–13  programming  period , 
reflecting  a much  higher  importance  
to this policy  area  (see  Annex  II for 
the breakdown  by Member  States) . 
In the 2014–20  programming  period , 
cohesion  policy  support  to the shift  
towards  a low-carbon  economy  will 
further  increase  and  may  reach  at least  
27 billion  euro  from  the ERDF14. Further  
support  can also  be provided  through  
the Cohesion  Fund .13 Other  EU programmes  
promoting  RES in the 2007–13 
programming  period  were : 
European  Energy  Programme  
for Recovery , Intelligent  
Energy  Europe  Programme  
and Framework  Programme  
for Research .
14 Regions  will have  to invest  
a minimum  share  of ERDF  
resources  (20 % for more  
developed  regions , 15 % for 
transition  regions  and 12 % 
for less developed  regions)  in 
supporting  the shift  towards  
a low-carbon  economy  in all 
sectors , including  investments  
in renewable  energy  
(Article  4(1) of Regulation  (EU)  
No 1301/2013 of the European  
Parliament  and of the Council  
of 17 December  2013 on 
the European  Regional  
Development  Fund  and on 
specific  provisions  concerning  
the Investment  for growth  
and jobs  goal  and repealing  
Regulation  (EC) No 1080/2006 
(OJ L 347, 20.12.2013, p. 289 )).
Cohesion  policy  spending  for RES  — key  facts
 ο270,8  billion  euro  — total  ERDF /CF allocations  for 2007 –13
 ο0,6 billion  euro  — total  ERDF /CF allocations  to RES  for 2000 –06
 ο4,7 billion  euro  — total  ERDF /CF allocations  to RES  for 2007 –13
At least  27 billion  euro  — estimated  minimum  ERDF  allocations  to supporting  the shift  towards  a low-car -
bon  economy , including  RES , for 2014 –20. Further  allocations  could  also  be made  from  the Cohesion  Fund  
(footnote  14).Box  1
11 Introduction
Shared  management
09 
In the framework  of cohesion  policy  
the Member  States  draft  the individual  
operational  programmes , set up and  
operate  their  management  and  control  
systems  and  issue  annual  implemen -
tation  reports  to the Commission . 
Moreover , as part  of the day-to-day  
management , national  or regional  
bodies  select  the projects  and  are 
responsible  for their  implementation  
and  evaluation .
10 
Managing  authorities , intermediate  
bodies  and  certifying  authorities  are in 
charge  of managing  the implementa -
tion  of the operational  programmes15. 
Project  funding  is subject  to rules  and  
conditions  laid  down  partly  at EU16 and  
partly  at Member  State  level  (pro -
ject  selection ; project  cost , benefit  
and  earnings  assessments ; and  also  
economic , social  and  environmental  
impact  assessments  are responsibili -
ties of the Member  States’  authorities) .11 
The  Commission  issues  guidelines  for 
drawing  up operational  programmes , 
approves  the operational  programmes  
and  supervises  the setting  up and  the 
operation  of systems  in the Member  
States . In particular , it monitors  the 
implementation  of the operational  
programmes  essentially  through  the 
implementation  reports  received  and  
through  participation  in monitoring  
committees . In addition  to annual  
implementation  reports , the Commis -
sion  may  request  specific  programme  
information  and  ‘project  selection’  
data  from  the managing  authorities .15 A summary  of the rules  for the 
application  of the European  
Regional  Development  
Fund , the European  Social  
Fund  and the Cohesion  
Fund  2007–13, including  on 
management  and control  
systems , is available  on: 
http ://europa .eu/legislation_
summaries /regional_policy /
management /g24241 _en.htm
16 Council  Regulation  (EC)  
No 1083/2006 of 11 July 2006 
laying  down  general  
provisions  on the European  
Regional  Development  
Fund , the European  Social  
Fund  and the Cohesion  Fund  
and repealing  Regulation  
(EC) No 1260/1999 (OJ L 210, 
31.7.2006, p. 25).
12
 Audit  scope  
and  approach
12 
The  audit  sought  to answer  the ques -
tion  whether  the ERDF  and  CF projects  
investing  in renewable  energy  gen -
eration  had  achieved  good  results . 
In this regard , multiple  audit  criteria  
were  developed  (see  Annex  IV) which  
were  based  on different  sources  and  
studies , including  such  by the Com -
mission’s  services . The  Court  examined  
whether  the audited  projects  were  
implemented  and  delivered  outputs  
as planned  and  whether  they  attained  
their  energy  generation  targets . The  
audit  analysed  in particular  whether  
the funds  in the operational  pro-
grammes  in the 2007–13  programming  
period  had  been  allocated  to well  
prioritised , cost-effective  and  mature  
renewable  energy  generation  projects  
with  rational  objectives  and  the extent  
of the projects’  contribution  in achiev -
ing the 2020  RES  target .
13 
The  audit  results  were  derived  from  
an examination  of 24 completed  
renewable  energy  generation  projects  
from  nine  operational  programmes  
financed  through  the ERDF  or the CF in 
Austria , Finland , Malta , Poland  and  the 
United  Kingdom17. The  projects  were  
in the biomass , photovoltaic  (PV) , solar  
thermal  and  wind  energy  sectors18. 
Annex  III presents  a list of the audited  
RES  projects .17 Based  on the allocation  of 
funds  to RES in the operational  
programmes  the following  
were  selected :
 OP I — Investing  in 
Competitiveness  for  
a Better  Quality  of Life —  
2007 MT161PO001
 OP Niederösterreich  
2007–13: Ziel Regionale  
Wettbewerbsfähigkeit  & 
Beschäftigung /EFRE  —  
2007 AT162PO001
 OP Salzburg  2007–13: 
Ziel Regionale  
Wettbewerbsfähigkeit  & 
Beschäftigung /EFRE  -  
2007 AT162PO006 
 OP Steiermark  2007–13:  
Ziel Regionale  
Wettbewerbsfähigkeit  & 
Beschäftigung /EFRE  —  
2007 AT162PO007
 OP Program  Operacyjny  
Infrastruktura  i Środowisko  —  
2007 PL161PO002 
 OP Regionalny  Program  
Operacyjny  Województwa  
Lubelskiego  — 
2007 PL161PO007
 OP Alueellinen  Kilpailukyky-ja  
työllisyystavoite ; Länsi-Suomen  
EAKR-Toimenpideohjelma  
2007–13 —  
CCI2007 FI162PO003
 OP West  Wales  and the 
Valleys  ERDF  Convergence  
programme  —  
2007 UK161PO002
 OP East  Wales  ERDF  Regional  
competitiveness  and 
Employment  programme  —  
2007 UK162PO012
18 Of the 24 audited  projects , 
9 were  for electricity  
production  from  full-scale  
or micro-wind  turbines  
or photovoltaic  panels , 
15 projects  related  to heat  
generation  from  biomass  or 
hot water  production  from  
solar  collectors . The size of 
the projects  varied  from  
household-scale  single  solar  
panel  projects  to a wind  farm  
with  16 turbines .
13
 Observations
Audited  projects  
delivering  outputs  as 
planned  …
The  overall  picture  is one  
of well-planned  projects  
delivering  according  to plan
14 
The  audited  RES  projects  were  suf-
ficiently  mature  and  ready  for imple -
mentation  when  selected . In spite  of 
relatively  long  preparatory  phases  in 
some  of the biomass  and  wind  energy  
projects  critical  permits , licences  and  
technical  plans  had  usually  been  ob-
tained  prior  to project  approval . Where  
applicable , it was  also  ensured  that  the 
installations  were  connected  to the 
transmission  or distribution  networks  
or that  contracts  were  concluded  with  
a sufficient  number  of consumers19.
15 
There  have  been  no significant  cost  
overruns  or time  delays  in the projects . 
Overall , the audited  RES  projects  were  
implemented  within  the planned  time  schedules  or with  only  relatively  small  
time  slippages  (implementation  was  
delayed  by more  than  6 months  only  in 
two  projects  of which  one  was  due  to 
repair  downtime  of a small  combined  
heat  and  power  plant) . No significant  
cost  overruns  occurred  during  imple -
mentation . Box  2 shows  examples  of 
audited  RES  projects .
16 
With  the exception  of one  biomass  
facility20, the RES  generation  capaci -
ties were  installed  and  operational  
as planned . No major  risks  to their  
technical  sustainability  were  apparent . 
Few  deviations  from  initial  planning  
and  approved  project  proposals  were  
found . The  projects’  installed  energy  
generation  capacities  were  generally  
in line  with  the co-financing  decisions . 
The  facilities  have  been  in opera -
tion  without  major  technical  or other  
problems  since  their  commissioning . 
Only  a few generation  units  from  the 
audited  projects  were  not in operation  
mode . Operators  had  in place  suffi -
cient  expertise  and  resources  to ensure  
a smooth  running  and  regular  mainte -
nance  of their  installations .19 For instance , the approval  of 
the audited  biomass  projects  
in Austria  was conditional  
on a sufficient  number  of 
consumers  of the produced  
heat  energy .
20 One  biomass  power  plant  
in Austria  deviated  from  
the original  plan  in that  it 
utilised  EU funds  for heat  
network  extension  instead  
of installing  a second  boiler  
as per the original  plan . This  
deviation  was in anticipation  
of an extension  of heating  
capacity  to serve  additional  
heat  consumers  and is 
therefore  not a shortcoming  
from  a sound  financial  
management  point  of view .Picture  1Interior  view  of the biomass  power  plant  in Bruck  an der 
Mur , Austria  (project  installed  and  operational  as planned)
Source : European  Court  of Auditors .

14 Observations Picture  2Wood  chips  in a storage  hopper  in the biomass  power  plant  in Bruck  an der Mur , 
Austria
Source : European  Court  of Auditors .
Examples  of audited  RES  projects  co-financed  by the cohesion  policy  funds  — outputs
For more  details  concerning  project  outputs  see Annex  III.
Biomass
Three  audited  biomass  heating  plants  (capacity  from  3 MW  to 8 MW)  with  district  heating  network  lines  
(of 0,6  to 11 km)  were  constructed  in Austria . The  plants  supplied  heat  and  hot water  for a total  of 266  con -
sumers  (private  individuals  or industrial  companies) .
Three  audited  projects  in Finland  related  to the construction  of new  biomass-pellet  or wood  chips  boilers  (ca-
pacity  from  0,8  MW  to 2,5  MW) . They  replaced  old fossil  fuel  (heavy  oil) boilers . Two  of these  projects  included  
also  construction  of the required  district  heating  network  (0,6 and  3 km) .
Wind  power
Five  wind  farms  with  power  capacities  ranging  from  3,2  to 38 MW  were  constructed  in Poland . The  facilities  
include  all necessary  infrastructures  (high /medium  voltage  substations , connections  to electricity  grid  and  
service  roads) .
Solar  power  (PV  and  solar  collectors)
Two  projects  installed  PV electricity  systems  with  associated  hardware  and  monitoring  systems  on public  
buildings  in Malta . One  project  was  complemented  by a small  wind  turbine .
Five  similar  projects  in Poland  installed  individual  sets  of flat plate  solar  collectors  for households  and  public  
buildings  in five  municipalities  to supply  residents  with  hot water . In total , over  3 000  public  and  private  ben -
eficiaries  installed  solar  collectors . One  project  included  street  lighting  and  PV.Box  2
15 Observations
… but  encountering  some  
difficulties  in 
implementation
There  is scope  for further  
improvement  at all project  
stages  — from  procurement  
through  operations  to moni -
toring  and  evaluation
17 
Difficulties  with  RES  electricity  inte -
gration  into  the grid  have  hampered  
exploitation  of RES . Throughout  the EU 
the development  of the grid  has been  
identified  as one  of the key barriers  to 
the large-scale  integration  of RES  elec -
tricity  into  the transmission  and  distri -
bution  grids21. Accordingly , the Union  
and  its Member  States  need  to invest  in both  national  networks  and  cross-
border  links  as part  of building  the 
internal  energy  market . The  owners  of 
the projects  audited  emphasised  that  
spare  capacity  in the grids  was  insuffi -
cient22, the grids  have  to be expanded  
and  modernised  and  greater  transpar -
ency  about  the distribution  of costs  
among  the grid  operators , government  
and  project  promoters  could  improve  
system-wide  efficiency . While  only  few 
of the audited  projects  encountered  
grid  connection  problems , the deploy -
ment  of RES  generation  is, nonethe -
less , not accompanied  by improved  
grids  in the Member  States . Technical  
and  cost  issues  were  frequently  cited  
by national  authorities  and  RES  opera -
tors  as impediments  to an effective  
RES  integration  to the grids . Box  3 il-
lustrates  problems  in connection  with  
RES  electricity  in the grids .21 COM( 2013 ) 175 final .
22 See also  Directive  2005/89/ EC 
of the European  Parliament  
and of the Council  of 
18 January  2006 concerning  
measures  to safeguard  
security  of electricity  supply  
and infrastructure  investment  
(OJ L 33, 4.2.2006, p. 22). 
Article  3(2)(f) stipulates  
that  Member  States  in 
implementing  measures  
aimed  at safeguarding  
security  of electricity  supply  
shall  take  account  of the 
need  to ensure  sufficient  
transmission  and generation  
reserve  capacity  for stable  
operation .Picture  3Windfarm  in Golice , Poland
Source : European  Court  of Auditors .

16 Observations
18 
The  Commission  in its analysis  of Mem -
ber States’  2011  renewable  energy  pro-
gress  reports  indicated  that  progress  
removing  the administrative  barriers  
was  still slow , with  complex  and  dis-
couraging  authorisation  and  permit -
ting  procedures24. There  is potential  for 
improvements  in the Member  States  
where  the audit  took  place . The  audit  
found , for example , that  Malta  had  
embarked  on RES  development  only  
during  the 2007–13  period  whereby  a market  for RES  has not yet developed  
to maturity . An effective  administra -
tive  system  has not developed  in full 
yet. Moreover , in Poland  and  in the 
United  Kingdom  national  or regional  
harmonised  approaches  to coordinate  
the work  of the authorities  were  par-
tially  lacking . Notably  measuring  and  
reporting  of projects’  energy  results  
were  poor  and  hence  data  was  not 
used  for comparing  projects  and  dif-
ferent  RES  sectors  as a useful  informa -
tion  in designing  future  measures .24 SWD( 2013 ) 102 final  of 
27 March  2013 ‘Renewable  
energy  progress  report’ .Access  to the grid  of RES  electricity  in Poland , integration  of electricity  from  
photovoltaic  into  the grid  in Malta
The  poor  state  and  lack  of spare  capacity  of the transmission  and  distribution  grids  have  been  key barriers  to 
the further  integration  of electricity  from  PV and  wind  energy  in Poland . Apart  from  the need  for expansion  
and  modernisation  of grid  infrastructure , complications  with  obtaining  the necessary  permits  for grid  con -
nection  (legal  and  technical  problems  as well  as grid  connection  fees)  hampered  RES  development23. In the 
audited  wind  energy  projects , the lead  times  to construction  of the facilities , including  for the required  grid  
connection  permits , have  been  4 to 5 years .
Clear  guidelines  about  planning  permission  and  permits , where  required , were  available  concerning  solar  and  
PV installations  in Malta . However , in 2010  and  2011  when  multiple  EU co-funded  projects  were  commissioned  
these  frequently  encountered  difficulties  with  feeding-in  of their  generated  electricity  — usually  the electric -
ity in excess  of producers’  own  consumption . Since  meters  had  not been  installed  by the grid  operator  the 
producers  were  not compensated  for their  electricity  by the feed-in  tariff  for periods  of up to 4 months .
23 Integration  of electricity  from  renewables  to the electricity  grid  and to the electricity  market  — RES-Integration . National  report : Poland . 
Eclareon , Oeko-Institut  e.V., 20.12.2011.Box  3
17 Observations
19 
However , a good  practice  example  was  
found  in Austria . A quality  manage -
ment  tool  for biomass  heating  plants  
assured  proper  monitoring  arrange -
ments  in this Member  State  (‘QM  Hei-
zwerke’ , see Box  4).
Project  monitoring  in Austria
All biomass  district  heating  plants  larger  than  400  kW and /or feeding  a heating  network  larger  than  1 km are 
obliged  to carry  out an accompanying  quality  management . Coordination  of the funding  process  and  the 
management  of the necessary  planning  and  operating  data  is facilitated  through  a database  which  provides  
a standard  platform  for project  beneficiaries , as well  as technical  and  economic  data  for quality  managers  and  
an IT platform  for monitoring  and  optimisation  of the operations . Introduced  in 2006, ‘QM  Heizwerke’  con -
tains  data  from  over  100  biomass  plants .
Web  link: www .qm-heizwerke .atBox  4 Picture  4Auditors  visiting  biomass  power  plant  in Weissenbach  an der Triesting , Austria
Source : European  Court  of Auditors .

18 Observations
20 
The  procurement  processes  did not 
ensure  full transparency , fairness  or ef-
ficiency  in contractors’  selection :
 οThe  tenders  had  to be cancelled  
in two  audited  PV projects  in 
Malta  because  all bids  had  been  
technically  or administratively  
non-compliant . This  was  due  to 
either  unnecessarily  high  technical  
requirements  or overly  complex  
procedures  and  requirements . In 
both  cases  some  delay  occurred  
and  competition  among  bidders  
was  hampered .
 οIn two  projects  in Poland , the 
wind  turbine  models  were  speci -
fied  unnecessarily  in construction  
plans  or construction  permits . This  
prevented  tender  specifications  
which  could  ensure  competitive  
procurement  and  best  price /quality  
ratios . In another  project , likewise , 
a specific  solar  collector  type  had  
been  pre-determined . In each  of those  tenders  only  one  bid of 
those  submitted  met  the technical  
specifications .
 οImplementing  bodies  and  project  
beneficiaries  lacked  sufficient  ex-
pertise  on RES  technologies , their  
markets  and  procurement  frame -
works . Multiple  RES  equipment  
and  installation  works  have  been  of 
a similar , sometimes  identical , na-
ture  and  small  in size , especially  the 
operations  under  grant  schemes . 
Therefore , conditions  were  there  
for a coordinated  procurement  
managed  by a specialised  unit  of 
experts  at national /regional  level  to 
obtain  better  price /quality  ratios , 
economies  of scale  and  also  shorter  
procurement  periods . Examples  are 
roof  top water  heating  systems , PV 
panels  and  small  biomass  in Malta  
and  Poland . There  were  temporary  
suspensions  of projects  in Malta , 
partly  as a result  of non-efficient  
organisation  of procurement .Picture  5Biomass  power  plant  in Flachau , Austria
Source : European  Court  of Auditors .

19 Observations
21 
The  preparation  of the RES  projects  
has been  insufficient  for effective  
monitoring  and  evaluation . The  objec -
tives  and  performance  indicators  set 
in all operational  programmes  audited  
were  imprecise  and  not based  on reli-
able  baseline  data . Thus , the projects  
in the same  or different  RES  sectors  
could  not be compared ; nor could  the 
contribution  of the EU funds  to the EU 
and  national  RES  targets  be verified  
by the competent  authorities  (see  also  
paragraph  30).
… and  results  not  prop -
erly  measured  or projects  
not  attaining  their  energy  
generation  targets  in the  
majority  of cases
RES  data  collection  and  
reporting  can  be improved
22 
No accurate , validated  data  about  
actual  RES  project  results  is available  in 
the Member  States . The  RES  sector  was  
characterised  by enormous  volatility  in 
terms  of the costs  of the technologies  
(most  technologies  saw  massive  price  
reductions)  and  increasing  energy  
prices . It is important  to analyse  up-to-
date  information  about  RES  technol -
ogy  costs  in order  to establish  which  
technologies  render  the most  favour -
able  yields  in the specific  local  circum -
stances  and  the appropriate  levels  of 
support .
23 
However , while  data  is available  about  
the projects’  installed  generation  
capacities , no or non-reliable  data  was  
available  on the actual  generated  en-
ergy  in 11 out of 24 audited  projects . Actual  measurement  and  reporting  
not having  been  conditions  for public  
co-financing , project  final  reports  pro-
vided  only  estimated , non-measured  
results  — usually  based  on technical  
parameters  of the RES  technologies  
as supplied  by the manufacturers  and  
the specific  local  situations . Multiple  
RES  producers  did not measure  their  
energy  yields . Thus , in 11 of 24 au-
dited  projects  (five  in Poland  — solar  
projects  in the Lublin  region , four  in 
Malta  and  two  in the United  Kingdom)  
the energy  results  were  not based  
on measured /validated  data  but on 
assumed  values  taken  from  literature  
or professional  estimates  made  by 
engineers .
Project  results  not  always  
achieved
24 
Of 13 out of the 24 audited  projects , 
in which  energy  generation  results  
were  actually  measured , the targets  
were  attained  in only  5 projects , and  
almost  attained  in 3 further  projects . 
The  remaining  projects  did not reach  
or only  partly  reached  their  production  
targets . While  in several  cases  this was  
due  to insufficiently  precise  forecasts  
some  projects  had  also  encountered  
technical  problems  in their  initial  
stages . Table  1 compares  the RES 
projects’  planned  with  actual  energy  
generation .
25 
In summary , the evaluation  of 
the 24 audited  projects’  cost-effec -
tiveness , implementation  and  achieve -
ment  of objectives  has resulted  in 
a mixed  bag  of good , satisfactory  
and  poor  projects , as is laid  out in 
Annex  IV. Box  5 indicates  reasons  
for weak  performance  in some  RES 
projects .
20 Observations
Reasons  for weak  project  performance
In Austria , actual  energy  generation  was  in line  with  or above  forecasts  in those  project  stages  which  were  
directly  supported  by ERDF  funds . However , in two  projects  which  were  later  extended  by additional  heat  
capacity  and  networks  serving  additional  customers  the planned  targets  were  not achieved . The  main  causes  
were  overestimated  heat  demand  or non-consumption  of heat , temporarily , by major  customers .
The  reasons  for a lower  than  anticipated  performance  in the Polish  wind  energy  projects  were  too optimistic  
wind  forecasts  and  technical  problems  during  the first  year  of operation .
In the United  Kingdom , moreover , although  final  data  was  not available  and  the audited  grant  schemes  were  
not completed  at the time  of the audit , the results  of sub-projects  revealed  nonetheless  that  some  of them  
did not attain  their  planned  energy  generation  targets  — mainly  due  to high  water  contents  in the biomass  
materials  or lower  energy  demand  than  estimated .Box  5 Table  1Comparison  of average  planned  and  actual  energy  generation  in audited  RES  
projects  with  measured  energy  generation  results , 2009–12, in %
Source : Court’s  own  calculations  based  on ‘QM  Heizwerke’  database  (Austria) , information  about  average  investment  costs  of similar  projects  
(Finland  and  Poland) ; project  financing  agreements , information  about  project  results  calculated  by beneficiaries .PL Project 20MT Project 22
MT Project 21MT Project 24
MT Project 23
- 20 %
20 %0 %
40 %
60 %
80 %
100 %AT Projec t 1AT Projec t 2FI Project 4FI Projec t 5FI Project 7FI Projec t 8UK P rojec t 9UK Projec t 10PL P rojec t 11PL P rojec t 12PL Project 13PL P rojec t 14PL P rojec t 16PL P rojec t 17
Data not availablePL Project 19
PL P rojec t 18
PL P rojec t 15
FI Projec t 6
AT Project 3
- 60 %- 40 %
Planned resultsData not available
21 Observations
The  principle  of cost-  
effectiveness  is not  fully  
considered  in planning  
the  RES  projects
Cost-effectiveness  — an 
important  objective  in EU 
spending
26 
Cost-effectiveness  concerns  the abil -
ity or potential  of an audited  entity , 
activity , programme  or operation  to 
achieve  certain  outcomes  at a reason -
able  cost . Cost-effectiveness  analyses  
are studies  of the relationship  between  
project  cost  and  outcomes , expressed  
as cost  per unit  of outcome  achieved25.27 
Optimal  (or cost-effective)  RES  energy  
generation  is important  for economic  
performance . Cohesion  policy  funds  
constitute  a significant  part  of sup -
port  for RES  activities  and  could  
be an important  driver  of both  RES 
policy  as well  as regional  economic  
development .25 ISSAI  3000: Standards  and 
guidelines  for performance  
auditing  based  on Intosai ’s 
Auditing  Standards  and 
practical  experience .Picture  6Windmill  (outside  and  interior  views  of a wind  turbine  in Poland)
Source : European  Court  of Auditors .
22 Observations
There  is scope  for an 
emphasis  on cost-
effectiveness  at an early  
stage
28 
In connection  with  the preparation  
of the operational  programmes , the 
national  authorities  did not conduct  
proper  needs  assessments  to identify  
which  technologies  could  contribute  
to attaining  the RES  targets  in the 
most  cost-effective  way  and  how  they  
could  be complemented  by other  
financial  instruments  or national  sup -
port  schemes . As a result , the opera -
tional  programmes  did not contain  
explanations  as to how  the EU funds  
could  contribute  cost-effectively  to 
attaining  the RES  objectives .
29 
Moreover , the Commission  and  the 
national  authorities  did not plan  the 
cohesion  policy  (or national)  funds’  
contributions  in attaining  the RES 
targets . From  the audited  operational  
programmes , those  in Austria  and  in 
Finland  did not lay out the planned  
and  actual  RES energy  generated  from  
the ERDF-  and  CF-supported  measures . 
The  installed  capacity  from  RES in the 
five  audited  countries  to meet  the 
RES target  in 2020  is 95 304  MW  (see  
Table  2). The  implementation  reports  
submitted  by the managing  authori -
ties to the Commission  reveal  that , by 
2012, 4 464  MW  or 4,7 % of the required  
capacity  as per the 2020  target  (or 8,1 % 
in relation  to the 2013  trajectory  target  
in the audited  Member  States)  was  con -
tributed  through  the cohesion  policy  
projects  in these  countries .  The  cohesion  policy  funds’  use for RES 
has been  variable  among  the Mem -
ber States . As can also  be seen  from  
Table  2, for multiple  Member  States  no 
adequate  data  is available  for compar -
ing the achievement  of the cohesion  
policy  projects  in relation  to the RES 
targets . This  lack  of data  inhibits  estab -
lishing  baseline  economic  and  energy  
data  in different  RES  sectors  and  for 
different  RES  technologies .
23 Observations Table  22007–13  cohesion  policy  funds  for RES  and  their  impact  on achievement  of 
RES  2020  targets  in the Member  States
1 Allocations /output  (EUR /MW)  among  Member  States  is not comparable  due  to different  nature  of investments  (energy  generation , RES pro-
motion , networks , pilot  projects , etc.).
Source : National  renewable  energy  action  plans  (2010 ), Implementation  reports  of the operational  programmes  for 2012.OPERDF  and  CF 
funds  allocated  
to RES  (EUR)1Additional  RES  capacity  as a result  
of ERDF  and  CF investments  (MW)Required  additional  RES  capacity  to 
meet  the  RES  2020 target  (MW) ERDF /CF contribution  of total  RES  
capacity  to meet  the  RES  2020 
target  (in %) PlannedReported  
(end  2012 )by 2013 by 2020
(1) (2) (3) (4) (5) (6) (7 = 3:6)
Austria 25 037 408 105 99 11 301 13 179 0,79
Belgium 11 851 495 No data  available 3 062 8 255
Data  not reported  to the CommissionBulgaria 16 710 959 No data  available 4 232 5 189
Cyprus 9 520 000 No data  available 190 584
Czech  Republic 397 759 730 131 12 No data  available
Germany 252 995 745 29 118 71 621 110 934 0,03
Denmark No data  available 6 017 6 754
Data  not reported  to the Commission Estonia 0 6 No data  available
Spain 160 152  052 No data  available 49 722 69 844
Finland 20 682 247 No data  available 24 690 33 420 Data  not reported  to the Commission
France 363 591 135 1 161 307 1 833 445 39 628 62 167 Data  not confirmed
Greece 283 795 789 156 106 6 872 13 271 1,18
Hungary 349 310 777 0 0 1 109 1 537 Data  not reported  to the Commission
Ireland No data  available 3 496 8 339
Italy 775 717 953 5 215 2 893 32 524 43 823 11,9
Lithuania 58 485 290 0 173 1 289 1 635 Data  not reported  to the Commission
Luxembourg 1 767 056 5 000 11 000 179 347 Data  not confirmed
Latvia 67 180 000 77 21 1 661 2 168 3,55
Malta 78 200  000 No data  available 36 160 Data  not reported  to the Commission
Netherlands 19 182 600 No data  available 6 086 14 994 Data  not reported  to the Commission
Poland 825 761 396 972 246 4 444 10 335 9,4
Portugal 59 857 312 0 0 12 699 19 200 Data  not reported  to the Commission
Romania 331 542 611 200 275 9 635 12 589 1,58
Sweden 52 342 949 0 271 21 744 23 786 Data  not reported  to the Commission
Slovenia 54 186 553 355 120 1 258 1 693 21
Slovakia 90 252 216 98 72 2 144 2 746 3,57
United  Kingdom 159 590  365 12 000 4 120 14 660 38 210 31,4
Croatia No data  available Data  not reported  to the Commission
Audited  MS 1 109 271 416 13 077 4 464 55 131 95 304 13,72
In total 4 665 401 221 1 185 643 1 852 975 318 998 505 159 Data  not confirmed
24 Observations
30 
The  cost-effectiveness  of measures  in 
different  RES  sectors  was  not ex-
amined  and  did not determine  the 
budgets  earmarked  to RES  under  the 
audited  operational  programmes  while  
proper  needs  assessment  and  mid-
term  evaluations  were  lacking :
 οWhen  operational  programmes  
were  designed  in 2007  there  had  
been  a lack  of detailed  situation  
analysis  (including  needs  assess -
ment  in different  RES  sectors  in the 
regions) ; in particular , the costs  per 
unit  of energy  capacity  installed  
or the costs  of energy  generation  
per unit  had  not been  estimated  by 
national  authorities  thus  neglecting  
the cost-benefit /cost-effectiveness  
of the measures  planned  to be 
financed  through  public  means ;
 οAlso , the operational  programmes  
did not take  advantage  of the 
results  of or lessons  learnt  from  
previous  RES  programmes  financed  
by national  or EU resources ;
 οNo adequate  justification  for allo -
cating  public  funds  to RES  genera -
tion  interventions  was  provided . 
Fund  allocations  were , in general , 
based  on rough  estimation  of 
the regional  potential  and  fund  
absorption  capacities  rather  than  
systematic  analysis  of the regional  
situation  and  comparison  between  
potential  alternatives  in terms  of 
types  of RES  or RES  technologies ; οAlthough  the authorities  in Fin-
land  and  in the United  Kingdom  
inserted  some  adaptations  in their  
programmes  along  the way  with -
out formal  assessments , in general  
however  no mid-term  evaluations  
or similar  assessments  of the 
2007–13 measures  were  conducted  
which  could  have  helped  redirect  
the RES  programmes .
31 
Furthermore , the operational  pro-
grammes  failed  to establish  per-
formance  indicators  for proper  
monitoring  and  evaluation  of cost-
effectiveness  of RES  measures  which  
could  also  have  facilitated  assessing  
the contribution  of the EU funds  to 
the committed  RES  targets  (Table  2). 
While  the operational  programmes  
in Austria , Poland  and  Malta  had  
indicators  referring  to additional  RES 
capacity , the set of result  indicators  in 
Finland  did not include  indicators  for 
creation  of generation  capacity , pro-
duced  energy  or reduction /avoidance  
of CO2 emissions , and  in the United  
Kingdom  a result  indicator  in respect  
of RES  capacity  creation  was  also  lack -
ing. This  means  that , in these  cases , 
the managing  authorities  and  the 
Commission  were  not in a position  to 
conduct  adequate  monitoring  and  ex 
post  evaluation  of the cohesion  policy  
funds’  investments  in RES26.26 The annual  implementation  
reports  by Finland  and 
the United  Kingdom  did 
not provide  explanations  
about  actual  results  and 
their  measurement  and no 
assessment  of the barriers , 
the potential  and the needs  
in the different  RES sectors  
in the regions  covered  by 
the audited  OPs had been  
conducted .
25 Observations
… and  there  is also  scope  
for more  cost-effective  
RES  generation  projects
32 
Removing  inefficiencies  in the plan -
ning  and  implementation  of RES  pro-
jects  will make  a direct  contribution  
to achieving  the 2020  EU and  national  
RES  targets . But it can also  benefit  
the energy  consumers  and  boost  the 
broader  economy  as well .
33 
The  results  of the EU-supported  
projects  varied  in terms  of their  cost-
effectiveness . The  investment  costs  
of RES  technologies  range  widely  and  
are site specific . There  is no single  
most  cost-effective  RES  generation  technology  in the EU. Therefore  the 
audit  compared  only  costs  within  
a particular  RES  sector  in the same  
Member  State . Four  audited  projects  
were  significantly  more  expensive  than  
similar  projects  in the same  Mem -
ber State  (biomass  and  PV projects , 
see Table  3). The  calculated  average  
costs  for installed  capacity  varied  
from  0,16  million  EUR /MW  to 1,8  mil-
lion  EUR / MW  in the audited  projects . 
As calculated  by the national  authori -
ties in one  of the Member  States  where  
the audit  took  place , the payback  
periods  varied  from  2 to 537  years  in 
the audited  projects . Capital-intensive  
investments  with  payback  periods  of 
more  than  100  years  will not achieve  
an economically  reasonable  break-
even  point . This  indicates  that  public  
support  was  not always  allocated  to 
the most  cost-effective  projects .Picture  7Transformer  station  in a wind  park  in Golice , Poland
Source : European  Court  of Auditors .

26 Observations Table  3Cost-effectiveness  of the audited  RES  projects
Source : Court’s  own  calculations  based  on project  documentation , analyses  by the managing  authorities1.
1 Note  to FI projects : Average  machinery  and  equipment  investment  costs  of the audited  projects . Project  5 includes  piping  costs  on the site, 
Project  6 auxiliary  boiler  only . Data  not available  for projects  MT 23 and  24 (PV) , PL 16 to 20 (solar  energy)  as well  as UK 9 and  10 (biomass) .EUR/MW Millions
EUR/MW Millions
EUR/kWp ThousandsActual in vestmen tInvestment in 1MW or kWp, compared with average investment cost in the Member State
Average in MS
0 0,20 0,40 0,60 0,80 1,00 1,20
1,00 1,50 2,00 0,50 0
0 1,00 2,00 3,00 4,00 5,00Biomass Wind PVPL P rojec t 15
PL Project 14
PL Project 13PL P rojec t 12
PL P rojec t 11
MT Project 22
MT Project 21FI Projec t 8
FI Projec t 7
FI Projec t 6
FI Projec t 5
FI Project 4
AT Projec t 3
AT Project 2
AT Project 1
27 Observations
34 
Rational  energy  objectives  were  only  
partly  set for the RES  projects . The  
projects  were  in line  with  national  
strategic  RES  objectives . Fuel  supply  
concepts  existed  where  necessary  
(biomass  projects  in Austria , Finland  
and  in the United  Kingdom) . Some  pro-
jects  were  preceded  by limited  stud -
ies showing  their  economic  viability  
and  profitability  but no analyses  were  
made  concerning  the best  and  most  
cost-effective  RES  types  and  best  
technological  solutions . Evaluations  of 
previous  similar  interventions  were  not 
referred  and  thus  no ‘lessons  learnt’  
were  used  in preparing  the audited  
RES  projects .
35 
Only  about  half  of the audited  projects  
(13 of 24) had  data  through  which  the 
achievement  of the indicators  in terms  
of actually  achieved  energy  generation  
could  be verified  (Table  1 and  An-
nex  III), see also  paragraph  24. Further -
more , frequently  baseline  data  about  
the costs  of energy  production , the 
quantities  of conventional  fuels  used  
by consumers  was  not available  before  
objective-setting  and  designing  the 
projects  (e.g. operational  programme  
of the Lublin  region  in Poland) . Conse -
quently , in such  cases , it is not possible  
to assess  whether  the funded  projects  
actually  generated  the expected  
economic  or financial  results  (e.g. for 
calculating  payback  periods) .36 
The  selection  procedures  did not 
guarantee  cost-effective  projects . In 
general , the project  selection  criteria , 
approved  by the monitoring  commit -
tees  established  for each  operational  
programme , were  not enabling  the 
implementing  authorities  to identify  
the most  cost-effective  RES  projects . 
The  creation  of energy  capacity , actual  
energy  generation  and  the relevant  
necessary  investments  were  in many  
cases  not weighted  as selection  or 
award  criteria . In a few cases , no spe-
cific  selection  criteria  in relation  to RES 
generation  had  been  developed  but 
instead  selection  criteria  universally  
applicable  to multiple  sectors  covered  
by the operational  programme  were  
used27.
37 
There  has been  insufficient  competi -
tion  among  project  applications  in 
some  cases . Where  the projects  were  
identified  through  calls  for proposals  
maximum  cost-effectiveness  of ap-
plications  (payback  period , investment  
to energy  generation  ratio)  was  not 
considered . Whereas  usually  project  
applications  had  to fulfil  minimum  cri-
teria , the processes  could  not prevent  
subsidising  relatively  low quality  pro-
jects  in terms  of their  energy  genera -
tion  results . A determined  minimum  
investment  size  risked  that  applica -
tions  for smaller  projects  — possibly  
having  better  economic  parameters  — 
were  discarded .27 For instance : 
– the selection  of RES 
projects  under  the 
operational  programme  
‘Infrastructure  and 
Environment’  in Poland  was 
based  on the same  criteria  
applied  in different  sectors , 
i.e. for non-comparable  
types  of RES projects ;
– in Finland , the project  
applications  were  not 
prioritised  and only  
estimated  payback  
periods  were  used  as cost-
effectiveness  and eligibility  
criteria ; 
– in Malta , the selection  
criteria  applied  to multiple  
sectors  covered  by the 
operational  programme  
but not specifically  to 
the RES sector . Though  
one criterion  provided  
scores  in relation  to the 
projects’  ‘contribution  
towards  indicators  beyond  
minimum  required’ , the 
selection  criteria  did 
not include  any cost-
effectiveness  or cost-
benefit  criteria  for RES 
generation ;
– in Austria , a maximum  
cost-effectiveness  of 
applications  (payback  
period , investment  to 
energy  generation  ratio)  
was not considered  in 
the audited  operational  
programmes .
28 Observations
38 
On the other  hand , Austria , the United  
Kingdom  and  to some  extent  Finland  
had  technical  and  economic  criteria  
in the financing  rules  geared  towards  
preventing  wasteful  biomass  projects  
to be selected . There  was  therefore  
less  risk of selecting  non-effective  
applications . Also , project  profitability  
was  taken  into  account  whereby  more  
profitable  projects  received  less  sub -
sidies  (Box  6). Such  adaptation  of the 
level  of project  co-financing  was  not 
ensured  by the competent  authorities  
in the other  Member  States  where  the 
audit  took  place .39 
The  EU co-financing  rates  varied  be-
tween  2 % and  85 % in the operational  
programmes , without  this being  justi -
fied  in the relevant  documents . The  
co-financing  principle  holds  that  part  
of the investment  costs  of a project  is 
borne  by the final  recipient  of a public  
grant  whereby  the revenue  or profit -
ability  in the project  are to be taken  
into  account . The  purpose  of the grant  
should , furthermore , be to support  an 
action  which  could  not otherwise  take  
off due  to a financing  gap  or a lack  
of an economic  incentive . There  is an 
opportunity  cost ; high  co-financing  
rates  reduced  the size  or number  of 
other  RES  projects  which  could  have  
been  supported  through  public  funds . 
No links  were  made  between  rate  of 
support  and  profitability  or need  for 
incentivising  investors  to carry  out RES 
generation  projects . Non-justified  very  
high  co-financing  rates  (public  finan -
cial support  to an amount  higher  than  
necessary  for a project  to be economi -
cally  or financially  viable)  increased  the 
risk of deadweight  — i.e. replacing  pri-
vate  funds , but also  national  funds  — 
and  reduced  the number  of supported  
RES  generation  projects . Box  7 illus -
trates  cases  of high  co-financing .
Project  selection  — cases  in Austria , Finland  and  the United  Kingdom
In Austria , when  applying  for co-funding,  certain  technical  and  economic  criteria  have  to be met  (heat  den -
sity per running  meter  of the district  heating  pipe , district  heating  and  boiler’s  efficiency) . As a result , there  is 
much  less  risk that  non-effective  projects  are supported .
In Finland , the eligibility  criteria  and  possibility  to have  consultation  with  energy  consultant /advisor  intend  
to eliminate  non-commercially  viable  projects : the project  applicants  were  required  to provide  information  
about  the payback-period  of the applied  project , which  should  not be less  than  3 years  (commercially  profit -
able)  nor longer  than  12 years  (uneconomic) , without  the public  aid.
In the United  Kingdom , the proposed  project  costs  were  compared  with  target  costs  based  on past  similar  
biomass  projects .Box  6
29 Observations
40 
Profitability  calculations  were  not made  
for different  RES sectors  or technolo -
gies . When  planning  the programmes  
the co-financing  rates  did not distin -
guish  between  the RES sectors , size  and  
types  of investments , other  promotion / 
support  regimes  in the Member  States  
(feed-in  tariffs , premiums) , likely  profit -
ability  of the investments  and  the type  
of RES technologies  used .High  public  co-financing  — cases  in Poland  and  Malta
In Poland , the schemes  for small  PV and  solar  were  allocated  85 % from  EU funds , whereby  individual  project  
owners  (households)  could  receive  up to 100 % subsidy . Most  large  wind  farms  received  maximum  public  sup -
port  — either  close  to 70 % of total  eligible  investment  costs  or 10 million  euro  (4 of the 5 audited  projects) . 
While  the maximum  co-financing  rates  were  applied  in most  cases  they  were , however , not modulated  or 
justified  based  on cost-effectiveness  considerations  in any programming  document . Four  of five  wind  power  
project  beneficiaries  recognised  that  they  could  have  implemented  the projects  without  or with  reduced  
grants  and  intended  to use the EU grants  for early  repayment  of loans .
Malta  devoted  a large  part  of available  EU funding  for supporting  RES  installations  of public  institutions  
thereby  not sufficiently  leveraging  private  funding  sources . As a rule , the EU financed  as much  as 85 % of 
investment  costs  in those  projects . Two  large  grant  schemes , furthermore , for private  households  and  enter -
prises  financed  RES  installations  by 50 % or 60 % respectively .Box  7 Picture  8Solar  collectors  mounted  on the roof  of a family  house  in Poland
Source : European  Court  of Auditors .

30 Observations
Cohesion  policy  funds  
having  limited  EU added  
value  — the  RES  projects  
did  not  make  their  full  
contribution  to the  EU’s  
energy  objectives
41 
In only  a few cases  was  significant  EU 
added  value  demonstrated . In those  
projects  the ERDF /CF co-financing  
facilitated  the cap-funding , the co-
financing  has been  a welcome  addi -
tional  source  of investment  and  thus  
contributed  to the implementation  
of the projects . For the (larger)  wind  
farms  it was  also  regarded  as a qual -
ity stamp  for third-party  financing  
institutions . It is clear  that  in countries  
with  low RES  penetration , which  had  
few RES  programmes  and  less  admin -
istrative  experience  in this sector , the 
EU funds  have  had  more  value  added  
in that  they  have  helped  to develop  
additional  economic  development , in-
crease  the quality  of the relevant  pro-
jects  and  also , to some  extent , through  
acting  as a catalyst  and  for leveraging  
other  funds . Moreover , there  has been  
an ‘operational  value  added’  to some  
extent  as the EU projects  imposed  
certain  obligations  on the imple -
menting  bodies  through  which  some  
learning  effects  were  assured  for the 
organisations  involved . Those  effects  
were  emphasised  notably  by organisa -
tions  in Malta , Poland  and  the United  
Kingdom .42 
The  Court  also  found  that  the RES 
allocations  within  the operational  pro-
grammes  in Austria  and  Finland  were  
prone  to a risk of replacing  national  
funds . Indeed , in both  these  coun -
tries  the ERDF  merely  complemented  
existing  national /regional  funding  
mechanisms  and  in Austria  the EU sup -
port  was  virtually  integrated , without  
changing  anything  else , into  an exist -
ing subsidy  scheme  for biomass  plants . 
Austria  and  Finland  have  a long-lasting  
tradition  of RES  (especially  in the hydro  
energy  and  biomass  areas)  and  it is dif-
ficult  to assess  whether  the EU funds  
contributed  to additional  value  added , 
particularly  in regard  to innovation .
31 Observations
43 
In 2012, the Commission  stressed  that  
Member  States  and  regions  need  to 
ensure  that  funding  for RES  comple -
ments  private  investment , leverag -
ing it, and  not crowding  it out28. The  
Court  found  that  some  RES  projects  
could  have  been  implemented  with -
out public  support . It was  evident  that  
multiple  project  applicants  could  have  
set up the RES  installations  without  or 
with  smaller  public  grants  thus  freeing  
up money  for additional  RES  meas -
ures . However , the grant  decisions  
were  nonetheless  important  in view  of 
bankable  project  financing :
 οThe  Austrian  projects  in question  
were  all endorsed  after  completion  
of the construction  works  signalling  
that  the subsidy  was  not a condi -
tion  for investment .
 οFour  of the five  audited  projects  in 
Finland  could  have  been  realised  
without  subsidies  (only  one  project  
would  not have  been  implemented  
without  support  by public  funds) .
 οSeveral  wind  energy  project  own -
ers said  they  would  have  carried  
out their  projects  without  public  
subsidies  as the economic  incen -
tive  through  the wind  yields  and  
the ‘green  certificates’  had  been  
sufficient . Indeed , multiple  existing  
similar  wind  farms  had  been  con -
structed  without  being  subsidised .44 
The  RES  investments  had  only  a lim-
ited  effect  on building  managerial  
capacities . One  of the intended  effects  
of EU added  value  is improved  ad-
ministrative  or managerial  capacities  
in the Member  States . Albeit  various  
stakeholders  in Malta , Poland  and  
the United  Kingdom  claimed  there  
had  been  invaluable  learning  effects  
from  the EU projects , in general  no 
far-reaching  contributions  to improv -
ing project  planning , implementation  
and  operation  could  be demonstrated . 
The  RES  grant  schemes  and  individual  
projects  were  generally  managed  with  
a focus  on regularity  issues  without  
addressing  value  for money  require -
ments . In Austria  and  Finland , the EU 
co-financing  was  merely  made  part  
of the national  support  mechanisms  
without  particular  innovation  aspects  
(see  as well  paragraph  42). The  experi -
ence  gained  during  the implementa -
tion  of the projects  was  not dissemi -
nated  in these  two  Member  States  or 
neighbouring  regions .
45 
The  RES  projects  were  often  operat -
ing in fragile  regulatory  environments . 
Although  the EU funds  devoted  to RES 
generation  were  indeed  not aimed  
at reforming  regulatory  frameworks , 
they  could  nevertheless  have  trig-
gered  improvements  to those . The  RES 
legal  frameworks  in many  Member  
States  have  suffered  multiple  revi -
sions , including  retroactive  changes  in 
the subsidy  and  promotion  regimes . 
Permitting  procedures  are often  com -
plex  and  discouraging  or not applied  
consistently  and , together  with  market  
uncertainty  and  volatility  in energy  
prices , jeopardise  investor  confidence  
in the sector .28 COM( 2012 ) 663 final  of 
15 November  2012 ‘Making  
the internal  energy  market  
work’ .
32 Observations
46 
There  has been  variable  but overall  
low use of Cohesion  Funds  for RES 
in the Member  States . Although  the 
EU funds  allocated  to RES  increased  
from  0,6  in the 2000–06  program -
ming  period  to 4,7  billion  euro  in 
the 2007 –13 programming  period , this 
represents  only  1,7 % of total  ERDF  
and  CF spending . In relation  to the 
enormous  investment  needs  in the 
sector  for reaching  the EU 2020  RES 
target  the allocation  of EU funds  by 
the national  and  regional  authorities  
was  low29. The  Member  States  allo -
cated  between  0 % (the  lowest  value)  
and  10,7 % (the  highest  value)  of total  
ERDF  and  CF funds . Even  the 10 % al-
located  by Malta  for RES  is not signifi -
cant  to reaching  its national  RES  target  
of 10 % by 2020  when  considering  
that  the country  had  practically  no 
RES  in 2007  and  attained  less  than  2 % 
of RES  in final  energy  consumption  
by 2012  (see  Annex  I). Of the Member  
States  covered  by the audit , Malta  
had  failed  to reach  the first  mid-term  
objective  and  Austria , Finland  and  
Poland  had  not transposed  the RES 
directive  in national  legislation  by the 
end  of October  2013  (the  deadline  
was  5 December  2010 ).47 
The  uptake  of the funds  allocated  
to RES  has been  slow . By the end  
of 201230, the absorption  of the 
available  ERDF  and  CF funds  for RES 
for 2007–13  (only  58 % ) has been  
much  lower  than  the average  for 
the total  ERDF  and  CF funds  (88 % ) 
and  also  lower  than  for energy  ef-
ficiency  measures  (84 % ). Although  
the market  failures  and  barriers  are 
of a different  nature  in this sector  the 
EU co-financed  projects  in almost  all 
Member  States  have  been  managed  
by the same  managing  authorities , see 
Table  4. Relatively  high  complexity  of 
the RES  projects  and  a lack  of admin -
istrative  capacity  to manage  invest -
ment  measures  in this sector , clearly , 
had  an impact  on the lower  ERDF  and  
CF disbursement  rates . Thus , overall , 
the Cohesion  Funds  were  of a modest  
significance  for achieving  the EU RES 
target .29 SEC( 2011 ) 131 final  of 
31 January  2011.  
30 The amounts  allocated  by 
the managing  authorities  to 
selected  projects . The last 
available  data  is from  the end  
of 2012.Table  4Absorption  of cohesion  policy  funds  for RES  projects  in the audited  Member  States  
(‘selected  projects’  as at end  of 2012 )
Source : DG Regional  Policy  database  SFC 20 07.EU Member  StateTotal  cohesion  policy  funds  
selected  projects  (%)Cohesion  policy  funds  selected  
Energy  Efficiency  projects  (%)Cohesion  policy  funds  selected  
RES  projects  (%)
Austria 75,6 2 87, 3 50,6
Finland 90,8 34,5 30,6
Malta 88,1 37,9 43,3
Poland 85,4 112,2 5 7, 8
United  Kingdom 84,7 73,6 49,9
Average  all Member  States 87,7 84,5 58,0
33
 Conclusions  and  
recommendations
48 
Overall , the Court  concludes  that  value  
for money  of cohesion  policy  funds  
support  to RES  generation  projects  has 
been  limited  in helping  achieve  the EU 
RES  2020  target .
49 
The  audited  projects  delivered  out-
puts  as planned : Most  of the audited  
RES  projects  were  sufficiently  mature  
and  ready  for implementation  when  
selected , there  have  been  no ma-
jor cost  overruns  and  time  delays  in 
the projects  and  the RES  generation  
capacities , generally , were  installed  as 
planned  (paragraphs  14 to 16).
50 
However , the Court  found  also  that  
there  were  weaknesses  in imple -
mentation : In particular  concerning  
performance  indicators , measuring  
and  reporting  of project  results  as 
well  as procurement  procedures  and  
outcomes . In general , difficulties  of 
integrating  RES  electricity  into  the 
grids  have  been  identified  as a major  
impediment  to the development  of 
RES  in the EU (paragraphs  17 to 21).
51 
Moreover , the energy  generation  tar-
gets  were  not achieved  or the results  
not properly  measured  in around  two  
thirds  of the audited  RES  projects . 
In most  of these  cases , insufficient  
or non-measured  data  about  actual  
generated  energy  was  available . The  
non-achievement  of planned  results  
was  mostly  due  to imprecise  forecasts  
or technical  problems . Overall , the 
project  outcomes  have  been  mixed  
(paragraphs  22 to 25).52 
Furthermore , cost-effectiveness  has 
not been  the guiding  principle  in plan -
ning  the projects . The  underlying  op-
erational  programmes  were  designed  
without  prioritisation  of the RES  sec-
tors  and  without  assessments  of the 
funds’  contributions  to the RES  objec -
tives . Fund  allocations  were , in gen -
eral , based  on rough  estimation  of the 
regional  potential  and  fund  absorption  
capacities  rather  than  systematic  ana- 
 lysis  of the regional  situation  and  com -
parison  between  potential  alternatives  
in terms  of types  of RES  or RES  tech -
nologies . The  cost-effectiveness  of the 
measures  was  neglected  when  they  
were  allocated  the budgets . Rational  
energy  objectives  and  performance  
indicators  for energy  generation  had  
not been  set well  in all projects . The  
selection  criteria  and  procedures  were  
frequently  not conducive  to selecting  
the most  cost-effective  RES  projects . 
Project  results  were  mixed  in regard  
to cost-effectiveness  whereby  in some  
Member  States  the high  co-financing  
rates  were  not justified  in the docu -
ments  in relation  to the projects’  prof -
itability  (paragraphs  26 to 40).
53 
The  audit  also  found  that  the cohesion  
policy  funds  for RES  had  a limited  EU 
added  value . There  has been  a risk of 
public  funding  replacement  in those  
Member  States  which  simply  used  the 
EU funds  to complement  their  national  
grants  for RES  as well  as a risk of dead -
weight . While  the EU co-financing  had  
some  ‘operational  value  added’  the in-
vestment  projects  have  not, however , 
helped  build  up managerial  capacities  
in a significant  way . Overall  the use of 
ERDF  and  CF for RES  has been  modest  
in relation  to the need  for increased  
efforts  to reach  the EU objectives  
(paragraphs  41 to 47).
34 Conclusions and recommendations
54 
The  Court  emphasises  the need  for 
improvements  if cohesion  policy  fund -
ing is to make  the maximum  possible  
contribution  to achieving  the energy  
targets31. Furthermore , cohesion  
policy  spending , in general , brings  
benefits  to the broader  economy , 
including  economic  growth  and  job 
creation  which  are overarching  aims  
of cohesion  policy . In view  of a likely  
enhanced  use of EU funds  for promot -
ing RES  in the 2014 –20 programming  
period , the Court  makes  the following  
recommendations :
Recommendation  1
The  Commission , through  guidance  
setting  for programme  and  project  
preparation  and  selection  as well  as 
through  conditions  for making  funding  
available  for RES  generation  invest -
ments , should :
ο  ensure  that  future  cohesion  policy  
co-funded  RES  programmes  are 
guided  by the principle  of cost-
effectiveness , including  EU fund -
ing support  to cost-effective  
programmes  that  would  not 
otherwise  take  place , so as to avoid  
deadweight . Programmes  must  
be based  on proper  needs  assess -
ment , prioritisation  of the most  
cost-effective  technologies  (while  
not discriminating  between  RES 
sectors)  and  optimal  contribution  
to the EU 2020  target . Adequate  
RES  generation  objectives  in rela -
tion  to the budget  as well  as pro-
ject  selection  criteria  with  a focus  
on the cost-effectiveness  of the 
energy  generation  results  (avoid -
ing over-compensation  of projects)  
need  to be set;ο  promote  the establishment  by the 
Member  States  of a stable  and  pre-
dictable  regulatory  framework  for 
RES  in general , along  with  smooth -
er procedures  for the integration  
of electricity  from  RES  into  the grid  
networks .
Recommendation  2
The  Member  States  should  establish  
and  apply , based  on Commission  
guidance , minimum  cost-effectiveness  
criteria  which  are adapted  to the pro-
jects’  circumstances . They  should  also  
enhance  the added  value  of cohesion  
policy  funds  by improving  RES  project  
implementation  as well  as monitor -
ing and  evaluation  and  by building  
a stock  of measured  data  about  energy  
generation  costs  in all relevant  RES 
sectors .31 Within  this policy  area , the 
Court  published  a report  
on the energy  efficiency  
measures  co-financed  by 
the ERDF  and the CF (Special  
Report  No 21/2012 ‘Cost-
effectiveness  of Cohesion  
Policy  Investments  in Energy  
Efficiency’  (https ://eca.europa .
eu)). The audit  analysed  the 
cost-effectiveness  of cohesion  
policy  investments  in energy  
efficiency , with  a specific  
focus  on the Commission’s  
management  role in relation  
to its approval  of operational  
programmes  and the 
monitoring  of programme  
execution  in the regions .
35 Conclusions and recommendations
This  Report  was  adopted  by Chamber  II, headed  by Mr Henri  GRETHEN , Member  
of the Court  of Auditors , in Luxembourg  at its meeting  of 9 April  2014.
For the Court  of Auditors
Vítor  Manuel  da SILVA  CALDEIRA
President

36
 Annexes
Overview  of Member  States’  progress  towards  the 2020 RES  targetAnnex  I
Achievement  of 2020 RES target  according  to information  provided  by the Commission : 
1  Source : Eurostat , 10 March  2014. Actual  share  of energy  from  renewable  sources  (in % of gross  final  energy  consumption)  in 2012 (which  also  
provides  data  for 2010 ). 
2  Source : Renewable  energy  progress  report  (Report  from  the Commission  to the European  Parliament , the Council , the European  Economic  
and  Social  Committee  and  the Committee  of the Regions , (COM( 2013 ) 175 final , 27.3.2013. First  interim  target , calculated  as the average  of 
2011/2012 shares .
3 Source : see footnote  1 above .
4 Source : Directive  2009/28/ EC.Member  State 2010 RES  share1 1st interim  target22012 RES  share32020 RES  target4
Belgium 5,0  % 4,4 % 6,8 % 13 %
Bulgaria 14,4  % 10,7  % 16,3 % 16 %
Czech  Republic 9,3 % 7, 5 % 11,2  % 13 %
Denmark 22,6  % 19,6  % 26,0  % 30 %
Germany 10,7  % 8,2 % 12,4  % 18 %
Estonia 24,7  % 19,4  % 25,2  % 25 %
Ireland 5,6 % 5,7 % 7, 2 % 16 %
Greece 9,7 % 9,1 % 15,1  % 18 %
Spain 13,8  % 10,9  % 14,3 % 20 %
France 12,7  % 12,8  % 13,4  % 23 %
Italy 10,6  % 7, 6 % 13,5  % 17 %
Cyprus 6,0 % 4,9 % 6,8 % 13 %
Latvia 32,5  % 34,0  % 35,8  % 40 %
Lithuania 19,8  % 16,6  % 21,7  % 23 %
Luxembourg 2,9 % 2,9 % 3,1 % 11 %
Hungary 8,6 % 6,0 % 9,6 % 13 %
Malta 0,4 % 2,0 % 1,4 % 10 %
Netherlands 3,7 % 4,7 % 4,5 % 14 %
Austria 30,8  % 25,4  % 32,1  % 34 %
Poland 9,3 % 8,8 % 11,0  % 15 %
Portugal 24,2  % 22,6  % 24,6  % 31 %
Romania 23,2  % 19,0  % 22,9  % 24 %
Slovenia 19,2  % 17, 8  % 20,2  % 25 %
Slovakia 9,0 % 8,2 % 10,4  % 14 %
Finland 32,4  % 30,4  % 34,3 % 38 %
Sweden 47, 2  % 41,6  % 51,0  % 49 %
United  Kingdom 3,3 % 4,0 % 4,2 % 15 %
EU 12,5  % 10,7  % 14,1  % 20 %
37 Annexes
Cohesion  policy  (ERDF  and  CF 2007–13 ) funds  allocation  to RES  and  selected  
projects  2007–12Annex  II
1  Rate  of selection  above  100 % means  funds  were  reallocated  from  other  priorities  or measures  within  the same  or from  another  Operational  
Programme . 
Source : DG Regional  Policy  database  SFC2007, 2012 Annual  Implementation  Reports  for selected  projects . Member  StateEU allocated  decided  amount Projects  selected
ERDF  and  CF total  
amount  (euro)
(A)Allocated  to RES  
amount  (euro)
(B)% of total  funds  for 
RES
(C)Total  projects  
selected  
EU Amount  (euro)
(D)% of selected  
projects
(D)/(B)1
Belgium 990  283  172 11 851 495 1,2 % 7 242 095 61,1  %
Bulgaria 5 488 168 381 16 710 959 0,3 % 4 226 413 25,3 %
Czech  Republic 22 751 854 293 397 759 730 1,7 % 131 059  678 32,9  %
Denmark 254 788 620
Germany 16 107 313 706 252 995 745 1,6 % 119 319  102 47, 2  %
Estonia 3 011 942 552
Ireland 375 362  372
Greece 15 846 461 042 283 795  789 1,8 % 392 484 152 138,3 %
Spain 26 595 884 632 160 152  052 0,6 % 71 145 156 44,4  %
France 8 054 673 061 363 591 135 4,5 % 245 249  934 67, 5  %
Croatia 705 861 911
Italy 21 025 331 585 775 717 953 3,7 % 397 058 482 51,2  %
Cyprus 492 665  838 9 520 000 1,9 % 5 191 095 54,5  %
Latvia 3 947 343 917 67 180 000 1,7 %
Lithuania 5 747 186 096 58 485 290 1,0 % 67 554  207 115,5  %
Luxembourg 25 243 666 1 767 056 7, 0 % 4 875 000 275,9  %
Hungary 21 292 060 049 349 310 777 1,6 % 179 983 308 51,5  %
Malta 728 123  051 78 200  000 10,7  % 33 879 548 43,3 %
Netherlands 830 000  000 19 182 600 2,3 % 22 345 138 116,5  %
Austria 680 066  021 25 037 408 3,7 % 12 676 799 50,6  %
Poland 57 178 151 307 825 761 396 1,4 % 477 355  029 5 7, 8  %
Portugal 14 558 172 647 59 857 312 0,4 % 5 006 939 8,4 %
Romania 15 528 889 094 331 542 611 2,1 % 209 940 000 63,3 %
Slovenia 3 345 349 266 54 186 553 1,6 % 14 408 713 26,6  %
Slovakia 9 998 728 328 90 252 216 0,9 % 66 524 170 73,7  %
Finland 977 401 980 20 682  247 2,1 % 6 329 763 30,6  %
Sweden 934 540 730 52 342 949 5,6 % 8 772 042 16,8  %
United  Kingdom 5 392 019 735 159 590  365 3,0 % 74 770 872 46,9  %
Cross-border 7 893 300 818 199 927 583 2,5 % 148 745 005 74,4  %
EU27 + cross-border 270  757  167  870 4 665 401 221 1,7 % 2 706 142 640 58,0  %
38 Annexes
List  of audited  RES  generation  projectsAnnex  III
Project  
NoMem -
ber 
StateOperational  
programmeInterventionImplementation  
modeProject  budget
(million  euro)Of which  co-financingAdditional  
RES  capac -
ity installed  
(planned /
actual)  MW  
or kWp /aInvest -
ments  in 
audited  
projects
(million  
EUR /MW  or 
EUR /kWp /a)Average  en-
ergy  generated  
(planned /
actual)
MWh /aNational  
(million  euro)ERDF /CF (million  
euro)
1
ATLower  AustriaConstruction  of biomass  plant  in 
Weissenbach  an der TristingStand-alone  
project0,745 0,117 0,117 3/3 MW 0,5172 440/  
2 319 MWh /a
2 StyriaConstruction  of biomass  plant  
and  a district  heating  network  in 
Bruck  an der MurStand-alone  
project5,658 0,871 0,882 8/8 MW 0,48818 659/ 
12 263 MWh /a
3 SalzburgConstruction  of biomass  plant  
and  a district  heating  network  
in FlachauStand-alone  
project5,667 0,886 0,885 6/4 MW 1,02724 009/ 
23 026 MWh /a
4
FILänsi-SuomenConstruction  of biomass-pellet  
boiler  replacing  three  fossil  fuel  
boilers  and  main  pipeline  in 
Lievestuore  Stand-alone  
project0,405 0,017 0,011 1/1 MW 0,2524 136/ 
5 215 MWh /a
5 Länsi-SuomenConstruction  of biomass-wood  
chip  boiler  replacing  fossil  fuel  
boiler  and  modification  of exist -
ing district  heatingnetwork  in 
Kyyjärvi  industrial  site Stand-alone  
project0,711 0,085 0,056 1/1 MW 0,4152 500/ 
2 394 MWh /a
6 Länsi-SuomenConstruction  of a new  biomass-
pellet  boiler  replacing  fossil  fuel  
boiler  at Tikkakoski  site Stand-alone  
project0,388 0,022 0,009 2,5/2,5 MW 0,1274 000/ 
7 500 MWh /a
7 Länsi-SuomenConstruction  of a new  biomass-
pellet  boiler  replacing  fossil  fuel  
boiler  and  necessary  district  
heating  network  in a converted  
storage  facility  in Kiukainen . Stand-alone  
project0,324 0,029 0,02 1/1 MW 0,2702 800/ 
4 000 MWh /a
8 Länsi-SuomenConstruction  of a new  biomass-
pellet  boiler  replacing  fossil  fuel  
boiler  in Eura  Stand-alone  
project0,447 0,054 0,036 0,8/0,8 MW 0,31 140/ 
1 500 MWh /a
9
UKEast  Wales  
(Competitiveness)  Wood  Energy  Business  Scheme  2 
(80085 )Grant  scheme 0,2 0 0,076 MW /Not 
providedNA2 700 MWh / 
Not yet available
10West  Wales  
and  the Valleys  
(Convergence)Wood  Energy  Business  Scheme  2 
(80028 )Financing  scheme 1,2 0 0,492,6 MW /Not 
providedNA5300 MWh / 
Not yet available
39 Annexes Annex  III
Project  
NoMem -
ber 
StateOperational  
programmeInterventionImplementation  
modeProject  budget
(million  euro)Of which  co-financingAdditional  
RES  capac -
ity installed  
(planned /
actual)  MW  
or kWp /aInvest -
ments  in 
audited  
projects
(million  
EUR /MW  or 
EUR /kWp /a)Average  en-
ergy  generated  
(planned /
actual)
MWh /aNational  
(million  euro)ERDF /CF (million  
euro)
11
PLInfrastructure  
and  EnvironmentConstruction  of wind  farm  East  
Margonin  district  IIStand-alone  
project29,209 11,81 5,906 20/20 MW 1,46046 735/ 
47 288 MWh /a
12Infrastructure  
and  EnvironmentConstruction  of three  wind  
turbines  in Stypolow , Kozuchow  
municipalityStand-alone  
project7, 5 8 4 1,85 4,315 4,5/4,5 MW 1,68514 153/ 
10 074 MWh /a
13Infrastructure  
and  EnvironmentConstruction  of wind  farm  
Jarogniew-MołtowoStand-alone  
project30,179 15,35 10,0 20/20 MW 1,56259 211/ 
47 825 MWh /a
14Infrastructure  
and  EnvironmentConstruction  of wind  farm  in 
Golice  areaStand-alone  
project55,75 35,41 10,0 38/38 MW 1,46780 332/ 
57 393 MWh /a
15Infrastructure  
and  EnvironmentConstruction  of four  wind  
power  stations  in the Pluznica  
CommuneStand-alone  
project5,914 1,51 3,365 3,2/3,2 MW 1,8488 286/ 
7 381 MWh /a
16 LubelskieInstallation  of solar  collectors  on 
public  and  residential  buildings  
in Kłoczew  CommuneStand-alone  
project1,659 0,24 1,412,82/2,82 
MW0,5281 502 MWh /a 
/ Not provided
17 LubelskieInstallation  of solar  collectors  on 
public  and  residential  buildings  
in Kraśnik  Commune  Stand-alone  
project1,096 0,14 0,9311,55/1,55 
MW0,588972 MWh /a/ 
Not provided
18 LubelskieInstallation  of solar  collectors  on 
public  and  residential  buildings  
in Potok  Górny  Commune  Stand-alone  
project1,866 0,27 1,533,46/3,61 
MW0,4151 974 MWh /a/ 
Not provided
19 LubelskieInstallation  of solar  collectors  on 
public  and  residential  buildings  
in Ruda-Huta  CommuneStand-alone  
project1,188 0,17 1,0101,89/1,89 
MW0,519990 MWh /a/ 
Not provided
20 LubelskieInstallation  of solar  collectors , PV 
and  street  lighting  in Goraj  and  
Turobin  CommunesStand-alone  
project1,371 0,2 1,1650,12/0,12 
MWNANot defined / 
Not provided
40 Annexes Annex  III
Project  
NoMem -
ber 
StateOperational  
programmeInterventionImplementation  
modeProject  budget
(million  euro)Of which  co-financingAdditional  
RES  capac -
ity installed  
(planned /
actual)  MW  
or kWp /aInvest -
ments  in 
audited  
projects
(million  
EUR /MW  or 
EUR /kWp /a)Average  en-
ergy  generated  
(planned /
actual)
MWh /aNational  
(million  euro)ERDF /CF (million  
euro)
21
MTInvesting  in 
Competitiveness  
for a Better  Qual -
ity of LifeInstallation  of Renewable  Energy  
Sources  at Malta  College  of Arts , 
Science  and  TechnologyStand-alone  
project0,464 0,07 0,395134/134 KW 
p/a3 464 235/213 MWh /a1
22Investing  in 
Competitiveness  
for a Better  Qual -
ity of LifeEnergy-Smart  Authority  (Hous -
ing Authority)Stand-alone  
project0,041 0,006 0,0353,48/3,51 
KW p/a3 9495,23/ 5,28 
MWh /a1
23Investing  in 
Competitiveness  
for a Better  Qual -
ity of LifePromotion  of RES in the Domestic  
SectorGrant  scheme 16,932 2,76 14,392 9 216 KW p/a NA9 015/13 824 
MWh /a1
24Investing  in 
Competitiveness  
for a Better  Qual -
ity of LifeERDF  Energy  Grant  Scheme  for 
EnterprisesGrant  scheme 18,404 2,76 15,643 6 023 KW p/a NA5 000 MWh /a/ 
Not provided
1 Note : Actual  results  are not based  on measured  data .
41 Annexes
Summary  evaluation  of RES  project  resultsAnnex  IV
N.B. For reasons  of comparability , in this annex  some  projects  are divided  in sub-projects  so that  the total  is 27.
Number  of evaluated  projects /sub-projects
Poor Satisfactory GoodNot applicable / 
data  not 
availableProject  implementationInstallations  functioning  without  significant  problems  (project  perfor -
mance  is good , if instaliation  is functioning  without  unplanned  outage  
periods ; satisfactory  if outage  periods  have  limited  impact  on energy  
production ; poor  if outage  periods  have  significant  impact  on energy  
production)0 2 25 0
Installed  energy  capacity  (project  performance  is good  if planned  energy  
capacity  installed ; satisfactory , in case  of non-significant  devia -
tions  from  plan  and poor  if energy  capacity  not installed /significant  
deviations)0 0 27 0
Total  production  capacity  in use in line with  planning  (project  perfor -
mance  is good  if energy  capacity  in use according  to plan , satisfactory , 
in case  of non-significant  deviations  from  plan  and poor  if energy  capac -
ity not used /significant  deviations  from  plan)2 6 19 0
Technical  Plan  (TP)  in compliance
(project  performance  is poor  if there  are significant  deviations  from  TP; 
satisfactory  if some  deviations  with  no real impact  on results  and good  
if there  are no deviations)0 1 26 0
Budget  in compliance  (project  performance  is good  if there  are no devia -
tions  in price , satisfactory  if increase  of 0 % <x<  20 %, poor  if increase  
of > 20 %)1 0 26 0
Operational  Plan  (OP)  in compliance  (project  performance  is good  if 
there  are no deviations  from  OP, satisfactory  if few deviations  with  no 
real impact  on results  and poor  if significant  deviations)2 6 19 0
Risk  management , project  complexity , implementation  barriers  (project  
performance  is good  if action  taken  where  risks  identified , satisfactory  
if risks  partly  analysed  and mitigated , poor  if no proper  risk analysis  
conducted)0 10 17 0
Transparent , relevant  and measurable  performance  indicators  and selec -
tion  of the best  prepared /mature  applications  (project  performance  is 
good  if adequate  indicators  used  to select  best  prepared  and mature  ap-
plications , cost-effectiveness  of applications  evaluated  and if competition  
among  applications  ensured ; satisfactory  if these  criteria  only  partly  
applied ; poor  - if not applied)0 27 0 0
Licensing /permits /public  acceptance  (mature , ready  project) . Project  
performance  is good  if facility  is in operation , no problems  related  to 
obtaining  of necessary  permits  were  identified ; satisfactory  if only  
critical  licenses  obtained , poor  if serious  problems  identified  in licensing /
permits /public  acceptance0 2 25 0
42 Annexes Annex  IV
Number  of evaluated  projects /sub-projects
Poor Satisfactory GoodNot applicable / 
data  not 
availableCost  - effectivenessOperational  efficiency . Project  performance  is good  if operational  ef-
ficiency  is > 95 %; satisfactory  if 80< x < 95 %; poor  if < 80 %4 7 7 7 9
Investment  (construction)  costs  (EUR /MW  or EUR /KWp) . Project  perfor -
mance  is good  if investment  costs  are higher  than  average  < 10 % or 
less; satisfactory  if higher  than  average  10 %<x<  30 %; poor  if higher  
than  average  > 30 %4 1 17 5
Cost-effectiveness  criteria  used  in project  selection . Project  performance  
is good  if most  cost-effective  projects  selected :
- best  cost /energy  capacity  installed  ratio(EUR /MW)
- best  cost /energy  generation  ratio  (EUR /MWh) ; 
satisfactory  - if cost-effectiveness  criteria  used  partly ; poor  - if not used12 10 5 5 0
Project  financing  based  on open  call and selection  procedure , competi -
tion  between  applications . Project  performance  is good  if open  call and 
selection  procedure  used ; 
satisfactory  - if used , but low number  of proposals  received ; poor  - if 
not used8 14 5 5 0
Appropriate  studies  available . Project  performance  is good  if feasibility /
business  or other  studies  used  for planning ; satisfactory  - if not always  
followed ; poor  - if not used6 10 10 10 1
Ownership  (owners’ /stakeholders’  commitment  to implement  project) . 
Project  performance  is good  if there  was  solid  ownership  with  adequate  
knowledge  and assets  committed  to the project  from  project  develop -
ment  phase  through  operation  of the facility ; satisfactory  - if stable  
with  some  vulnerability  of the assets  or knowledge ; poor  - if unstable , 
no adequate  knowledge  and assets  committed  to project  planning  and 
implementation .0 10 17 0
Coherence  with  RES strategic  framework . Project  performance  is good  
if project  objectives  were  relevant  and coherent  with  RES strategic  frame -
work ; satisfactory  - if some  components  of projects  not directly  linked  
with  RES objectives ; poor  - if objectives  were  not relevant  or coherent  
with  RES strategic  framework .0 0 27 0
Number  of evaluated  projects /sub-projects
Achievement of objectives Poor Satisfactory GoodNot  
applicable /
data  not 
available
Energy  generated . Project  performance  is good  if energy  generated  is > 
95 % of planned ; satisfactory  if 85< x < 95 %; poor  if < 85 %6 2 6 13
43
The  Commission  therefore  considers  that  efficiency  
and  effectiveness  should  not only  be measured  in 
megawatts  of RES  per euro  invested , but also  in 
terms  of the overall  success  of the programme  and  
the projects  in attaining  desired  results .
The  Commission  considers  that  the cost-effective -
ness  concept  can be defined  in several  ways : very  
short-term  cost reduction , or medium-  to long-term  
dynamic  efficiency  cost reduction  through  innova -
tion  for the overall  transformation  of the energy  
system  in tune  with  2020 targets  and  preparing  the 
ground  for beyond .
IV — Second  bullet
The  Commission  considers  that  the cohesion  policy  
investments  in RES  have  been  made  in line  with  
the objectives  and  requirements  of the applicable  
legislative  framework . Its views  on the European  
added  value  in cohesion  policy  were  set out in the 
June  2011 Commission  Staff  Working  Document  
‘The  added  value  of the EU budget ’2. The  bulk  of 
investment  in RES  should  be made  by the private  
sector . Member  States  and  regions  need  to ensure  
that  public  funding  does  not replace , but comple -
ments  and  leverages  private  investment  in accord -
ance  with  state  aid rules . Cohesion  policy  funding  
should  be used  to complement  existing  national  
support  schemes  to ensure  added  value . The  Com -
mission  considers  that  a variety  of factors  need  to 
be taken  into  account  in the analysis  of added  value  
of EU funds  in this area .
1 Article  30 of Regulation  (EU, Euratom)  No 966/2012 of the 
European  Parliament  and  of the Council  of 25 October  2012 on the 
financial  rules  applicable  to the general  budget  of the Union  and  
repealing  Council  Regulation  (EC, Euratom)  No 1605/2002.
2 SEC( 2011 ) 867 final  of 29.6. 2011, Commission  Staff  Working  
Paper  ‘The added  value  of the EU budget ’, accompanying  the 
Commission  Communication  ‘A budget  for Europe  2020 ’.Executive  summary
III
The  Commission  welcomes  the finding  that  all the 
audited  RES  generation  projects  delivered  outputs  
as planned . In view  of the increased  cohesion  policy  
investments  that  can be foreseen  in sustainable  
energy , including  renewable  energy , over  2014–20, 
the report  from  the Court  is very  timely , and , gener -
ally, the report’s  drive  to make  optimal  use of the 
funding  is welcome .
IV
Until  the installation  is fully  operational , the actual  
performance  of the system  is not known . The  actual  
level  of energy  generation  varies  from  year  to year  
depending  on several  parameters  (including  e.g. 
weather  conditions , reliability  of the appliance  and  
building  occupancy) . Actual  data  are reported  once  
the project  is fully  operational .
IV — First  bullet
Cost-effectiveness  considerations  may  be defined  
in the selection  criteria  of the specific  interven -
tions . However , cohesion  policy  serves  a broader  
purpose  and  all operational  programmes  financed  
by cohesion  policy  have  to comply  with  the policy’s  
objectives  to strengthen  economic , social  and  ter-
ritorial  cohesion  and  promote  overall  harmonious  
development  by reducing  disparities  between  the 
levels  of development  of regions  and  promoting  
development  in least  favoured  regions . Cohesion  
policy  is an integrated  and  place-based  policy , and  
an increased  share  of RES  is one  of multiple  objec -
tives  of its programmes , meaning  that  projects  may  
simultaneously  aim  at more  objectives  than  just 
RES  generation . The  Commission  acknowledges  the 
principles  of efficiency  and  effectiveness  as defined  
in the EU’s  Financial  Regulation1. The  regulation  
states  that  the principle  of efficiency  concerns  the 
best  relationship  between  resources  employed  and  
results  achieved  and  the principle  of effectiveness  
concerns  the attainment  of the specific  objectives  
set and  the achievement  of the intended  results .Reply  
of the Commission
Reply of the Commission 44
Where  there  is evidence  resulting  from  a perfor -
mance  review  that  a priority  has failed  to achieve  
the milestones  relating  only  to the financial  and  
output  indicators  and  key implementation  steps  
set out and  that  the Member  State  has not taken  
the necessary  steps  to rectify  the problem , the 
Commission  may  suspend  all or part  of an interim  
payment  or apply  ultimately  financial  corrections . 
The  performance  reserve  should  not be allocated  to 
such  programme .
Under  the 2014–20 legal  framework , the Commis -
sion  strengthens  as well  the ex ante  conditionalities  
for the funds  so as to ensure  that  the necessary  
conditions  for their  effective  implementation  are in 
place . 
In addition , the Commission  through  its active  
and  continuous  work  with  the Member  States  will 
advise  managing  authorities  to include  the recom -
mendations  of the European  Court  of Auditors  into  
the selection  process  and  selection  criteria  of RES 
projects . Contribution  to the expected  results  of the 
priority  axis  is now  required  to be included  in the 
selection  criteria .
The  Commission  partly  accepts  this recommenda -
tion . The  Commission  agrees  on the importance  of 
avoiding  deadweight . To support  a more  market-
based  approach  in the 2014–20 period , the Com -
mission  encourages , as foreseen  in Regulation  
(EU)  No 1303/2013, the use of financial  instruments  
instead  of grants  to support  investments  which  are 
expected  to be financially  viable  but do not give  
rise to sufficient  funding  from  market  sources . 
The  Commission  also  agrees  that  programmes  must  
be based  on proper  needs  assessments . For that  
purpose , Regulation  (EU)  No 1303/2013 provides  
that  the Partnership  Agreement  for 2014–20 shall  
set out an analysis  of disparities , development  
needs  and  growth  potential . Choices  made  in each  
operational  programme  shall  be justified  accord -
ingly . Requirements  stemming  from  the renewable  
energy  directive  (e.g. strategic  approach , needs  
assessment  and  national  renewable  energy  action  
plans)  will also  ensure  optimal  planning  of cohesion  
policy  RES  investments . V
The  Commission  has constantly  underlined  to 
Member  States  the point  on weaknesses  of national  
administrative  systems . 
The  reform  of cohesion  policy  for 2014–20 will 
provide  the monitoring  committee  of respective  
operational  programmes  with  the necessary  incen -
tives  to approve  selection  criteria , thereby  ensuring  
maximum  impact  for this type  of investment . Mem -
ber States  and  regions  will have  to decide  upfront  
what  objectives  they  intend  to achieve  with  the 
available  resources  and  identify  precisely  how  they  
will measure  progress  towards  those  goals  for each  
priority  axis . This  will allow  regular  monitoring  and  
debate  on how  financial  resources  are used .
For the programming  period  2014–20, requirements  
have  been  introduced  for a stronger  intervention  
logic  for all priorities , including  a number  of com -
mon  output  indicators , whose  use is obligatory  
where  relevant . In the area  of RES , both  the ERDF  
and  the CF regulations  for 2014–20 include  a com -
mon  indicator  on ‘Additional  capacity  of renewable  
energy  production ’.
As regards  the observations  related  to cost-effec -
tiveness  aspects , the Commission  refers  to its reply  
to paragraph  IV.
VIII — Recommendation  1
Under  the framework  for cohesion , the Commission  
is not involved  in the selection  of projects , except  
for the approval  of major  projects .
The  new  regulatory  framework  for 2014–20 never -
theless  ensures  from  the start  that , through  the con -
tent  of the adopted  programmes  and  the interven -
tion  logic  including  objectives’  result  indicators  and  
outputs  encapsulated  in priority  axes , the selection  
of projects  will be done  by Member  States  as far as 
possible  according  to the Court’s  recommendation . 
Also , based  on the performance  framework  estab -
lished  for each  operational  programme , the Com -
mission  will be in position  through  milestones  relat -
ing only  to the indicators  to encourage  and  review  
the performance  of programmes . 
Reply of the Commission 45
VIII — Recommendation  2
The  Commission  accepts  this recommendation  and  
considers  it for its part , implemented . The  Commis -
sion’s  November  2013 guidance  for the design  of 
renewables  support  schemes  should  be taken  into  
consideration  by Member  States . The  forthcoming  
energy  and  environmental  aid guidelines  will also  
contribute  to increasing  the cost-effectiveness  of 
Member  States  support  schemes  for renewable  
energy .
Introduction
07
The  Commission  notes  that  the responsibility  for 
removing  sector-specific  obstacles  that  hamper  
investments  in RES  lies with  the Member  States .
The  Commission  has addressed  these  obstacles  in 
its regular  reports  making  recommendations  to 
Member  States . Support  schemes  were  not always  
well  designed , leading  either  to unfavourable  
conditions  or overcompensation . The  Commission’s  
guidance  for the design  of renewables  support  
schemes , issued  in November  2013, as well  as the 
guidance  on the use of renewable  energy  coop -
eration  mechanisms  underline  the principles  that  
should  be followed  to address  this situation4. 
4 C(2013 ) 7243 final  of 5.11. 2013, Commission  communication  
‘Delivering  the internal  electricity  market  and  making  the most  of 
public  intervention ’ and  accompanying  Commission  staff  working  
papers  SWD( 2013 ) 439 final  ‘European  Commission  guidance  for the 
design  of renewables  support  schemes ’ and  SWD( 2013 ) 440 final  
‘Guidance  on the use of renewable  energy  cooperation  mechanisms ’.Nevertheless , cohesion  policy  is an integrated  and  
place-based  policy , and  an increased  share  of RES 
is only  one  of its multiple  objectives . In particu -
lar other  cohesion  policy  objectives , such  as the 
promotion  of innovation  may  justify  the choice  of 
technologies  which  are not the most  cost-effective . 
Regulation  (EU)  No 1303/2013 provides  that  selec -
tion  procedures  and  criteria  need  to ensure  the 
contribution  of operations  to the achievement  of 
the specific  objectives  and  results  of the relevant  
priority  of the operational  programme , which  may  
aim  at more  objectives  than  RES  generation . 
As regards  major  projects , in the 2014–20 pro-
gramming  period  the Commission  will continue  to 
require  carrying  out a cost-benefit  analysis , includ -
ing an economic  and  a financial  analysis . As part  of 
cost-benefit  analysis , an option  analysis  is required , 
which , among  other  aspects , takes  into  account  
economic  and  financial  considerations , such  as con -
struction  costs , in order  to choose  the best  option , 
while  trying  to maximise  the project’s  benefits  for 
society .
The  Commission  accepts  the recommendation  in 
the second  indent . It has consistently  reminded  
Member  States  of the need  to ensure  stability  in the 
regulatory  framework  and  has also  constantly  criti -
cised  frequent  and  retroactive  modifications  in the 
Member  States’  regulatory  frameworks . The  Novem -
ber 2013 Commission  communication  on ‘Delivering  
the internal  electricity  market  and  making  the most  
of public  intervention ’ and  the Commission’s  guid -
ance  for the design  of renewables  support  schemes  
as well  as the guidance  on the use of renewable  
energy  cooperation  mechanisms  address  these  
issues3. 
3 C(2013 ) 7243 final  of 5.11. 2013, Commission  communication  
‘Delivering  the internal  electricity  market  and  making  the most  of 
public  intervention ’ and  accompanying  Commission  staff  working  
papers  SWD( 2013 ) 439 final  ‘European  Commission  guidance  for the 
design  of renewables  support  schemes ’ and  SWD( 2013 ) 440 final  
‘Guidance  on the use of renewable  energy  cooperation  mechanisms ’. 
Reply of the Commission 46
Observations
17
While  the Commission  acknowledges  that  difficul -
ties with  RES  electricity  integration  into  the grid  
have  hampered  exploitation  of RES , this is not 
directly  dependent  on project  management . The  
requirement  to improve  RES  electricity  access  to 
grids  is a legal  requirement  under  the renewable  
energy  directive .
18
The  Commission  indeed  considers  that  progress  by 
the Member  States  in removing  the administrative  
barriers  in this area  is slow .
As to the reference  to the United  Kingdom , the 
Commission  considers  that  the formulation  should  
take  into  account  the constitutional  arrangements  
and  devolution  process  prevailing  in this Mem -
ber State . The  various  operational  programme  
documents  and  programme  monitoring  commit -
tees  within  the United  Kingdom  are stand-alone  
and  independent , and  harmonisation  is achieved  
through  the use of cross-cutting  themes  embedded  
into  all programmes  in the country .
20 — First  indent
The  contracting  authority  recognised  these  
issues  and  it was  precisely  to ensure  transpar -
ency  and  more  competition  that  the tenders  were  
relaunched . 
20 — Second  indent
With  regard  to the wind  projects  in Poland , there  
were  no obstacles  (if as a result  of the award  proce -
dure  the offer  of another  supplier  would  have  been  
selected)  for the beneficiary  to apply  for a change  
to building  permits  issued  and  specify  another  
model  of turbines .
With  regard  to the solar  collector  project  in Poland , 
the scope  of the tender  was  described  properly  and  
in accordance  with  the applicable  legislation . In the description  of the tender , it was  determined  
that  the proceeding  concerned  the given  solar  col-
lector  type  or another  type  with  the same  parame -
ters . The  project  in question  was  also  subject  to two  
controls  carried  out by national  authorities  which  
did not question  the compliance  of the project  with  
the public  procurement  law.
21
For the programming  period  2014–20, requirements  
have  been  introduced  for a stronger  intervention  
logic  for all priorities , including  a number  of com -
mon  output  indicators , whose  use is obligatory  
where  relevant . In the area  of renewables , both  the 
ERDF  and  the CF Regulations  for 2014–20 include  
a common  indicator  on ‘Additional  capacity  of 
renewable  energy  production ’. However , evaluation  
will always  be required  to disentangle  the contri -
bution  of the operations  co-financed  by the cohe -
sion  policy  funds  to changes  in renewable  energy  
production  and  consumption  patterns  from  the 
influence  of other  external  factors .
23
Until  the installation  is complete  and  fully  opera -
tional , the actual  performance  of the system  is not 
known . The  actual  level  of energy  generation  varies  
from  year  to year  depending  on several  parameters  
(including  e.g. weather  conditions , reliability  of the 
appliance  and  building  occupancy) . Actual  data  are 
reported  once  the project  is fully  operational .
24
As regards  the wind  projects  in Poland , of which  
4 out of 5 did not attain  the targets  according  to 
Table  1, the Commission  considers  that  the results  
should  be assessed  during  the full operational  
period  of a wind  farm , which  was  not the case  for 
one  of the projects . Better  territorial  planning  of 
RES  investments  is advisable , taking  into  account  
the specific  conditions  for the RES  type  concerned  
in the particular  location . The  fact  that  RES  projects  
sometimes  do not reach  or only  partly  reach  their  
planned  production  targets  confirms  the high  risk 
profile  of such  investments  and  thus , the need  for 
public  funding  in order  to get bankable  projects  
and  thus  leverage  private  funding .
Reply of the Commission 47
Box  5 — Second  paragraph
The  Commission  has suggested  to the Polish  
authorities  and  the ‘Joint  Assistance  to Support  
Projects  in European  Regions  (JASPERS) ’ partner -
ship  to assess  results  and  the financial  rate  of return  
(FRR)  of the wind  farm  projects  on the basis  of more  
realistic  estimates . The  result  indicators  would  then  
better  reflect  the working  time  of wind  farms .
Box  5 — Third  paragraph
In the United  Kingdom , two  of the five  sites  audited  
have  delivered  lower  outputs  than  expected  due  
to lower  demand  on the systems  than  forecast . The  
data  collection  exercise  planned  by the manag -
ing authority  for the end  of the operations  intends  
to collect  site-specific  data  which  should  provide  
further  clarity  on why  demand  was  lower  than  
envisaged .
26
The  Commission  acknowledges  the principles  of 
efficiency  and  effectiveness  as defined  in the EU’s  
Financial  Regulation . The  regulation  states  that  the 
principle  of efficiency  concerns  the best  relation -
ship  between  resources  employed  and  results  
achieved  and  the principle  of effectiveness  con -
cerns  the attainment  of the specific  objectives  set 
and  the achievement  of the intended  results . The  
Commission  therefore  considers  that  efficiency  
and  effectiveness  should  not only  be measured  in 
megawatts  of RES  per euro  invested , but also  in 
terms  of the overall  success  of the programme  and  
the projects  in attaining  desired  results .
27
Cost-effectiveness  considerations  may  be defined  
in the selection  criteria  of the specific  interventions . 
However , cohesion  policy  serves  a broader  purpose  
and  all operational  programmes  financed  by cohe -
sion  policy  have  to comply  with  the policy’s  objec -
tives  to strengthen  economic , social  and  territorial  
cohesion  and  promote  overall  harmonious  develop -
ment  by reducing  disparities  between  the levels  of 
development  of regions  and  promoting  develop -
ment  in least  favoured  regions . Cohesion  policy  is an integrated  and  place-based  
policy , and  an increased  share  of RES  is one  of mul -
tiple  objectives  of its programmes , meaning  that  
projects  may  simultaneously  aim  at more  objec -
tives  than  just  RES  generation . Moreover , as regards  
investments  in RES  specifically , the Commission  
considers  that  the cost-effectiveness  concept  
can be defined  in several  ways : very  short-term  
cost-reduction , or medium  to long-term  dynamic  
efficiency  cost-reduction  through  innovation  for 
the overall  transformation  of our energy  system  in 
tune  with  2020 targets  and  preparing  the ground  
for beyond .
28
While  Regulation  1083/2006 did not require  ‘needs  
assessments ’, the Commisison  agrees  that  a needs  
assessment  can be useful . As a general  require -
ment  for all operational  programmes  funded  under  
cohesion  policy  in the 2007–13 period , programmes  
contain  ‘an analysis  of the situation  of the eligible  
area  or sector  in terms  of strengths  and  weaknesses  
and  the strategy  chosen  in response ’. 
In 2014–20, the priority  axes  will select  one  or more  
investment  priorities  according  to the specific  
needs  and  context  of the Member  States . The  spe-
cific  objectives  and  the corresponding  result  indica -
tors  will then  express  what  each  priority  axis  aims  
to achieve  — related  to the analysis  of the situation  
and  the policy  needs  identified .
29
In the 2007–13 period , relative  shares  allocated  to 
RES  investments  differed  between  Member  States , 
to be seen  in the light  of total  volume  of funds  
available , national  needs  and  priorities  set by each  
Member  State . The  cohesion  policy  operational  pro-
grammes  for 2007–13 were  planned  and  adopted  
before  the adoption  of the 2020 climate  and  energy  
targets  and  the respective  EU legislation . Considera -
tion  of contribution  towards  2020 RES  targets  was  
subsequently  taken  into  account , if and  when  Mem -
ber States  notified  revisions  in their  operational  
programmes . 
Reply of the Commission 48
36
As for the specific  projects , Member  States  them -
selves  are in charge  of the selection . As regards  
considerations  in relation  to cost-effectiveness  and  
the broader  objectives  of cohesion  policy , the Com -
mission  refers  to its replies  to paragraphs  26 and  27.
37
The  Commission  refers  to its replies  to para -
graphs  26 and  27.
39
The  Commission  agrees  on the importance  of avoid -
ing deadweight . As regards  the co-financing  rates , 
the provisions  are set out in Article  53 of Regulation  
(EC)  No 1083/2006. This  does  not mean  in itself  that  
part  of the investment  costs  of a project  is borne  
by the final  recipient  of a public  subsidy . There  
are also  provisions  as regards  revenue-generating  
projects  in Article  55 of the same  regulation . In 
order  to comply  with  the binding  RES  targets , 
Member  States  need  to encourage  investments  
in RES  projects , which  may  not be bankable  on 
their  own , considering  a higher  risk profile  of such  
investments . Co-financing  rates  of RES  state  aid 
projects  are established  by state  aid decisions , in 
which  case  the funding  gap  methodology  does  not 
apply . Nevertheless , calculation  of the funding  gap  
is still encouraged  as it helps  to set the amount  (or 
intensity)  of aid and  limit  the state  aid below  the 
maximum  level , as appropriate .
To support  a more  market-based  approach  in the 
2014–20 period , the Commission  encourages  and   
Regulation  (EU)  No 1303/2013 provides  for the use 
of financial  instruments  instead  of grants  to be 
implemented  to support  investments  which  are 
expected  to be financially  viable , but do not give  
rise to sufficient  funding  from  market  sources . 
Support  via financial  instruments  shall  be based  on 
a detailed  ex ante  assessment  in accordance  with  
Article  37(2) of the above  regulation  which  has, inter  
alia, established  evidence  of market  failures  or sub -
optimal  investment  situations , and  the estimated  
level  and  scope  of public  investment  needs , includ -
ing types  of financial  instruments  to be supported .However , it is important  to note  that  the bulk  of 
investment  in this area  should  be made  by the 
private  sector . Member  States  and  regions  need  to 
ensure  that  public  funding  does  not replace  but 
complements  and  leverages  private  investment  in 
accordance  with  state  aid rules . Cohesion  policy  
funding  should  be used  to complement  existing  
national  support  schemes  to ensure  added  value . 
30
Since  the adoption  of the renewable  energy  direc -
tive  in 2009 and  the legal  requirement  to adopt  
national  renewable  energy  action  plans  (NREAPs) , 
Member  States  were  in fact  required  to conduct  
proper  needs  assessment  for RES  investments , and  
NREAPs  were  based  on such  needs  analysis . They  
also  constitute  a serious  and  well-reflected  basis  
for RES-related  investments  in Member  States . In 
addition , the fact  that  such  plans  were  adopted  in 
a transparent  manner  and  made  publicly  available  
did contribute  to better  planning  and  transparency , 
allowing  for the first  time  all actors , including  inves -
tors  and  neighbouring  Member  States , to coordi -
nate  such  investments  and  thus  to increased  added  
value  and  cost-effectiveness . Nevertheless , all 2007–
13 cohesion  policy  operational  programmes  had  
been  negotiated  and  approved  before  the NREAPs  
were  due  (June  2010 ).
30 — Fourth  indent
A mid-term  evaluation  of operational  programmes  
was  not compulsory  unless  specific  circumstances  
warranted  it, according  to Article  48 of Regulation  
(EC)  No 1083/2006. 
Nonetheless , all projects  in Wales  are, from  2014, 
subject  to evaluation . In the course  of 2014, the 
Welsh  Managing  Authority  will commission  a syn-
thesis  of all operation  evaluations  to draw  out pro-
gramme  level  findings , including  those  of energy  
operations .
32
The  Commission  agrees  with  the general  statement  
but notes  that  no major  inefficiencies  in the plan -
ning  and  implementation  of the audited  projects  
have  been  identified .
Reply of the Commission 49
Conclusions  and  recommendations
Common  reply  to paragraphs  48 
and  52
The  reform  of cohesion  policy  for 2014–20 will 
provide  the monitoring  committee  of respective  
operational  programmes  with  the necessary  incen -
tives  to approve  selection  criteria  ensuring  maxi -
mum  impact  for this type  of investments . Member  
States  and  regions  will have  to decide  upfront  what  
objectives  they  intend  to achieve  with  the available  
resources  and  identify  precisely  how  they  will meas -
ure progress  towards  those  goals  for each  priority  
axis . This  will allow  regular  monitoring  and  debate  
on how  financial  resources  are used .
For the 2014–20 period , Regulation  (EU)  
No 1303/2013 provides  that  selection  procedures  
and  criteria  need  to ensure  the contribution  of 
operations  to the achievement  of the specific  
objectives  and  results  of the relevant  priority  of the 
operational  programme , which  may  aim  at more  
objectives  than  RES  generation . As regards  major  
projects , the Commission  requires  Member  States /
Managing  Authorities  to carry  out a cost-benefit  
analysis , including  an economic  and  a financial  
analysis , for each  major  project , in order  to dem -
onstrate  that  the project  is desirable  from  an 
economic  point  of view  (i.e. society  is better  off 
with  the project)  and  that  the contribution  of the 
cohesion  policy  funds  is needed  for the project  to 
be financially  viable  and , in some  cases , bankable , 
taking  into  account  its risk profile . As part  of the 
cost-benefit  analysis , an option  analysis  is required , 
which , among  other  aspects , takes  into  account  
economic  and  financial  considerations , such  as 
keeping  construction  costs  as low as possible , in 
order  to choose  the best  option , while  trying  to 
maximise  the project’s  benefits  for society . 
The  Commission  also  refers  to its replies  to para -
graphs  25 to 26, 28 to 32, 36 to 37 and  39.Box  7
The  wind  farm  projects  in Poland  received  between  
22 % and  70 % of total  eligible  investment  costs , up 
to a maximum  of 10 million  euro . It can be noted  
that  the EU co-financing  level  of wind  farm  major  
projects , i.e. projects  under  Commission  assess -
ment , is 22–25 %.
42
As regards  national  public  funding  mechanisms , 
indeed  cohesion  policy  funding  was  required  to 
complement  these  in accordance  with  Article  9 of 
Regulation  (EC)  No 1083/2006. The  ERDF  comple -
menting  existing  funding  mechanisms  have  a finan -
cial added  value  in that  more  could  be done  than  
would  be the case  in the absence  of the cohesion  
policy  funds . For added  value , the nature  of the 
policy  does  not need  to be changed .
44
The  Commission  points  out that  the EU added  value  
in improving  administrative  capacities  is one  which  
takes  time . RES  investments  are a relatively  new  
area  for cohesion  policy  and  it will take  some  time  
for such  learning  effects  to take  place .
45
The  Commission  refers  to its reply  to paragraph  7.
46
The  Commission  refers  to its reply  to paragraph  29.
Reply of the Commission 50
 — Contribution  of support  to development  of 
renewable  energy  markets  in the MS and  in the 
EU;
 — Contribution  of EU funds  for reaching  the RES 
targets  in a cost-  and  energy-efficient  way  while  
promoting  innovation  and  technology  develop -
ment  (objectives  of EU integrated  energy  and  
climate  change  policy) . 
The  Commission  also  refers  to its replies  to para -
graphs  42, 46 and  47.
Recommendation  1
Under  the framework  for cohesion , the Commission  
is not involved  in the selection  of projects , except  
for the approval  of major  projects .
The  new  regulatory  framework  for 2014–20 never -
theless  ensures  from  the start  that , through  the con -
tent  of the adopted  programmes  and  the interven -
tion  logic  including  objectives’  result  indicators  and  
outputs  encapsulated  in priority  axes , the selection  
of projects  will be done  by Member  States  as far as 
possible  according  to the Court’s  recommendation . 
Also , based  on the performance  framework  estab -
lished  for each  operational  programme , the Com -
mission  will be in position  through  milestones  relat -
ing only  to the indicators  to encourage  and  review  
the performance  of programmes . Where  there  
is evidence  resulting  from  a performance  review  
that  a priority  has failed  to achieve  the milestones  
relating  only  to the financial  and  output  indicators  
and  key implementation  steps  set out and  that  the 
Member  State  has not taken  the necessary  steps  to 
rectify  the problem , the Commission  may  suspend  
all or part  of an interim  payment  or apply  ultimately  
financial  corrections . The  performance  reserve  
should  not be allocated  to such  programme .50
The  Commission  has constantly  underlined  to 
Member  States  the point  on weaknesses  of national  
administrative  systems . This  is also  a legal  require -
ment  addressed  by Article  13 of the renewable  
energy  directive . This  is monitored  and  analysed  
in the Commission’s  biennial  renewable  energy  
progress  reports . 
The  Commission  also  refers  to its replies  to para -
graphs  17 to 21.
51
The  Commission  refers  to its replies  to para -
graphs  23 to 25.
53
The  Commission  considers  that  the cohesion  policy  
investments  in RES  have  been  made  in line  with  
the objectives  and  requirements  of the applicable  
legislative  framework . Its views  on the European  
added  value  in cohesion  policy  were  set out in the 
June  2011 Commission  Staff  Working  Document  
‘The  added  value  of the EU budget ’. The  Commis -
sion  considers  that  the following  factors  would  
need  to be taken  into  account  in the analysis  of 
added  value  of EU funds  in this area :
 — Contribution  of supported  technologies  and  
projects  to reaching  the EU RES  objectives , 
including  promotion  of technological  devel -
opment  and  innovation , and  contribution  to 
providing  opportunities  for employment  and  
regional  development , especially  in rural  and  
isolated  areas ;
 — Contribution  of supported  projects  for reaching  
of RES  targets  and  progress  of implementa -
tion  of national  renewable  energy  action  plans  
(including  by taking  into  account  contribu -
tion  to promotion  of RES  in different  sectors  
(RES-Electricity , RES-Heating  and  Cooling  and  
RES-Transport) ;
Reply of the Commission 51
Nevertheless , cohesion  policy  is an integrated  and  
place-based  policy , and  an increased  share  of RES 
is only  one  of its multiple  objectives . In particu -
lar other  cohesion  policy  objectives , such  as the 
promotion  of innovation  may  justify  the choice  of 
technologies  which  are not the most  cost-effective . 
Regulation  (EU)  No 1303/2013 provides  that  selec -
tion  procedures  and  criteria  need  to ensure  the 
contribution  of operations  to the achievement  of 
the specific  objectives  and  results  of the relevant  
priority  of the operational  programme , which  may  
aim  at more  objectives  than  RES  generation . 
As regards  major  projects , in the 2014–20 pro-
gramming  period  the Commission  will continue  to 
require  carrying  out a cost-benefit  analysis , includ -
ing an economic  and  a financial  analysis . As part  of 
cost-benefit  analysis , an option  analysis  is required , 
which , among  other  aspects , takes  into  account  
economic  and  financial  considerations , such  as con -
struction  costs , in order  to choose  the best  option , 
while  trying  to maximise  the project’s  benefits  for 
society . 
Recommendation  1 — Second  bullet
The  Commission  accepts  this recommendation . It 
has consistently  reminded  Member  States  of the 
need  to ensure  stability  in the regulatory  frame -
work  and  has also  constantly  criticised  frequent  and  
retroactive  modifications  in the Member  States’  
regulatory  frameworks . The  November  2013 Com -
mission  communication  on ‘Delivering  the internal  
electricity  market  and  making  the most  of public  
intervention ’ and  the Commission’s  guidance  for 
the design  of renewables  support  schemes  as well  
as the guidance  on the use of renewable  energy  
cooperation  mechanisms  address  these  issues5. 
5 C(2013 ) 7243 final  of 5.11. 2013, Commission  communication  
‘Delivering  the internal  electricity  market  and  making  the most  of 
public  intervention ’ and  accompanying  Commission  staff  working  
papers  SWD( 2013 ) 439 final  ‘European  Commission  guidance  for the 
design  of renewables  support  schemes ’ and  SWD( 2013 ) 440 final  
‘Guidance  on the use of renewable  energy  cooperation  mechanisms ’.Under  the 2014–20 legal  framework , the Commis -
sion  strengthens  as well  the ex ante  conditionalities  
for the funds  so as to ensure  that  the necessary  
conditions  for their  effective  implementation  are in 
place . 
In addition , the Commission  through  its active  
and  continuous  work  with  the Member  States  will 
advise  managing  authorities  to include  the recom -
mendations  of the European  Court  of Auditors  into  
the selection  process  and  selection  criteria  of RES 
projects . Contribution  to the expected  results  of the 
priority  axis  is now  required  to be included  in the 
selection  criteria .
Recommendation  1 — First  bullet
The  Commission  partly  accepts  this recommenda -
tion . The  Commission  agrees  on the importance  of 
avoiding  deadweight . To support  a more  market-
based  approach  in the 2014–20 period , the Com -
mission  encourages , as foreseen  in Regulation  
(EU)  No 1303/2013, the use of financial  instruments  
instead  of grants  to support  investments  which  
are expected  to be financially  viable  but do not 
give  rise to sufficient  funding  from  market  sources . 
Support  via financial  instruments  shall  be based  on 
a detailed  ex ante  assessment  in accordance  with  
Article  37(2) of the above  regulation  which  has, inter  
alia, established  evidence  of market  failures  or sub -
optimal  investment  situations , and  the estimated  
level  and  scope  of public  investment  needs , includ -
ing types  of financial  instruments  to be supported . 
The  Commission  also  agrees  that  programmes  must  
be based  on proper  needs  assessments . For that  
purpose , Regulation  (EU)  No 1303/2013 provides  
that  the Partnership  Agreement  for 2014–20 shall  
set out an analysis  of disparities , development  
needs  and  growth  potential . Choices  made  in each  
operational  programme  shall  be justified  accord -
ingly . Requirements  stemming  from  the renewable  
energy  directive  (e.g. strategic  approach , needs  
assessment  and  national  renewable  energy  action  
plans)  will also  ensure  optimal  planning  of cohesion  
policy  RES  investments . 
Reply of the Commission 52
Recommendation  2
The  Commission  accepts  this recommendation  and  
considers  it for its part , implemented . The  Commis -
sion’s  November  2013 guidance  for the design  of 
renewables  support  schemes  should  be taken  into  
consideration  by Member  States . The  forthcoming  
Energy  and  Environmental  Aid guidelines  will also  
contribute  to increasing  the cost-effectiveness  of 
Member  States  support  schemes  for renewable  
energy .
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QJ-AB- 14-006 -EN-C  ISSN  1831 -0834
The  ECA  assessed  the results  of renewable  
energy  generation  projects  co-financed  by 
cohesion  policy  funds  contributing  to the 
relevant  EU 2020 target . It concludes  that , while  
they  delivered  outputs  as planned , multiple  
investment  projects  were  not guided  by the 
principle  of cost-effectiveness  or lacked  a real  EU 
added  value . The  ECA  recommends  that  the 
Commission  promotes  the principle  of 
cost-effectiveness  in EU co-financed  support  
programmes  and  that  the Member  States  
establish  a stable  and  predictable  renewable  
energy  regulatory  framework . Moreover , the 
Member  States  should  apply  minimum  
cost-effectiveness  criteria , applied  to projects’  
circumstances , and  enhance  EU added  value  
through  improved  project  implementation , 
monitoring  and  evaluation .
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