Opinion of the Committee of the Regions on Promotion of renewable energy
Date: 2008-10-08
Institutions: European Committee of the Regions
Subjects: EU financing, EU programme, energy policy, pollution control measures, renewable energy

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Opinion of the Committee of the Regions on ‘Promotion of renewable energy’

(2008/C 325/03)

THE COMMITTEE OF THE REGIONS

— wishes to ensure support schemes are accessible to renewable producers at all scales, including small
installations and believes that, for consistency, support for renewable energy should be accompanied
by the phasing out of subsidies for the production and use of fossil fuels (with the exception of
possible support for cogeneration plans used to provide district heating) and for the production and
use of nuclear energy. An exception shall also be granted to cases where carbon capture and storage is
applied to reduce the carbon dioxide quantities emitted by fossil fuel use;

— recommends ensuring maximum coordination between the principal European legislative acts in these
areas, specifically the Directive on the energy performance of buildings, the Directive on energy effi-
ciency and energy services, the third package liberalising energy and the various components of the
‘energy-climate’ package, including the Directive on renewable energy;

— urges the Commission to amend Article 4 to require the involvement of Local and Regional Authori-
ties in the formulation of national action plans, and to take this factor duly into consideration when
evaluating the national action plans;

— points out that setting a 10 % target for increased use of biofuels in transport will have the intended,
positive outcome only if biofuels are produced from commodities obtained in a way that does not
distort the natural balance of the environment, food supply or the economic balance of the market,
or social balance.

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Rapporteur: Paula BAKER (UK/ALDE), Member of Basingstoke and Deane Borough Council

Reference document

Proposal for a Directive of the European Parliament and of the Council on the promotion of the use of
energy from renewable sources

COM(2008) 19 final

I. POLICY RECOMMENDATIONS

THE COMMITTEE OF THE REGIONS

General

1.
welcomes the Renewable Energy Directive, because it
believes that renewable energy generation can reduce green-
increase the security of energy supply,
house gas emissions,
promote technology development, increase employment oppor-
tunities and contribute to regional development;

emphasises that,

2.
if the goals of the directive are to be
achieved, it is imperative that a strategic alliance of regional and
local authorities be established to ensure the bottom-up devel-
opment of renewable energy;

urges a legislative framework that provides long term
3.
stability for investment decisions so that innovative renewable
projects, using the wide range of technologies now available,
can become competitive against conventional technologies;

welcomes the adoption of binding objectives for renew-
4.
able energy. However, it points out that in order to ensure that
the final objectives are effectively pursued without delay and
achieved, the intermediary objectives as identified in Part B of
Annex 1 to the draft directive must also be binding; and calls
for local and regional authorities to be involved in discussions
with Member States in the preparation of national Action Plans
to ensure that there is adequate oversight of the intermediary
objectives and that the implementing instruments to be adopted
are defined at local level;

fully supports the Commission proposal

5.
that Member
States develop electricity grid infrastructure to accommodate
electricity produced from renewable sources and to give it
priority access to the grid, but stresses access must be at a fair
and competitive price, whether this is achieved by Feed-In-Tariff
or otherwise;

similarly stresses the importance of grid infrastructure for
6.
gas, and heating from renewable sources and residual heat and
to give these types of energy reasonable access to their relevant
grid infrastructures;

believes that grid suppliers should make, and bear the
7.
costs of, reasonable adjustments to give access to renewable
energy sources, these costs should not be spread across all
energy consumers;

policies must be dealt with separately, they are necessary, of the
utmost importance and relevant as regards meeting the objec-
tives of the renewable energy directive. The Committee recom-
mends that the provisions on this subject included in the draft
Directive on renewable energy be duly taken into consideration
the Directive on the
during the forthcoming adjustment of
it recommends
energy performance of buildings. Generally,
ensuring maximum coordination between the
principal
European legislative acts in these areas, specifically the Directive
on the energy performance of buildings, the Directive on energy
the third package liberalising
efficiency and energy services,
energy and the various components of
the ‘energy-climate’
package, including the Directive on renewable energy. Particu-
larly in view of achieving binding national targets, attention
must focus on national
the Directive on
Renewable Energy;

implementation of

Role of Local and Regional Authorities

9.
considers that Local and Regional Authorities have experi-
ence and established competence to influence energy infrastruc-
ture and policies within their regions. Many European regions
are already demonstrating a political commitment to promoting
renewable energy in their regions; they have set concrete goals
in this sphere and are pursuing them actively. They already
influence energy infrastructure and policies by their actions in
spatial planning, regional development, influencing the actions
of individual citizens, and in many cases have fostered innova-
tive applications of renewable energy (solar, ground source,
biomass, hydroelectric power and wind) in relation to buildings
and transport and other areas;

10.
notes that the shift from non-renewable to renewable
energy sources implies an increase in relatively small scale, local,
energy production, which will also reduce long distance electri-
city transmission losses and will involve and impact upon the
activities of all Local and Regional Authorities;

11.
recognises that activities undertaken by local and regional
authorities through which they may help achieve the goals of
the directive include:

— spatial planning (through clear planning and development

specifications as both a regulator and enabler);

— their ownership and management of public land and prop-
erty (including street lighting, housing, transport, as well as
public buildings and offices and captive fleets);

Supports the European Commission's initiative of urging
8.
national,
to apply policies
promoting low energy and passive buildings. Although these

regional and local authorities

— provision of sustainable transport services and establishment
of alternative means of transport (such as hire of electric
cars and bicycles);

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— provision of heating and cooling networks for private
housing or large public buildings (swimming pools, schools,
town or regional halls, etc.);

the formulation of national action plans, and to take this factor
duly into consideration when evaluating the national action
plans;

— regional development;

— measures to assist renewable energy companies including

grants and access to finance;

— provision of grants and facilitating access to finance to make
renewable energy accessible to individual households, public
organisations and companies;

— communication with the citizen;

19.
recalling the experience of the national energy efficiency
action plans (NEEAPs), it calls on the Commission to publish, in
good time, guidelines for preparing NAPs, including a model.
The involvement of local and regional authorities in drafting the
NAPs will be clearly identified as a major part of the process of
preparing NAPs in any model, guide or other form of recom-
mendation published by the European Commission on the
subject of NAPs;

— provision of

information and training (to citizens,

builders, equipment
support schemes);

installers and repairers,

to
to SMEs on

— promoting energy research, development and technological
innovation, especially as far as energy saving, efficiency and
renewable energy are concerned;

12.
urges the Commission to resist pressure to require
Member States to set up centralised, single, administrative
bodies dealing with applications and assistance for new renew-
able installations;

cautions against ‘surplus energy’ standards being applied

13.
retrospectively to public buildings;

14.
In the light of the experience with NEEAPs, also calls on
the Commission to allocate the necessary resources (including
human resources) and to take the requisite steps (including legal
action and financial sanctions) to ensure that the Member States
for Renewables
submit high-quality National Action Plans
(NAPR) by the set deadlines, thus enabling the directive's objec-
tives to be met;

points out that, additionally, Local and Regional Authori-
15.
ties control
large budgets for public purchasing and procure-
ment of energy consuming products and services; stresses that
in the formative phases of a shift to a much more dominant
renewable energy Europe,
the significant role of Local and
Regional Authorities in specifying, innovating and negotiating
with the renewable energy sectors should be strengthened;

16.
recognises that activities by Local and Regional Authori-
ties to reduce the total demand for energy, by actions to
improve energy efficiency, make an important contribution to
achieving the aims of the Renewable Energy Directive;

National Action Plans

believes that, many of

17.
the actions (see for example
Article 12) which will be included in the NAP will fall to Local
and Regional Authorities to implement, Local and Regional
Authorities have already undertaken significant action, and this
experience should be utilised fully in the production, implemen-
tation and monitoring of NAPs;

Support Measures

20.
urges the Commission to take steps to encourage take up
of existing support schemes for renewable energy such as Struc-
the Intelligent Energy for
tural Funds, access to EIB loans,
Europe scheme under
the Competitiveness and Innovation
Framework Programme (CIP), the various schemes and initia-
tives under the 7th Framework programme for Research, and
the Commission's plans set down in its Communication on the
Strategic Energy Technology Plan COM (2007) 723 final;

21.
wishes to ensure support schemes are accessible to
renewable producers at all scales, including small installations
and believes that, for consistency, support for renewable energy
should be accompanied by the phasing out of subsidies for the
production and use of fossil fuels (with the exception of possible
support for cogeneration plans used to provide district heating).
and for the production and use of nuclear energy. An exception
shall also be granted to cases where carbon capture and storage
is applied to reduce the carbon dioxide quantities emitted by
fossil fuel use;

sufficient

is made available

wishes the Commission to recognise the contribution of,
22.
and ensure that
to
support
encourage research and development to harness clean, renew-
able maritime energies such as from wind, waves, tide and
that national and regional aid
ocean currents. Points out
programmes, which offer solutions tailored to national, regional
and local situations, have shown that
they are capable of
successfully promoting renewable energy. Therefore, although
additional support from the European level continues to be
desirable, national and regional aid programmes must remain
the principal tools for promoting this form of energy. Any
European-level standardisation of the terms and conditions of
aid programmes is to be avoided;

Guarantees of Origin

23.
notes that the Commission proposal for EU wide Guar-
antees of Origin to validate electricity, heating and cooling from
renewable sources conforms to the Committee of the Regions
Opinion on Limiting global climate change (1) which called for a
green energy certificate to be introduced;

18.
therefore urges the Commission to amend Article 4 to
require the involvement of Local and Regional Authorities in

(1) CdR 110/2007 fin.

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24.
believes that the use of Guarantees of Origin also for
trading and accounting is overcomplicated and suggests the
Commission reconsiders and clarifies it, with a view to better
guaranteeing the transparency and legal certainty of the system.
It also suggests that at the same time, the Commission ensures
that the system for trading in and marketing Guarantees of
Origin does not jeopardise the implementation and efficiency of
national or regional aid programmes, as well as considering a
separate certificate for voluntary trading;

25.
considers that the contribution made by microgeneration
must be taken into account in order that this element of each
Member States' overall energy package is properly recognised
and supported;

Information and Training

26.
notes that energy generation, distribution and use is
changing rapidly and believes the rate of change will increase in
coming years; therefore there must be widespread dissemination
installers and
of information and training so that producers,
consumers of energy have appropriate understanding of new
technologies allowing changes to take place efficiently and equi-
tably;

27.
supports the Commission proposal that Member States
ensure that appropriate information, guidance and accreditation
schemes are established;

28.
stresses that Local and Regional Authorities have an
important role in education and training, and are increasingly
consulted by their citizens to improve the quality of information
which is currently on offer; they will also be directly involved in
implementing guidance on planning controls and standards for
new buildings, therefore urges that Local and Regional Authori-
ties are fully involved in the development and implementation
information, awareness, guidance, education and training
of
schemes;

Biofuels

notes that Local and Regional Authorities have promoted
29.
biofuel use by, for example, collecting used cooking oils to
produce bio-diesel for municipal vehicles, and the generation of
biogas from sewage and other bio wastes also for use in muni-
cipal vehicles and the generation of wood pellet supplies,
primarily for heat but also in conjunction with CHP schemes,
from locally managed woodlands, and waste wood. Initiatives in
various European regions to establish ‘biofuel networks’ must
also be supported. These networks coordinate the production
level. Provided that
and consumption of biofuels at regional
biofuels are sustainably produced,
taking into account all
economic, environmental and social aspects, such networks can
contribute to the development of regional economies;

Believes that the 10 % target for renewable energy in
is best met by increased use of electric vehicles

30.
transport
powered by renewably generated electricity;

that

biofuels

produced

31. maintains
from wastes,
by-products and residues have two climate change benefits as
they reduce transport emissions and they remove materials from
the waste stream, and thus represent good management of
limited resources, of which biomass is an example. Nor do
biofuels produced in this way compete with food production;

points out that increased use of biofuels in transport will
32.
have the intended, positive outcome only if biofuels are
produced from commodities obtained in a way that does not
distort the natural balance of the environment, food supply or
the economic balance of the market, or social balance;

33.
notes that emissions of air pollutants that are damaging
to human health, from biofuel use in transport vary depending
on the source. Biofuels therefore have the potential to contribute
to an improvement or a deterioration in air quality, which local
government has a key role in managing;

34.
urges, therefore, that comprehensive research is under-
taken on the tail-pipe emissions of different biofuels and that air
quality impacts are considered alongside sustainability assess-
ment, in a holistic manner;

35.
recommends that NAPs (national action plans), which
local and regional authorities will be involved in preparing,
should include detailed provisions on the commodities from
which biofuels will be produced. NAPs should take account of
the specific nature of
the natural resources and agricultural
potential of each Member State;

urges that biofuels offering significant and quantified

36.
savings in greenhouse gas emissions are supported;

understands that cellulosic biomass (2) and algae can be
37.
harvested with less interference to the food economy and less
strain on land resources; as long as this is compatible with other
marine activities; although production methods are still under
development, green house gas savings of up to 90 % are
claimed (3). Furthermore, vehicle fuels can be produced from
waste by generating biogas through anaerobic digestion, with a
corresponding reduction in greenhouse gas emissions;

38.
calls on the European Commission to develop further
the environmental sustainability criteria for biofuels laid down
in Article 15 of the draft directive. These criteria should, inter
alia, provide a solution to the following questions, crucial to the
general sustainability of biofuels:

— the question of inputs (intensive practices involving synthetic

fertilisers and pesticides);

— the question of water saving in cultivation methods;

— the use of land which could be utilised for food crops.

(2) Wood (such as willow, hybrid poplar, eucalyptus), tall perennial grasses
(such as switchgrass and miscanthus, crop residues and municipal
organic waste.

(3) National Geographic October 2007 and Engineering & Technology

May 2008.

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Furthermore, following the examples of the above mentioned
it calls on the Commission to take into
regional networks,
account
regional production/consumption
chains;

the potential of

40.
believes that sustainability criteria need to be applied to
EU produced and non-EU produced biofuels to give the public
confidence in their purchasing decisions and in any schemes
operated by their local authority;

39.
urges rigorous assessment of biofuel sustainability in step
with technological change and amendment of the minimum
GHG saving as technology develops;

41.
biofuels must be produced sustainably and in a way
which minimises the climate impact. Under no circumstances
should permanently wooded areas be cleared in order to make
way for energy crops which, de facto, fix smaller quantities of
carbon dioxide;

II. RECOMMENDATIONS FOR AMENDMENTS

Amendment 1

Article 3(3)

Text proposed by the Commission

CoR amendment

3.
Each Member State shall ensure that the share of
energy from renewable sources in transport in 2020 is at
least 10 % of final consumption of energy in transport in
that Member State.

In calculating total energy consumed in transport for the
purposes of
the first subparagraph, petroleum products
other
than petrol and diesel shall not be taken into
account.

3.
Each Member State shall ensure that the share of
energy from renewable sources in transport in 2020 is at
least 10 % of final consumption of energy in transport in
that Member State. This energy may be produced only
from commodities obtained in a way that does not distort
the natural balance of the environment or the economic
balance of the market in individual Member States.

In calculating total energy consumed in transport for the
the first subparagraph, petroleum products
purposes of
other
than petrol and diesel shall not be taken into
account.

Reason

Because the production methods for biofuels offering high greenhouse gas savings are still in development
and establishing a target at this point risks distorting the global market for food products.

Amendment 2

Article 4(1)

Text proposed by the Commission

CoR amendment

1

Each Member State shall adopt a national action plan.

The national action plans shall set out Member States'
targets for the shares of energy from renewable sources in
transport, electricity and heating and cooling in 2020, and
adequate measures to be taken to achieve these targets,
including national policies to develop existing biomass
resources and mobilise new biomass resources for different
uses, and the measures to be taken to fulfil the require-
ments of Articles 12 to 17.

1.
Each Member State shall adopt a national action plan
on the basis of energy action plans, elaborated at local and
regional level and coordinated with regional and land use
policies; Member States shall actively consult and involve
regional and local authorities, at an early stage,
in the
preparation of national action plans.

The national action plans shall set out Member States'
targets for the shares of energy from renewable sources in
transport, electricity and heating and cooling in 2020, and
adequate measures to be taken to achieve these targets,
including the use of Green Public Procurement, through the
introduction of ecological criteria encouraging the use of
energy from renewable sources in the procurement of
energy services by public authorities and the use of national
policies to develop existing biomass resources and mobilise
new biomass resources for different uses, and the measures
to be taken to fulfil the requirements of Articles 12 to 17.

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Reason

Since many of the actions included in the National Action Plans will fall to Local and Regional authorities to
implement, it is essential that they get involved in drafting the National Action Plans.

As part of the ETAP strategy for the dissemination of environmental technologies, the 25 Member States
have adopted National Action Plans for Green Public Procurement (Italy approved its plan via an interminis-
terial decree of 11 April 2008). GPP should be used to introduce ecological criteria (regarding the use of
renewable energy sources) in the public procurement of energy services.

The draft Directive as it stand only makes limited references to the positive role that Local and Regional
Authorities can play (Articles 12.1.a, 12.3 and 12.7). While recognising that the Commission's reasoning is
to prioritise the achievement of the goal without prejudicing the ways Member States might choose to
achieve it, the above amendment can help to increase the visibility and respect the competences of subna-
tional Local Government in it, and crucially to encourage national authorities to actively engage with them
when designing and implementing their National Action Plans.

Amendment 3

Article 12(3)

Text proposed by the Commission

CoR amendment

Member States shall require local and regional administra-
tive bodies to consider the installation of equipment and
systems for the use of heating, cooling and electricity from
renewable sources and for district heating and cooling
when planning, designing, building and refurbishing indus-
trial or residential areas.

Member States shall require local and regional administra-
tive bodies to consider the installation of equipment and
systems for the use of heating, cooling and electricity from
renewable sources and for district heating and cooling
when planning, designing, building and refurbishing indus-
trial, commercial, office or residential areas.

Amendment 4

Article 13(1)

Text proposed by the Commission

CoR amendment

shall ensure that

1. Member States
information on
support measures is made available to consumers, builders,
installers, architects and suppliers of heating, cooling and
electricity equipment and systems and of vehicles compa-
tible with the use of high biofuel blends or pure biofuels.

shall ensure that

1. Member States
information on
support measures, with involvement of local and regional
authorities, is made available to consumers, builders, instal-
lers, architects and suppliers of heating, cooling and electri-
city equipment and systems and of vehicles compatible
with the use of high biofuel blends or pure biofuels.

Reason

Local and regional authorities should play an important role in training and information activities for the
dissemination of renewable energy sources, to ensure that the targets of the 20-20-20 programme are
reached.

Amendment 5

Article 13(4)

Text proposed by the Commission

CoR amendment

4. Member States shall develop guidance for planners
and architects so that they are able properly to consider the
use of energy from renewable sources and of district
heating and cooling when planning, designing, building
and renovating industrial or residential areas.

4. Member States shall, with the involvement of local
and regional authorities, develop guidance for planners and
architects so that they are able properly to consider the use
of energy from renewable sources and of district heating
and cooling when planning, designing, building and reno-
vating industrial or residential areas.

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Reason

Local and regional authorities should play an important role in training and information activities for the
dissemination of renewable energy sources, to ensure that the targets of the 20-20-20 programme are
reached.

Amendment 6

Article 14(a)

Text proposed by the Commission

CoR amendment

Without prejudice to the maintenance and safety of grids,
Member States shall ensure that transmission system opera-
tors and distribution system operators in their territory
guarantee that gas produced from renewable energy sources
and residual heat are given priority access to their appro-
priate grids on reasonable conditions.

Reason

Gas (biogas) and heating from renewable sources should ultimately be given access to the relevant grids,
exploiting residual heat from industrial processes, the burning of waste etc. is a very effective way of saving
primary energy.

Brussels, 8 October 2008

The President

of the Committee of the Regions

Luc VAN DEN BRANDE