COMMISSION STAFF WORKING DOCUMENT REFIT evaluation of the Directive 2009/28/EC of the European Parliament and of the Council Accompanying the document Proposal for a Directive of the European Parliament and of the Council on the promotion of the use of energy from renewable sources (recast)
Date: 2016-11-30
Institutions: Directorate-General for Energy, European Commission
Subjects: EU programme, air quality, energy consumption, energy saving, environmental cooperation, greenhouse gas, reduction of gas emissions, renewable energy, renewable resources

EN 

   EN 

   EUROPEAN COMMISSION  Brussels, 30.11.2016  SWD(2016) 416 final   COMMISSION STAFF WORKING DOCUMENT REFIT evaluation of the Directive 2009/28/EC of the European Parliament and of the Council Accompanying the document Proposal for a  Directive of the European Parliament and of the Council on the promotion of the use of energy from renewable sources (recast) {COM(2016) 767 final} {SWD(2016) 417 final}  
 
 
Contents 

EXECUTIVE SUMMARY .......................................................................................................................... 4 

I. 

INTRODUCTION ............................................................................................................................... 8 

1.1. 
1.2. 

Purpose of the REFIT evaluation ........................................................................................................ 8 
Scope of the REFIT evaluation ........................................................................................................... 8 

2. 

BACKGROUND TO THE INITIATIVE .......................................................................................... 9 

2.1.  Description of the initiative and its intervention logic ........................................................................ 9 
2.2.  Baseline ............................................................................................................................................. 13 

3. 

EVALUATION LOGIC AND QUESTIONS .................................................................................. 14 

Effectiveness ..................................................................................................................................... 14 
3.1. 
3.2. 
Efficiency .......................................................................................................................................... 14 
3.3.  Relevance .......................................................................................................................................... 15 
3.4.  Coherence ......................................................................................................................................... 15 
3.5.  Added value ...................................................................................................................................... 15 

4.  METHODOLOGY / PROCESS FOLLOWED .............................................................................. 15 

5. 

IMPLEMENTATION, STATE OF PLAY AND RESULTS ......................................................... 17 

Progress towards 20% renewable energy EU target and national targets ......................................... 17 
5.1. 
Progress towards 10% target for the 2020 share of renewable energy in the transport ..................... 18 
5.2. 
5.3.  Main quantitative impacts associated with the Renewable Energy Directive ................................... 19 

6.  ANSWERS TO EVALUATION QUESTIONS .............................................................................. 21 

6. 1.  Effectiveness ..................................................................................................................................... 21 
6.1.1.  Has the RES Directive been effective in achieving the binding EU renewable energy target of 20% by 
2020,  and  the  Member  State  national  binding  renewable  energy  targets  for  2020?  Do  implementation 
and enforcement challenges and failures exist? If yes, where and why? .......................................... 21 
6.1.2.  Has the RES Directive effectively led to better planning and streamlining of the approval and licensing 
procedures for RES producers at national and local level? ............................................................. 26 
6.1.3.  Has the RES Directive been effective in achieving the binding 10% renewable energy target in transport 
by 2020? ............................................................................................................................................ 28 
6.1.4.  Has  the  RES  Directive  triggered  sufficient  progress  in  RES  deployment  in  the  heating  and  cooling 
sector, which was previously not covered by renewable energy targets? ......................................... 31 
6.1.5.  What effects (impacts) has the implementation of the RES Directive had at EU and individual Member 
State’s level? ..................................................................................................................................... 33 
6.1.6.  Which factors have hindered the achievement of objectives of the RES Directive? ......................... 36 
6.2. 
Efficiency .......................................................................................................................................... 37 
6.2.1.  To what extent has the RES Directive, and the binding targets included therein, been efficient means of 
developing  the  European  renewable  energy  sector?  Could  the  use  of  other  policy  instruments,  or 
mechanisms, have provided better efficiency? .................................................................................. 37 
6.2.2.  Have  the  RES  Directive  and  its  national  implementation  measures,  including  support  schemes,  been 
cost-efficient means of achieving the RES targets at the EU and national level? Have the expected results 
been obtained at  a reasonable  cost?  Are  results  proportionate  to  the benefits?  Could  the  same  results 
have been achieved with less funding/lower cost? ............................................................................ 39 
6.2.3.  Has the RES Directive effectively improved grid access conditions for renewable electricity producers? 
Has it done so in a cost-efficient manner? ........................................................................................ 44 
6.2.4.  Has the RES Directive added administrative burden to Member States' public authorities and economic 
operators?  Or,  on  the  contrary,  has  such  burden  been  reduced  [e.g.  compared  to  previous  EU 
legislation  in  the  area  of  renewable  energy  Directive  2001/77/EC  and  Directive  2003/30/EC]?  Have 

2 

 
 
 
Member  States  reporting  obligation  requirements  become  more  efficient,  or,  on  the  contrary,  has  the 
reporting burden increased? ............................................................................................................. 45 
6.2.5.  Has  the  establishment  of  the  sustainability  scheme  for  biofuels  and  bioliquids  led  to  the  creation  of  a 
cost-efficient  framework?  Has  it  achieved  its  aim  in  a  cost-efficient  manner?  What  impact  has  such 
sustainability system had on the Member States administrations and the private sector? ............... 47 
6.3.  Relevance .......................................................................................................................................... 48 
6.3.1.  To  what  extent  were  the  objectives  of  the  RES  Directive  relevant  to  the  needs  of  the  EU  Energy  and 
Climate Change policy? To what extent does the RES Directive remain relevant for the Energy  Union 
priorities, the 2030 Energy and Climate Framework and COP 21 global climate commitments? ... 48 
6.3.2.  To what extent is the RES Directive complementary to other EU initiatives in the field and has synergies 
with them? ......................................................................................................................................... 50 
6.4.  Coherence ......................................................................................................................................... 50 
6.4.1.  Is the RES Directive coherent with other EU policies in the area of energy and climate change? .. 50 
6.5.  Added value ...................................................................................................................................... 53 
6.5.1.  What is the EU added value of the RES Directive (can the objectives be better achieved by action at the 
EU level)? ......................................................................................................................................... 54 
6.5.2.  Why could the RES Directive objectives be better achieved by EU action? ..................................... 54 
6.5.3.  Would it be possible to achieve the same results in the absence of the RES Directive? ................... 54 

7.  CONCLUSIONS AND RECOMMENDATIONS .......................................................................... 55 

ANNEX 1: TABLE ON MEMBER STATES' PERFORMANCE TOWARDS THEIR RENEWABLE 
ENERGY TARGETS (%) ................................................................................................................ 60 

ANNEX 2: PROCEDURAL INFORMATION ........................................................................................ 62 

ANNEX 3: SYNOPSIS REPORT OF STAKEHOLDER CONSULTATION IN THE CONTEXT OF THE 
STUDY ............................................................................................................................................... 63 

3 

 
 
 
 
 
 
 
EXECUTIVE SUMMARY 

The  Renewable  Energy  Directive1  (RES  Directive),  with  its  nationally  binding  energy  renewable 
targets for 2020, is a core element of the 2009 EU climate and energy package, although the EU legal 
framework  on  renewable  energy  promotion,  previously  based  on  indicative  targets,  dates  back  to 
20012.  The  renewable  energy  targets  are  also  part  of  the  Europe  2020  strategy  for  growth,  in 
particular  of  its  flagship  initiative  for  a  resource-efficient  Europe,  given  their  contribution  to 
innovation, growth, jobs and security of energy supply. Furthermore, the Directive is the central EU 
level instrument to "promote the development of new and renewable forms of energy", an aim set out 
in Art 194(1)(c) TFEU. Renewable energy is currently the only decarbonisation option in the power 
sector which is being deployed at a rate that is close to what is required under long-term scenarios of 
the International Energy Agency (IEA) to attain the 2◦C target.3  

The 2009 RES Directive has effectively ensured that all Member State but one are currently on track 
to achieve their 2020 targets, thus improving the pre-existing situation were only few Member States 
had  achieved  their  2010  indicative  targets  for  renewable  electricity  and  transport.  The  share  of 
renewable energy (RES) in the EU increased by 6 percentage points between 2007 and 2015 (from 
10.4%  to  17%)4.  As  anticipated  in  the  2007  Renewable  Energy  Road Map5  outlining  the  proposed 
EU  renewable  energy  framework  based  on  binding  EU  and  national  renewable  energy  targets,  the 
Directive  has  triggered  the  development  of  comprehensive  policies  in  all  Member  States  in  the 
electricity,  heating  and  cooling  and  transport  sectors.  In  parallel  with  additional  national  RES 
policies,  the  2009  RES  Directive  has  also  spurred  European-led  global  investment  and  technology 
cost reductions that were still unimaginable a few years ago.  For instance, from 2010-2015, average 
costs  for  new  onshore  wind  plants  fell  by  30%  and  average  costs  for  new  utility  scale  solar  PV 
installations declined by two-thirds6, the latter also influenced by production growth in China. This 
fall in prices has confirmed the volume-dependent technology learning curve. RES investments have 
been  surpassing  conventional  energy  investments  for  the  first  time  in  20147.  While  production 
volume  and  scale  were  probably  the  most  successful  elements  triggered  in  20098,  the  future 
framework for RES development will need to emphasise more market integration. As technologies 
mature and markets evolve, this will be the most cost-efficient way of deploying and integrating RES 
technologies.  Market  based  schemes  also  increase  investor  certainty  since  support  mechanisms  are 

1 

2  

3  

4  

5 
6  
7  
8  

Directive  2009/28/EC  on  the  promotion  of  the  use  of  energy  from  renewable  sources  (Renewable  Energy 
Directive), OJ L 140, 5.6.2009 
2009 Climate and energy package included the amended EU ETS Directive (Directive 2009/29/EC)  
Decision  No 406/2009/EC  on  the  effort  of  Member  States  to  reduce  their  GHG  emissions  to  meet  the 
Community’s  GHG  emission  reduction commitments  up  to 2020,  and Renewable  Energy Directive  (Directive 
2009/28/EC)  
System Integration of Renewables – Implications for Electricity Security. Report to the G7, OECD/IEA, 2016, 
available at: 
https://www.iea.org/media/topics/engagementworldwide/g7/IEAIRENAReporttotheG7onSystemIntegrationofR
enewables.pdf  
Reference  year  used  in  2007  model  runs  for  the  2008  IA  for  the  2009  Climate  and  energy  package.  Data: 
EUROSTAT and 2015 draft preliminary figure (“Draft Renewable Energy Progress Report”, Öko Institute [to 
be published]).   
COM(2006) 848 final 
Renewable electricity Medium-Term Market Report 2015, (IEA, 2015) 
World Energy Investment Outlook (IEA, 2014) 
The  lack  of  critical  mass  on  the  market  and  the  failure  of  conventional  energy  prices  to  include  the  negative 
externalities were identified as specific problem drivers related to the renewable energy sources back in 2006 
and 2008, when the Renewable Energy Road Map and proposal for a Renewable Energy Directive were initially 
put forward by the Commission SEC (2006) 1719/3 and SEC (2008) 85 

4 

 
 
 
 
 
                                                           
more  transparent  and  predictable  and  less  exposed  to  unilateral  government  decisions  (e.g. 
modification of support conditions for existing installations). 

Results  of  the  public  consultation9  highlighted  that  the  RES  Directive  is  considered  successful  in 
helping  the EU  reach  its  energy  and  climate  objectives  by  72%  of respondents10.  In  particular,  the 
evaluation study11 published in April 2015, on which the present REFIT evaluation is based, found 
that  its  national  binding  targets  were  the  most  important  driver  for  renewable  energy  policies  and 
investments  in  many  Member  States,  and  its  reporting,  planning  and  monitoring  obligations  were 
rated  as  highly  effective  in  the  Fitness  Check  Evaluation  on  energy  planning  and  reporting12  for 
enabling quantitative analysis and transparency on RES planning and deployment in Member States 
and the EU as a whole.  

The  Directive  has  so  far  delivered  more  impact  in  the  electricity  sector  than  in  the  heating  and 
cooling sector, which can be partly explained by late transposition deadlines (31 December 2014) for 
the  heating  and  cooling  and  building  related  provisions,  in  addition  to  the  fact  that  the  Directive 
contains more electricity  market related  measures13. The biofuels sustainability scheme  included in 
the Directive in 2009  failed to anticipate and address the risk of indirect land use change, and this 
gap  was  only  addressed  with  the  adoption  of  the  ILUC  Directive14  in  2015  and  the  amended  EU 
biofuel sustainability criteria. The long and technically complex inter-institutional negotiations that 
led to the adoption of the ILUC Directive, together with the complexity of some provisions under the 
sustainability schemes, gave rise to some initial challenges for its implementation in several Member 
States. The transport sub-target has successfully resulted in the implementation of blending mandates 
in the vast majority of the Member States.     

With regard to efficiency, this evaluation found that the methodology underpinning the effort sharing 
for the 20% EU target struck the right balance between cost effectiveness and political acceptance. 
However,  the  flexibility and  cooperation  mechanisms  included  in  the  RES  Directive  (joint  support 
schemes, joint projects, statistical transfers, or even third country cooperation, set out in Articles 6 to 
11),  which  were  intended  to  help  Member  States  achieve  their  national  targets  and  the  EU  overall 
target by making use of cost effective RES development in other Member States and third countries, 
have  hardly  been  used  by  Member  States.  The  Guarantees  of  Origin  scheme  (Article  15),  which 
provides  a  mechanism  for  consumer  disclosure of  the  sources  of  renewable  electricity,  has  not  yet 
delivered  sufficient  transparency  with  regard  to  the  suppliers  fuel  mix.  The  unreaped  cost-

9  

10  

11  

12  

13  

14  

"Public  consultation  on  the  Renewable  Energy  Directive  for  the  period  after  2020:  Analysis  of  stakeholder 
views",  European  Commission,  2016,  available  at:  https://ec.europa.eu/energy/en/consultations/preparation-
new-renewable-energy-directive-period-after-2020 
Among those 72%, 100% of Member states and public authorities consider the RED as successful or even very 
successful and 94% of non-RES energy industries and 90% of network operators agree. 
"Mid-term evaluation of the Renewable Energy Directive. A study in the context of the REFIT Programme", CE 
Delft , 2015 
Fitness  check  of  the  Reporting,  "Planning  and  Monitoring  Obligations  in  the  EU  energy  acquis".  Reference 
number to be added when this REFIT is adopted.  
Certain  provisions  of Art. 13(4) of  the  Renewable Energy  Directive were  only  applicable  from  2015,  and  the 
nearly zero-energy building requirements for new buildings only become applicable as of 2021. 
Directive  (EU)  2015/1513  amending  Directive  98/70/EC  relating  to  the  quality  of  petrol  and  diesel  fuels  and 
amending  Directive  2009/28/EC  on  the  promotion  of  the  use  of  energy  from  renewable  sources,  OJ  L  239, 
15.9.2015 

5 

 
 
 
 
 
                                                           
effectiveness  of  cooperation  measures  was  nevertheless  countered  by  the  large  decrease  in 
technology costs, thus improving the overall production cost picture15.  

Furthermore, the Directive did not prescribe support schemes as obligatory, nor did it set out details 
as  regards  their  design  and  management.  However,  most  Member  States  have  relied  on  support 
measures to incentivise RES deployment.  Not all national support schemes were found to be equally 
efficient  and  responsive  to  market  signals,  which  mattered  even  more  when  adjustments  were  not 
done  fast  enough  in  line  with  the  (rather  unexpected)  rapid  technological  cost  decreases.  Many 
Member States have introduced support schemes which were not related to market signals, resulting 
in distortions of the electricity market and leading in some cases to high support costs. In some cases, 
adjustments were also made too abruptly, or even retroactively, resulting in market uncertainty and 
ultimately increasing the overall impact on investors. To address these issues, the Commission issued 
guidance on RES support schemes design and their reform in 201316. The move towards more market 
based support mechanisms was then further complemented by the 2014 Guidelines on State aid for 
environmental protection and energy17.   

The national character of current support schemes finally also prevents exploring the full benefits of 
European  market  integration.  However,  as  this  evaluation  could  also  demonstrate,  political 
considerations  (preference  to  keep  investments  in  the  own  Member  State)  may  prevail  in  such 
decisions, even if they were to result in less cost-effectiveness. Also, the experience of the only joint 
support scheme  implemented so far has  showed that  the original expectations of cost-effectiveness 
have not fully materialised due to national regulatory differences that go beyond the support scheme 
itself.  Nevertheless,  it  is  expected  that,  with  the  increasingly  ambitious  trajectories  post-2015,  and 
based  on  currently  promising  signals  for  further  joint  mechanisms,  these  instruments  will  gain  in 
importance in the second half of the decade. 

Solid evidence shows the relevance of the Renewable Energy Directive for reaching the greenhouse 
gas (GHG) reduction targets, as well as for the delivery of Article 194(1c) of the Treaty. Although 
the renewable energy targets are expressed in relative terms (i.e. as a share of future levels of energy 
consumption), progressing towards them effectively displaces fossil fuels and complements the EU 
GHG reduction18. The increase in the use of renewable energy resulted in approximately 380 Mt of 
gross  avoided  CO2  emissions  at  EU  level  in  2014.  As  energy  efficiency  improves  –  another  key 
dimension  of  the  EU's  decarbonisation  efforts  –,  the  growing  share  of  renewables  results  in  a 
progressively larger displacement of non-renewable energy sources.   

Moreover, the benefits of renewables go well beyond GHG reduction and include greater security of 
supply  and  more  innovation,  jobs  and  growth.  For  example,  avoided  imported  fuel  costs  due  to 
increasing use of renewable energy amount to around €20 billion a year for the EU as a whole19. This 
makes  renewable  energy  a  key  delivery  tool  for  several  dimensions  of  the  Energy  Union  Strategy 
and for EU commitments in the 2015 Paris Climate Agreement on climate change. In addition, since 
2014, the EU's ambition to lead the world in renewable energy has been declared as one of the key 
policy priorities of the Juncker Commission.  

15  

16  
17  

18  
19  

"Mid-term evaluation of the Renewable Energy Directive. A study in the context of the REFIT Programme", CE 
Delft , 2015 
European Commission guidance for the design of renewables support schemes",  SWD(2013) 439 final 
Communication from the Commission - Guidelines on State aid for environmental protection and energy 2014-
2020", OJ 2014/C 200/01 
"Renewable Energy in Europe 2016 – Recent growth and knock-on effects", EEA, 2016, No 4/2016 
"“Draft Renewable Energy Progress Report”, Öko Institute [to be published]. 2014 figures 

6 

 
 
 
 
 
                                                           
With regard to  coherence  with other policies, the link with  Internal Energy market provisions and 
the  Emissions  Trading  System  (ETS)  are  probably  the  most  important,  but  not  the  only  ones,  as 
further elaborated in the evaluation. 

While  RES  support  schemes  contributed  to  the  expansion  of  RES  electricity  production  and 
technology cost reductions, their impact on electricity wholesale market functioning also increased 
significantly.  In  the  absence  of  clear  principles for  the  market-compatibility  of  support  schemes  in 
the  RES  Directive,  non-market-based  support  schemes  were  introduced  in  many  Member  States. 
Such support schemes added a regulated layer to the electricity price that did not respond to market-
signals, thereby reducing the ability of the wholesale electricity price to steer trade and investment 
decisions effectively.  

The  2009  RES  Directive  established  priority  access  and  dispatch  for  renewable  energy  to 
compensate  for  electricity  market  rules  not  providing  renewable  producers  the  opportunity  to  fully 
participate in the market20. With the parallel ongoing  initiative for a new  market design improving 
the conditions for RES suppliers, the need for continuing preferential treatment will need to be re-
assessed and the role of the RES Directive in a reformed electricity market design to be re-defined.  

The deployment of renewables induced by the Directive contributed to a slight reduction in demand 
for  EU  ETS  allowances.  However,  the  overall  surplus  of  allowances21  implies  that  the  price-
dampening  effect  of  new  renewable  energy  was  in  fact  rather  limited.  The  general  deployment  of 
renewables  induced  by  the  Directive  has  worked  in  synergy  with  the  EU  ETS  by  ensuring  that 
regulatory,  administrative  and  energy  operating  systems  adapt  to  a  low  carbon  energy  future  and 
allow the ETS price signal to feed through to suppliers.   

There  was  an  EU-added  value  in  the  form  of  a  clear  joint  ambition  underpinned  by  national 
planning  that  allowed  investors  to  become  active  across  the  EU  under  similar  framework 
conditions22.The  EU  wide  roll-out  also  resulted  in  significantly  higher  effects  of  scale  and 
consecutively  more  pronounced  technology  cost  reductions  for  new  on-shore  wind  and  solar 
photovoltaic capacity (since 2015 also for off-shore wind). This has made deployment cheaper for all 
the Member States involved, as it would not have otherwise been. It emerged that a minimum degree 
of  coordination  in  the  area  of  RES  is  necessary  to  avoid  negative  effects  on  other  Member  States 
stemming  e.g.  from  insufficient  grid  development  (loop  flows23)  or  retroactive  changes.  It  is 
important  to  note  that  recent  stakeholder  feedback  (e.g.  Florence  Electricity  Forum,  June  201624) 
called  for  common  rules  on  support  schemes  and  for  more  regionalised  and  market  based 
approaches.  

EU  added  value  was  delivered  by  the  Concerted  Action  for  Renewables25,  which  is  a  structured, 
confidential  dialogue  enabled  by  the  Commission  among  national  authorities  tasked  with  the 

20  

21  

22  

23  

24 
25 

Due  amongst  other  things  to  the  lack  of  liquid  intraday  and  balancing  markets,  the  absence  of  rules  fit  for 
renewables, the lack of sufficiently flexible power systems 
The surplus amounted to around 2 billion allowances at the start of phase 3 (2013-2020) and increased further to 
more than 2.1 billion in 2013. In 2015, it was reduced to around 1.78 billion  
"Mid-term evaluation of the Renewable Energy Directive. A study in the context of the REFIT Programme", CE 
Delft , 2015 
If a national grid has not enough capacity to cope with its own generation infeed, this may lead to unexpected 
electricity flows across borders ("unscheduled flows" or "loop flows"). Such loop flows can significantly reduce 
the possibilities to trade electricity across borders. 
European Commission, 31st EU Regulatory Forum, "Draft Conclusions", 13th-14th June 2016 
CA-RES accessible at: http://www.ca-res.eu/index.php?id=2 

7 

 
 
 
 
 
                                                           
implementation of this Directive. This initiative has delivered particular benefits as Member States 
started  with  very  different  levels  of  experience,  offering  wide  knowledge  sharing  opportunities  for 
Member States which were less advanced in implementation.   

By excluding the production of biofuels in areas of high biodiversity and carbon value and by laying 
down a set of common biofuel sustainability criteria and methodology, the RES Directive established 
common EU sustainability criteria, preventing market fragmentation and potential trade barriers that 
could have arisen if national sustainability rules had diverged.  

The RES Directive (and energy efficiency  legislation) serve as a reference for Member States' low 
carbon  investments  funded  by  the  European  Structural  and  Investment  Funds,  and  for  the  EIB 
group26 lending, including in the framework of the European Fund for Structural Investments (EFSI). 
These  priorities  remain  valid,  as  the  EU  prepares  itself  for  achieving  the  2030  energy  and  climate 
targets in line with its COP21 commitments and renewed commitment to foster sustainable and green 
investments27. 

Finally, the RES Directive (together with other parts of 2009 climate and energy package) and the 
EU global leadership role in renewable energy contributed to the spread of renewable energy policies 
around  the  world.  By  2015,  at  least  173  countries  had  adopted  renewable  energy  targets  (not 
considering the intended nationally determined contributions prior to COP21), and an estimated 146 
countries had renewable energy support policies in place28. 

I. 

INTRODUCTION 

1.1. 

Purpose of the REFIT evaluation 

As  part  of  the  Commission's  Better  Regulation  agenda,  the  Renewable  Energy  Directive  was 
included in the Commission's 2013 REFIT programme29 in order to provide a comprehensive policy 
and regulatory fitness evaluation of the 2009 RES Directive. Building on the conclusions drawn from 
the  present  REFIT  evaluation,  the  Commission  intends  to  revise  the  regulatory  framework  on  the 
promotion of the use of energy from renewable sources by the end of 2016. The present evaluation 
informs the Impact Assessment for this revision. 

1.2. 

Scope of the REFIT evaluation 

The evaluation covers all aspects of the RES Directive30, but it should be noted that there is a parallel 
on-going Fitness Check evaluation on the reporting, planning and monitoring obligations in the EU 

26  
27 
28  
29  
30  

The EIB group consists of the European Investment Bank and the European Investment Fund 
"Europe investing again: Taking stock of the Investment Plan for Europe and next steps", COM (2016) 359 final 
Renewables 2016 - Global Status Report, REN21, 2016. 
Communication on Regulatory Fitness and Performance (REFIT): Results and Next Steps, COM (2013) 685 
Roadmap for the Renewable Energy Package is available here:  
http://ec.europa.eu/smart-regulation/roadmaps/docs/2016_ener_025_cwp_renewable _energy_package_en.pdf 

8 

 
 
 
 
 
                                                           
energy  legislation,  including  those  set  out  in  the  RES  Directive  (Articles  22  and  23)31.  Those  are 
therefore fully assessed in the referred parallel evaluation exercise32. 

The  RES  REFIT  evaluation  covers  28  Member  States  and  the  period  from  2010  (i.e.  the  legal 
implementation date of the Directive) to 2015 (i.e. date of latest statistical and other data evidence 
available), except where specified otherwise.  

2. 

BACKGROUND TO THE INITIATIVE 

2.1. 

Description of the initiative and its intervention logic 

The  RES  Directive  forms  part  of  the  EU  Energy  and  Climate  policy  package  mandated  by  the 
European Council in 2006 and 200733 and was adopted in 200934,35.  

The RES Directive lays down the principles according to which Member States need to ensure that 
the share of renewable energy in the EU final energy consumption reaches at least 20% by 2020. It 
establishes  non-uniform  national  mandatory  targets  for  the  share  of  renewables  in  final  energy 
consumption for each Member State (as opposed to pure indicative national targets of the previous 
legislation). The RES Directive also includes biennial indicative target trajectories36. 

The effort sharing amongst Member States for achieving the overall EU level 20% target was based 
on  a  flat-rate  increase  in  each  Member  State  weighted  by  gross  domestic  product  (GDP)  and 
modulated  to  take  account  of  earlier  development  of  renewable  energy  resources  in  that  Member 
State. Three sectors were covered, electricity, heating and cooling and transport, but the split of the 
share  between  the  sectors  was  left  to  the  discretion  of  the  Member  States.  However,  a  separate 
mandatory 10% target for the 2020 share of renewable energy in transport was provided.  

The  following  list  summarises  key  EU  and  national  measures,  resulting  from  the  2009  RES 
Directive:  

 

In  view  of  reducing  the  overall  cost  of  renewable  energy  target  achievement,  the  RES 
Directive  created  the  legal  framework  for  Member  States'  cooperation  in  the  form  of 
statistical transfers, agreements on joint support schemes and joint projects, with other 
Member States, or third countries (Art. 6-11);  

31  

32  

33  

34  
35  

36  

Roadmap to the Fitness check of Reporting, Planning and Monitoring Obligations is available here: 
http://ec.europa.eu/smart-
regulation/roadmaps/docs/2016_ener_024_cwp_refit_reporting_planning_obligations_en.pdf 
Preparatory  study  for  the  Fitness  Check  Evaluation  of  Planning  and  Reporting  Obligations  in  the  EU  Energy 
Acquis, Intermediate report, (Trinomics, April, 2016) 
European Council Conclusions (23-24 March 2006), 7775/1/06 and European Council Conclusions (8-9 March 
2007), 7224/1/07 
Renewable Energy Directive (Directive 2009/28/EC), OJ L 140/16, 5.6.2009 
Before then, two separate directives promoting renewable energy use in the electricity (Directive 2001/77/EC) 
and renewable energy use in transport (Directive 2003/33/EC) were in place. Among other, these two directives 
contained 2010 indicative targets for Member States for renewable electricity and share of renewable energy in 
transport. The Directive 2009/28/EC established an EU level framework based on binding targets to be achieved 
by 2020: an overall EU target of a 20% share of renewable energy sources in energy consumption, diferentiated 
national  binding  targets  in  line  with  this  overall  EU  20%  target,  and  a  universal  10%  target  for  renewables 
consumption in transport..  
Directive 2009/28/EC, Annex I Part B, OJ L 140/46, 5.6.2009 

9 

 
 
 
 
 
                                                           
  Given  the  binding  nature  of  the  target,  Member  States  were  left  with  more  flexibility  as 
regards  the  measures  needed  to  reach  the  targets.  Accordingly,  the  Directive  does  not 
prescribe,  but  only  suggests  Member  States  to  use,  inter  alia,  support  schemes  and 
cooperation measures (Art. 3 a) and b));  

  The  Directive  also  required,  for  the  first  time,  all  Member  States  to  prepare  National 
Renewable  Energy  Action  Plans  (Art.  4)  based  on  a  binding  template37  and  included 
provisions  on  national  authorisation,  certification  and  licensing  procedures,  and  permit 
granting for RES projects (Art. 13(1));  

  Provisions  requiring  Member  State  action  to  increase  the  use  of  RES  in  buildings  and 
district heating and cooling were laid down in Art. 13 (3-6), Art. 16(9) and Art. 16(11);  

 

In  order  to  guarantee  their  sustainable  production  and  use,  the  Directive  also  required  that 
biofuels and bioliquids counting towards the RES targets, or receiving public support, reach 
at  least  a  minimum  level  of  greenhouse  gas  (GHG)  emission  savings  and  do  not  lead  to 
unintended biodiversity impacts (Art. 17-19); solid and gaseous biomass sustainability issues 
were  left  to  Member  States'  discretion  in  line  with  national  competence  over  forestry 
management.  

The RES Directive was amended in 2015by the ILUC Directive38, which introduced a cap for food 
based biofuels and further incentives for advanced renewable fuels with a view to reduce the risk of 
indirect land use change (ILUC) and to prepare the transition towards the deployment of advanced 
renewable fuels. 

The  general  objectives  of  the  RES  Directive  as  stipulated  in  the  2006  and  2008  Impact 
Assessments39 are to:  

  Reduce CO2 from energy use, 

  Limit the global average temperature increase to not more than 2 degrees Celsius above the 

pre-industrial level; 

  Make the EU economy more energy secure; 

  Make the EU the most competitive economy in the world, in particular with respect to new 

energy technologies such as low carbon energy production technologies.  

The specific objective of the RES Directive is to achieve a 20% share of renewable energy in EU 
final energy consumption and a 10% share of energy from renewable sources in the transport sector 
by 2020. 

The intervention logic, setting out the rationale and approach for the Renewable Energy Directive is 
given in Figure 1. 

37  

38  

39  

Commission  Decision  of  30  June  2009  establishing  a  template  for  National  Renewable  Energy  Action  Plans, 
,C(2009) 5174 
Directive  (EU)  2015/1513  amending  Directive  98/70/EC  relating  to  the  quality  of  petrol  and  diesel  fuels  and 
amending  Directive  2009/28/EC  on  the  promotion  of  the  use  of  energy  from  renewable  sources,  OJ  L  239, 
15.9.2015 
SEC (2006) 1719/3 and SEC (2008) 85 Vol. II 

  10 

 
 
 
 
                                                           
Figure 1: Renewable Energy Directive (Directive 2009/28/EC): intervention logic and impact 

S
E
V
I
T
C
E
J
B
O

GENERAL 

To limit global average temperature 
increase to not more than 2◦C above 
the present industrial level; 

To make EU economy energy secure; 

To make the EU the most competitive 
economy in the world, in particular 
with respect to new energy 
technologies such as low carbon energy 
production technologies.  

____________________________________ 
 SPECIFIC 

To achieve a share of 20% of renewable 
energy, and 10% of renewable energy 
in transport by 2020. 

S
E
R
U
S
A
E
M

L
A
N
O
I
T
A
N
D
N
A
U
E

EU MEASURE 

INTENDED*  

Mandatory EU renewable energy target 
for 2020; 

Mandatory national renewable energy 
targets for 2020 and requirements for 
National renewable energy action 
plans; 

Cooperation mechanisms between 
Member States and with third 
countries  

Renewable energy access to grids and 
simplified administrative procedures 

Mandatory national renewbale energy 
targets for transport 10%; 

Sustainability criteria for biofuels  

__________________________________________ 

MEMBER STATE ACTION 

National renewable energy action plans 
and national measures (including 
support schemes) to meet the binidng 
national RES target and 10% renewable 
energy target for transport; 

Administrative simplificationand grid 
access measures for renewable energy 
producers; 

Guarantees of origin for renewbale 
electricity producers 

)
t
c
e
r
i
d
n
i
/
t
c
e
r
i
d
(

S
T
C
A
P
M

I

Supportive RES policy regime accross the 
EU, facilitating RES industry and technology 
growth; 

RES expansion and industrial development; 

Cumulative investment needs (2005-2020): 
600-670 billion EUR (in 2005 prices); 

Cumulative addittional production costs 
(2005-2020):210-290 bn EUR; 

Annual average addittional costs: 13-18 bn 
EUR; 
Reduction in GHG: 600-900 Mt CO2 eq p.a.; 
Reduced fossil fuel use: 234-300 Mt p.a.; 

GDP: - 0.05-0.5 %; 

Employment: + 650 000 . 

________________________________ 

UNINTENDED 

Global growth of RES technology and 
production; 

Infrastructure bottlenecks and loopflows; 

Rapid RES technology cost reductions; 

Production bubbles and increasing cost of 
support for some RES technologies in some 
Member States due to fixed support levels; 

Indirect Land Use Change. 

* Impact Assessment SEC (2008)85, based on oil price range $ 
48-78 

  11 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Intended main quantitative impacts 

The 2006 Impact Assessment for the Renewable Energy Road Map40 summed up the estimated 2020 
impacts of reaching a 20% renewable energy target, as follows: 

  The additional renewable energy deployment needed to achieve the 20% target by 2020 will 

lead to an annual GHG saving in the range of 600-900 Mt CO2 in 202041;  

  Replacing  fossil  fuels  with  renewable  energy  sources  will  contribute  to  a  reduction  of 

polluting emissions, especially from the electricity sector; 

  Avoided EU fossil fuel consumption was estimated in the range of 234-300 Mtoe/year from 
2020 onwards, including 200 Mtoe per year of imported fuels42; in monetary terms, increased 
capacity for RES production in the period 2005-2020 was expected to account for around 50-
57 bn EUR/year43; 

  Cumulative investment needs for renewable energy in the period 2005-2020 were estimated 

in the range of EUR 600-670 billion (in 2005 prices); 

  Cumulative additional production costs in the period 2005-2020 were estimated in the range 
of  EUR  210-290  billion  (with  48$/bbl  oil  price);  the  average  yearly  additional  production 
costs were projected to be in the range of 13-18 billion EUR/year in the period 2005-202044; 

  As regards GDP growth and employment, it was expected that by 2020 the EU GDP would 
be  0.5%  higher  than  under  a  business  as  usual  scenario,  and  employment  would  grow  by 
around 0.3%, resulting in about 650 000 additional jobs by 2020.  

  The biodiversity impact was expected to be overall positive, even if some negative effects 
could  emerge  in  the  case  of  wind  parks,  if  these  were  located  in  areas  of  high  biodiversity 
value, or biofuel production, if this would occur on land with high biodiversity value.  

  The  2006  Impact  Assessment  calculated  the  total  estimated  average  cost  on  the  basis  of 
dynamic and varied values of technology costs, assuming an average wind energy production 
cost  of  65  EUR/MWh,  650  EUR/MWh  for  photovoltaic  electricity  and a  range  between  20 
EUR/MWh and 180 EUR/MWh for biomass. 

 

In  terms  of  administrative  costs  linked  to  reporting  and  planning,  the  2008  Impact 
Assessment45 estimated additional cost to national authorities of ca. EUR 19 500 per Member 
State, and for the EU as a whole, of ca. EUR 0.5 million every two years.   

40  
41  
42  
43  
44  

SEC (2006) 1719 
Range based on Green-X and PRIMES, 2006 Impact Assessment, p.20 
Range based on Green-X and PRIMES, 2006 Impact Assessment, p.20 
Based on Green-X model calculations, 2006 Impact Assessment p.21 
The  annual  additional  cost  of  increasing  the  contribution  of  renewables  to  the  proposed  share  by  2020  was 
defined  as  the  total  costs  of  generation  of  renewables  minus  the  reference  cost  of  conventional  energy 
production. A balanced mix of renewable technologies, combined with low international oil prices ($48) were 
expected to result in additional average annual cost of achieving the proposed 20% RES share of approximately 
EUR 18 billion (in 2005 prices). Strong research and development efforts were expected to lower the costs of 
RES  policies  and  therefore  the  overall  cost of  this  policy. The  exact  choice  of  technologies  could reduce  this 
average cost by approximately 2 billion EUR per year. 

  12 

 
 
 
 
                                                           
The intended and unintended direct impacts of the RES Directive and other external factors, 
such  as  those  related  to  technology  developments,  unanticipated  indirect  land  use  change  risk  and 
impacts  of  2007-2010  economic  crisis,  are  reviewed  and  assessed  against  these  anticipated 
quantitative impacts in Section 6. 

2.2. 

Baseline 

For  the  purpose  of  the  present  evaluation,  the  2006  Impact  Assessment  for  the  Renewable  Energy 
Road Map and the 2008 Impact Assessments for the 2020 Energy and Climate Package are used to 
establish  the  baseline  for  describing  the  situation  prior  to  the  adoption  of  Renewable  Energy 
Directive in December 2008. The overall 2020 target framework and its main anticipated quantitative 
impacts were assessed in the 2006 Impact Assessment, while the 2008 Impact Assessment assessed 
the effort sharing among Member States in view of 20% RES target achievement and other crucial 
provisions of the Directive such as those on Guarantees of Origin, administrative and grid barriers, 
national  plans  or  biofuel  sustainability  criteria.  No  new  additional  modelling  approaches  were 
developed  for  the  purposes  of  this  evaluation.  It  must  be  noted,  however,  that  the  2006  and  2008 
Impact Assessments used 2005 and 2007 as baseline year respectively, whereas the RES Directive 
entered into force in 2010. The effects of this Directive will be analysed from 2010 onwards. 

Differences in the (modelling) methodology used in the 2006 and 2008 Impacts Assessments make 
the  comparison  of  some  key  impacts  challenging.  Furthermore,  in  the  2008  Impact  Assessment 
supporting  the  2020  Climate  and  Energy  Package,  some  renewable  energy  policy  aspects  were 
analysed  together  with  expected  impacts  from  GHG  emission  reduction  measures.  This  approach 
makes  the  distinction  and  comparison  of  certain  impacts  even  more  difficult.  Nevertheless,  a  fair 
degree  of  comparison  has  been  possible,  by  drawing  on  a  limited  number  of  baseline  indicators 
included in the 2006 and 2008 Impact Assessments, such as GHG saving, fossil fuel displacement, 
employment  and  technology  cost  reduction  impacts.    For  other  indicators,  the  quantification  of 
results  of  the  mid-term  evaluation  of  the  Renewable  Energy  Directive  should  be  read  with  due 
caution.  

The 2008 Impact Assessment noted that the majority of Member States were promoting the increase 
in renewable energy production either by green certificate regimes (4 Member States), or by feed-in-
tariff system (17  Member  States). The 2008 Impact Assessment also assumed that  an open market 
for Guarantees of Origin, combined with a continuation of national support schemes, would make the 
2020  renewable  energy  target  achievement  cheaper.  However,  the  option  of  Guarantees  of  origin 
being used as a form of cooperation mechanism for cost-effective target achievement was finally not 
retained in the adopted 2009 RES Directive.  

It  has  to  be  noted  that  the  Directive  provides  quantified  and  measurable  overall  and  national 
renewable energy targets that make it relatively easy to measure progress, but does not contain any 
other  measurable objectives.  The effectiveness  of the other  provisions in the Directive needs to be 
assessed against qualitative improvements.  

45  

Impact Assessment for the 2020 Energy and Climate Package SEC (2008) 85 

  13 

 
 
 
 
                                                                                                                                                                                                   
3. 

EVALUATION LOGIC AND QUESTIONS 

3.1. 

Effectiveness 

  Has the RES Directive been effective in achieving the binding EU renewable energy target of 
20% by 2020, and the Member State national binding renewable energy targets for 2020? Do 
implementation and enforcement challenges and failures exist? If yes, where and why? 

  Has the RES Directive effectively led to better planning and streamlining of the approval and 

licensing procedures for RES producers at national and local level?  

  Has the RES Directive been effective in achieving the binding 10% renewable energy target 

in transport by 2020? 

  Has  the  RES  Directive  triggered  sufficient  progress  in  RES  deployment  in  the  heating  and 

cooling sector, which was previously not covered by renewable energy targets? 

  What effects (impacts) has the implementation of the RES Directive had at EU and individual 

Member State’s level? 

  Which factors have hindered the achievement of objectives of the RES Directive?  

3.2. 

Efficiency 

  To what extent has the RES Directive, and the binding targets included therein, been efficient 
means of developing the European renewable energy sector?  Could the use of other policy 
instruments, or mechanisms, have provided better efficiency?  

  Have  the  RES  Directive  and  its  national  implementation  measures,  including  support 
schemes,  been  cost-efficient  means  of  achieving  the  RES  targets  at  the  EU  and  national 
level? Have the expected results been obtained at a reasonable cost? Are results proportionate 
to  the  administrative  cost  and  burden  on  Member  State  administrations  and  businesses? 
Could the same results have been achieved with less funding/lower cost? 

  Has  the  Directive  effectively  improved  grid  access  conditions  for  renewable  electricity 

producers? Has it done so in a cost-efficient manner? 

  Has the RES Directive added administrative burden to Member States' public authorities and 
economic  operators?  Or,  on  the  contrary,  has  such  burden  been  reduced  [e.g.  compared  to 
previous EU legislation in the area of renewable energy Directive 2001/77/EC and Directive 
2003/30/EC]? Have Member States reporting obligation requirements become more efficient, 
or, on the contrary, has the reporting burden increased? 

  Has  the  establishment  of  the  sustainability  scheme  for  biofuels  and  bioliquids  led  to  the 
creation  of  a  cost-efficient  framework?  Has  it  achieved  its  aim  in  a  cost-efficient  manner? 
What  impact  has  such  sustainability  system  had  on  the  Member  States  administrations  and 
the private sector? 

  14 

 
 
 
 
3.3. 

Relevance 

  To  what  extent  were  the  objectives  of  the  RES  Directive  relevant  to  the  needs  of  the  EU 
Energy and Climate Change policy? To what extent does the RES Directive remain relevant 
for  the  Energy  Union  priorities,  the  2030  Energy  and  Climate  Framework  and  the  COP  21 
Global Climate commitments?  

  To what extent is the RES Directive complementary to other EU initiatives in the field and 

has synergies with them? 

3.4. 

Coherence 

 

Is  the  RES  Directive  coherent  with  other  EU  policies  in  the  area  of  energy  and  climate 
change? 

3.5. 

Added value 

  What is the EU added value of the RES Directive (can the objectives be better achieved by 

action at the EU level)?  

  Why could the Renewable Energy Directive objectives be better achieved through EU action? 

  Would it be possible to achieve the same results in the absence of the RES Directive? 

4. 

METHODOLOGY / PROCESS FOLLOWED 

A supporting mid-term REFIT evaluation study of the RES Directive was launched in May 2014 and 
conducted until April 201546. The study was carried out by a consortium of experts led by CE Delft 
and  Ecologic  Institute,  Ricardo-AEA  and  REKK,  drawing  on  available  literature,  data  and 
stakeholder  interviews  with  national  authorities,  renewable  energy  industry  associations,  non-
renewable  energy industry associations, consumers' associations, NGOs, etc.47. Six case studies for 
countries  representing  various  degrees  of  progress,  potential  and  deployment  (Bulgaria,  Estonia, 
Germany, Poland, Spain and Sweden) were part of the supporting study. Furthermore, the 12 week 
public  online  consultation  (18th  November  2015  –  10th  February  2016)  that  took  place  in  the 
context  of  the  present  evaluation  and  Impact  Assessment  for  the  revised  Directive,  included  the 
following questions relevant for this evaluation48:  

  To  what  extent  has  the RES  Directive  been  successful  in  helping  to  achieve  the  EU  energy 

and climate change objectives? 

46  

47   

48  

"Mid-term evaluation of the Renewable Energy Directive. A study in the context of the REFIT Programme", CE 
Delft,2015 
For  full  account  of  stakeholders  interviewed,  see  "Mid-term  Evaluation  of  the  Renewable  Energy  Directive" 
study. 
"Public  consultation  on  the  Renewable  Energy  Directive  for  the  period  after  2020:  Analysis  of  stakeholder 
views",  European  Commission,  2016,  available  at:  https://ec.europa.eu/energy/en/consultations/preparation-
new-renewable-energy-directive-period-after-2020 

  15 

 
 
 
 
                                                           
 
 
 

 To  what  extent  has  the  RES  Directive  been  successful  in  addressing  the  following  EU 
transport policy objectives? 

  Please  name  the  most  important  barriers  hampering  the  development  of  sustainable 

renewable fuels and renewable electricity use in transport?  

  The use of cooperation mechanisms has been limited to date. Which of the below factors do 
you consider important in explaining the limited recourse by Member States to cooperation 
mechanisms so far?  

  To  what  extent  has  the  current  GO  system  been  successful  in  providing  consumers  with 

information on the sources of electricity that they consume?  

  Please identify precise challenges with regard to grid regulation and infrastructure barriers 

in EU Member States that you are aware of. 

  How would you rate the importance of the following barriers for consumers to produce and 

self-consume their own renewable energy? 

  Please  rate  the  importance  of  the  following  barriers  in  hampering  the  deployment  of 

renewable heating and cooling in the EU. 

  Has the RES Directive been effective and efficient in helping exploiting the renewable energy 

potential at local level? 

  How  would  you  rate  the  importance  of  the  following  barriers  that  may  be  specifically 
hampering  the  further  deployment  of  renewable  energy  projects  at  the  local  level 
(municipalities and energy cooperatives)? 

  How would you rate the administrative burden and cost of compliance with the RES Directive 

RED for national, regional and local authorities? 

  Please identify precise challenges with regard to grid regulation and infrastructure barriers 

in EU Member States that you are aware of. 

In addition to several dedicated meetings, a Stakeholder Conference was held on 5th February 2016 
to  gather  opinions  on  the  current  EU  renewable  energy  policy  framework  and  the  post-2020 
perspective,  and  to  complement  the  public  consultation  with  focus  on  three  themes:  renewable 
energy target achievement, role of consumers and communities, and renewable energy financing. A 
complete  description  of  the  stakeholder  consultation  outcome,  including  this  and  other  relevant 
meetings in the context of the present REFIT evaluation, is provided in Annex I.  

Limitations-robustness of the findings 

The  REFIT  evaluation  of  the  Renewable  Energy  Directive  occurs  5  years  ahead  of  the  target  year 
(2020),  while  the  heating  and  cooling  and  building  provisions  (Art.  13  (4-6))  have  only  been 
applicable  since  2015.  In  addition  so  far,  only  very  limited  experience  with  flexibility  and 
cooperation mechanisms (Art. 6-11) has been gained.  

Differences in the modelling methodology used in the 2006 and 2008 Impact Assessments preceding 
the adoption of the RES Directive, as well as differences in the studies and modelling tools used to 

  16 

 
 
 
 
assess the mid-term evaluation and impacts of the 2009 RES Directive, turn the comparison of some 
key  impacts  into  a  challenging  task.  Furthermore,  in  the  2008  Impact  Assessment,  supporting  the 
2020  Climate  and  Energy  Package,  some  renewable  energy  policy  aspects  were  analysed  together 
with  expected  impacts  from  GHG  emission  reduction  measures.  This  makes  the  distinction  and 
comparison of certain impacts also more demanding.  

Nevertheless,  a  fair  degree  of  comparison  has  been  possible,  by  drawing  on  a  limited  number  of 
baseline  indicators  included  in  the  2006  and  2008  Impact  Assessments.  For  other  indicators  and 
quantification  of  results,  additional  research  was  undertaken,  relying  on  independent  studies,  own 
research, work carried out for the European Commission and data from relevant international bodies 
(e.g. IEA/OECD, IRENA etc.).   

5. 

IMPLEMENTATION, STATE OF PLAY AND RESULTS 

From  a  legal  perspective,  the  RES  Directive  appears  to  have  raised  some  difficulty  for  Member 
States' transposition and application process, as 47 infringement cases were opened and 4 Member 
States were referred to the Court. Presently, 44 cases are closed and 3 cases are still pending. Most of 
the  infringement  cases  that  reached  the  most  advanced  stage  were  related  to  the  biofuels  and 
bioliquids  sustainability  criteria,  as  these  provisions  were  a  novelty  for  most  Member  States  and 
required more complex measures of implementation.  

So  far,  only  one  EU  pilot  case  has  been  opened  against  a  Member  State  that  did  not  meet  is 
2013/2014  interim  target,  triggering  the  obligation  to  resubmit  an  amended  National  Renewable 
Energy Action Plan.  

A  significant  number  of  complaints,  petitions  and  parliamentary  questions  were  addressed  to  the 
Commission in relation to retrospective and other changes in national support schemes occurring in 
various  Member  States,  and/or  discriminatory  measures  against  renewable  energy  operators, 
claiming  alleged  violations  of  the  RES  Directive  (due  to  insufficient  action  by  Member  States  to 
achieve their national binding targets) and of general principles of EU law. In most cases there was 
no sufficient grounds to initiate legal action against Member States based on these allegations, as the 
Directive  does  not  prescribe  the  use  of  support  schemes  to  achieve  the  national  renewable  energy 
targets, nor does it give details on the design and management of such schemes.  

The  following  section  summarises  the  current  situation  in  implementing  the  RES  Directive  in 
relation to the specific objectives set out in the intervention logic (see Figure 1). It also summarises 
the  current  status  of  progress  towards  the  binding  2020  EU  and  national  renewable  energy  targets 
based on the latest available data49 . 

5.1. 

Progress towards 20% renewable energy EU target and national targets 

With a 17%50 estimated  share in  2015 in the gross  final energy consumption51, the EU and all but 
one Member State are currently advancing well towards 2020 renewable energy targets.  

49  

50  
51  

Based on most recent EUROSTAT statistics for RES shares for 2014, and 2015 estimates for the forthcoming 
2016 Renewable Energy progress report 
“Draft Renewable Energy Progress Report”, Öko Institute [to be published]. draft preliminary figure 
EUROSTAT data 

  17 

 
 
 
 
                                                           
The  sectorial  shares  of  renewable  energy,  although  not  legally  stipulated  in  the  Directive,  but 
forming part of National Renewable Energy Action plans, also offer a positive picture on renewables' 
deployment  in  the  EU:  the  share  in  the  heating  and  cooling  sector  was  17.7%  in  201452  and  was 
estimated to reach 18.5%53 in 2015, while 27.5% and 30% of the EU's electricity was generated from 
renewables in 2014 and 2015 respectively and the share on renewable energy in the transport sector 
was 5.9% in 2014 and an estimated 6.2% in 201554. About 11% of the total EU electricity is sourced 
from variable renewable electricity (such as wind and solar)55.  

Figure 2: EU and Member State progress towards 2020 renewable energy targets (2015) 

Source: “Renewable Energy Progress Report”, Öko Institute [to be published] 

In 2015, twelve Member States had already achieved their 2020 targets (Austria, Bulgaria, Croatia, 
the Czech Republic, Denmark, Estonia, Finland, Greece, Italy, Lithuania, Romania and Sweden). All 
Member States were above their indicative trajectory in 2013/201456 except for the Netherlands, and 
majority of the Member States, as well as the EU, is well on track to 2015/2016 interim targets. 

5.2. 

Progress towards 10% target for the 2020 share of renewable energy in the transport  

With a share of 5.9% renewable energy in transport in 2014 and 6.2% estimated share in 2015, the 
EU is moving towards 10% RES share in transport by 2020, although at a slower rate (in percentage 
points) than towards the overall RES target. This rate needs to be increased if the EU is to meet its 
10% renewable target in transport in 202057.  

52  
53  
54  
55 

56  

57  

EUROSTAT data 
“Draft Renewable Energy Progress Report”, Öko Institute [to be published]. draft preliminary figure 
“Draft Renewable Energy Progress Report”, Öko Institute [to be published]. draft preliminary figure 
Wind, PV, CSP without storage and tidal, wave, ocean as % of total final electricity demand. Data based on JRC 
(forthcoming) analysis of 2015 Member State renewable energy progress report. 
Member  States'  compliance  with  their  indicative  trajectory  is  verified  using  Eurostat  data  on  their  renewable 
energy shares. This data is updated at the beginning of every year. 
From  2010  to  2014,  the  EU  has  increased  its  renewable  energy share  in  transport  by  1.2  percentage  points.  If  this  rate  is 
maintained, the EU renewable energy share in transport would only be 7, 1% in 2020. 

  18 

 
 
 
 
 
                                                           
In addition, the EU as a whole was 0.8 percentage points below its NREAP trajectory58 for transport 
in 201459. However, it must be taken into account that this trajectory, if met, would lead to a 11.2% 
renewable energy share in transport in 2020, higher thus than the 10% target. 

Regarding Member States' individual progress, Sweden and Finland, with 19% and 22% RES share 
in transport in 2014 respectively, were the only Member States that have already achieved the 10% 
RES transport target, whereas a large majority of other Member States (Austria, Bulgaria, the Czech 
Republic,  Denmark,  Germany,  Ireland,  Finland,  France,  Hungary,  Luxembourg,  The  Netherlands, 
Poland,  Slovakia,  Sweden)  have  achieved  at  least  5%  or  a  higher  share  of  renewable  energy  in 
transport60.  

When comparing Member States' performance against their indicative trajectory, as set out in their 
national renewable energy action plans (NREAP), only eight Member States61 are estimated to have 
met or exceeded their trajectory in 2015 (compared to six Member States in 2014).  

5.3.  Main quantitative impacts associated with the Renewable Energy Directive 

  GHG:  the  European  Environment  Agency  (EEA)  estimates  that  the  large  deployment  of 
renewable energy sources resulted in approx. 380 Mt of gross avoided CO2 emissions at EU 
level  in  201462,63.  Commission's  Joint  Research  Centre,  based  on  a  different  methodology, 
has  evaluated  substantially  higher  CO2  emission  reductions:  767  Mt  of  gross  avoided  CO2 
emissions  at  EU  level  in  2014.  More  than  65%  (512.5  Mt  CO2  eq)  of  net  GHG  emission 
savings  were  attributed  to  renewable  electricity  and  the  rest  was  coming  from  renewable 
heat/cold (29%) and transport (4%)64.  The use of renewable energy in transport resulted in 
137  Mt  of  gross  avoided  CO2  emissions  at  EU  level  from  2011  to  201465.  Most  of  these 
savings result from the use of biofuels, while only a small fraction stemmed from the use of 
renewable electricity in transport, especially in the rail sector66,67.  

  Fossil fuel displacement: renewables' production allowed the EU to cut its demand for fossil 
fuels  by  114  Mtoe  in  201468  (approximately  10  %  of  total  fossil  fuel  consumption)69,  thus 
bringing a solid contribution to the security of energy supply.  

58  

59  

60  
61  
62  
63  

64  

65  
66  
67  
68  

69  

Trajectory calculated as the average of the national trajectories set out by Member States in their national renewable energy 
action plans (NREAP). 
The current 2014 share of renewable energy sources in transport on EU-28 level is 5.9 % of gross final energy consumption, 
while the aggregated EU-28 NREAP trajectory, including electricity, would indicate a target of around 6.7 %. 
EUROSTAT data, 2014 
Austria, Finland, France, Hungary, Luxembourg,  Malta, Slovakia and Sweden 
"Renewable Energy in Europe 2016 – Recent growth and knock-on effects", EEA, 2016, No 4/2016 
This figure represents the total contribution of renewables to GHG reduction in a given year compared with the 
situation in 2005. This should not be compared with the 600-900 Mt CO2 figure in 2020 from the 2006 impact 
assessment, which has been calculated for the whole energy system.  
JRC, 2016 available at: http://iet.jrc.ec.europa.eu/remea/news/third-progress-reports-renewable-energy-
development-    eu2013-2014 
EEA, 2016. Direct emission savings, therefore not including emissions from indirect land use change. 
EEA, 2016 
"Renewable energy progress and biofuels sustainability", Ecofys, 2014 
This figure represents the total contribution of renewables to fossil fuel savings in a given year compared with 
the situation in 2005. This should not be compared with 234-300 Mtoe/year figure in 2020 from the 2006 impact 
assessment, which has been calculated for the whole energy system.  
"Renewable Energy in Europe 2016 – Recent growth and knock-on effects", EEA, 2016, No 4/2016 

  19 

 
 
 
 
                                                           
  Avoided imported fuel costs: they amounted to around €20bn in 201470,71 due to increasing 

use of renewable energy.  

  GDP growth and employment: the influence of RES-policies on GDP growth is difficult to 
isolate  and  to  compare  with  the  results  of  the  expected  impacts  in  the  2008  Impact 
Assessment, especially due to the fact that the effects of the 2007-2010 economic crisis have 
not  been  initially  factored  in.  A  first  rough  approximation,  based  on  the  volume  of 
investments and the avoided imports72, confirms that the direct influence of RES policies on 
GDP remains below 0.5% in 201473.   Employment in the RES sector has grown in the EU 
despite  the  economic  crisis.  The  EU  renewable  energy  industry  currently  employs  1.11 
million workers74, clearly surpassing the original anticipated estimates. The EU is one of the 
key global players with regard to net employment creation in the renewable energy sector. In 
2014, it had the second highest per-capita employment in the area of renewable energy sector, 
behind  Brazil.  In  the  same  year,  the  RES  industry  had  a  combined  turnover  of  144  billion 
EUR. 

  Innovation and global technology leadership: in the 2010-2015 period, renewable energy 
investment75  in  Europe  amounted  to  USD  486.1  billion  (compared  to  USD  404.4  billion  in 
China  and  USD  240  billion  in  the  United  States)76.  However,  it  must  be  noted  that 
investments  have  been  decreasing  in  Europe  since  2011,  whereas  they  are  continuously 
increasing  in  China.  In  201377,  European  companies  held  30%  of  all  patents  for  renewable 
technologies78.  

  Level  of  RES  subsidies  versus  fossil  fuel  subsidies:  independent  analysis  carried  out  in 
2014 79 estimated that total public support to coal and natural gas amounted to EUR 16 billion 
in 2012 in the EU, against EUR 11 billion for solar and wind energies combined. The public 
support to renewable energy has been increasingly integrated in the market, especially in the 
light of the Commission's Guidance for the design of renewables support schemes80, as well 
as  the  Guidelines  on  State  Aid  for  Environmental  Protection  and  Energy  2014-2020  (2014 
EEAG)81.  A recent EEA report82 identified that, in the European Economic Area countries 
(28-EU Member States, 4 EFTA (European Free Trade Association) countries and Turkey), 
fossil fuels continue to receive 53.3% of public support, whereas renewable energy (including 

70  
71  

72  
73   

74  
75  
76  
77  
78  
79  
80  

81  
82  

“Draft Renewable Energy Progress Report”, Öko Institute [to be published] 
This figure represents the total contribution of renewables to fossil fuel import savings in a given year compared 
with the situation in 2005. This should not be compared with 50-57 billion EUR/annum from the 2007 impact 
assessment, which has been calculated for the whole energy system 
Based on EEA, PRIMES and EUROSTAT 
This  figure  has  to  be  considered  carefully  and  as  gross  effect,  since  it  doesn't  factor  in  the  reduction  of 
investment in conventional generation and other variables 
EurObserv'ER, 15th Eurobserv'ER report, 2015. 2014 figure 
Data include government and corporate R&D 
"Renewables 2016 Global Status Report", REN21.2016 
Latest data available 
OECD Statistics database 
"Subsidies and costs of EU energy", Ecofys, 2014 
"Commission Staff Working Document - European Commission guidance for the design of renewables support 
schemes",  SWD(2013) 439 final 
"Guidelines on State aid for environmental protection and energy 2014-2020", OJ 2014/C 200/01 
"Energy  support  measures  and  their  impact  on  innovation  in  the  renewable  energy  sector  in  Europe",  EEA 
Technical report, No 21/2014 

  20 

 
 
 
 
                                                           
biofuels)  obtains  40.5%  of  the  public  support83.  Accordingly,  the  EEA  report  indicated  that 
the  support  aimed  at  renewable  energy  did  not  alter  the  competitive  position  between 
renewables and fossil fuels.  

6. 

ANSWERS TO EVALUATION QUESTIONS 

This  section  summarises  the  main  findings  in  relation  to  the  analysis  of  each  of  the  evaluation 
questions.  Most  questions  are  dealt  with  individually,  although  a  few  have  been  combined,  where 
there are significant overlaps in the information and evidence provided. 

6. 1. 

Effectiveness 

With  regard  to  effectiveness,  there  is  a  straightforward  measurable  indicator  included  in  the  2009 
RES  Directive  against  which  progress  can  be  measured:  the  national  binding  targets.  A  maximum 
effort  will  be  made  to  try  to  determine  which  elements  of  the  Directive  have  probably  made  the 
largest  contributions  to  this  indicator.  The  Directive,  however,  does  not  include  other  measurable 
objectives with regard to more specific provisions in the Directive. Therefore, the success of other 
provisions such as infrastructure development (Art 16), Guarantees of Origin (Art. 15), cooperation 
mechanisms  (Art.  6-11)  is  evaluated  more  qualitatively,  drawing  on  studies  and  complemented  by 
stakeholder feedback.  

6.1.1.  Has the RES Directive been effective in achieving the binding EU renewable energy target 
of  20%  by  2020,  and  the  Member  State  national  binding  renewable  energy  targets  for 
2020? Do implementation and enforcement challenges and failures exist? If yes, where and 
why? 

As  a  key  pillar  of  European  decarbonisation  policies84,  the  RES  Directive  as  a  whole  has  been 
effective  in  ensuring  that  the  EU  and  its  Member  States  are  on  track  towards  their  2020  binding 
renewable energy targets. With a 17% estimated RES share in 2015, the EU is expected to reach its 
20%  in  2020.  Only  one  Member  State  failed  against  its  2013/2014  interim  target.  This  is  a 
considerable  improvement  when  compared  to  the  situation  prior  to  the  adoption  of  the  2009  RES 
Directive, when only two85 Member States were in a position for reaching both their indicative RES 
targets for electricity and for transport86.  

The  renewable  energy  deployment  in  the  EU  and  in  the  individual  Member  States  has  been 
considerable: the cumulative growth in the EU RES share between 2010 (when the Directive came 
into  force)  and  2015  has  been  almost  7%87.    Effectiveness  has  been  relatively  higher  in  Member 
States with historically low starting points and low initial ambition levels (one could observe 50 % 
increases e.g. in Belgium, Luxembourg and The Netherlands, and more than doubling in the United 

83  

84  

85  

86  
87  

The  report  indicates  that  the  remaining  6%  of  public  support  targets  electricity  and/or  heat  production  and 
consumption, without specifying which energy source 
See on the complementary fucntions of the European Emissions Trading Scheme (ETS) and the RES Directive 
below, Section 6.4 
Only  7  Member  States  were  expected  to  achieve  their  2010  targets  for  renewable  energy  in  electricity 
generation; likewise, only 9 were expected to achieve their targets for renewable energy in transport. Only two 
Member  States  were  in  these  two  categories,  "Renewable  Energy:  Progressing  towards  the  2020  target", 
COM/2011/31 final 
"Renewable Energy: Progressing towards the 2020 target", COM/2011/31 final 
From 12.8% in 2010 to 17.0% in 2015, ESTAT and “Draft Renewable Energy Progress Report”, Öko Institute 
[to be published], draft preliminary figure 

  21 

 
 
 
 
                                                           
Kingdom). On the other hand, in countries like Austria, Denmark, Finland and Sweden, where RES 
historically had already played an important role in the energy mix, their absolute growth88 was more 
pronounced. 

The fact that, so far, an overwhelming majority of Member States is on the right trajectory does not 
mean  that  target  achievement  by  2020  is  certain  and  secure as  e.g.  the  trajectories  become  steeper 
after 2015 and RES investments in the EU have slowed recently. It is important to note as well that 
Eurostat official data is published with a two-year delay89. As Member State progress assessment is 
based  on  Eurostat  data,  anticipating  judgments  based  on  data  projections  should  be  done  with  due 
caution.  

The  above  trend  clearly  shows  that  the  2009  RES  Directive  has  strengthened  national  action  and 
efforts in renewable energy promotion across all Member States, in contrast to the previous EU legal 
framework (Directive 2001/77/EC and Directive 2003/30/EC), that was relying on indicative targets 
which triggered development of renewables in some Member States, whilst not preventing Member 
States with lower ambition to lag behind, thus also hindering target achievement at EU level.  

National Renewable Energy Action Plans and progress reports 

The  National  Renewable  Energy  Action  Plans  and  the  biennial  monitoring  exercise90  were 
considered  effective  in  increasing  transparency  and  clarity,  and  allowed  effective  monitoring  of 
progress  towards  the  2020  targets  set  in  the  RES  Directive  by  the  Commission.  As  of  today,  all 
Member States have national renewable energy planning policies in place, as opposed to the limited 
number of dedicated national level RES strategies in Member States back in 2007, when the outline 
for the new legally binding EU renewable energy framework was laid out in the Renewable Energy 
Roadmap.  The standard templates for planning and reporting minimised administrative burden for 
national reporting authorities, ensured maximum comparability and were considered best practice by 
half of the NGOs and almost a third of cooperatives participating in the public consultation on the 
revision  of  the  RES  Directive,  in  addition  to  the  vast  majority  of  stakeholders  taking  part  in  the 
public consultation on streamlining of planning, reporting and monitoring obligations as part of the 
Energy Union Governance initiative (for more details see REFIT on energy reporting91). However, 
some  NGOs  pointed  out  that  national  plans  would  have  been  more  effective  if  they  had  taken 
environmental sustainability and impacts into consideration, have had a spatial dimension and have 
had  to  be  periodically  updated92.  Indeed,  by  2015,  the  National  Renewable  Energy  Action  Plans 
became  outdated  as  policies,  market  circumstances  and  other  variables  had  changed  over  time. 
However, this limitation has been largely mitigated by the biennial Member State renewable energy 
progress  reports  that  provided  regular  updates  on  Member  State  regulatory  and  support  policies  in 
the field of renewable energy and which are essentially based on the same template as the National 
Renewable Energy Action Plans.  

Use of cooperation mechanisms 

88  
89  

90  

91  

92  

In Mtoe or pp 
"Renewable  energy  progress  report",  2015,  COM(2015)  293  final  and    "State  of  the  Energy  Union  Report", 
2015 
National Renewable Energy Action plans and biennial national renewable energy progress reports are legal  
requirements set out in Art. 4 and Art.22 of the Renewable Energy Directive  
Fitness  check  of  the  Reporting,  Planning  and  Monitoring  Obligations  in  the  EU  energy  acquis.  Reference 
number to be added when this REFIT is adopted 
"Public  consultation  on  the  Renewable  Energy  Directive  for  the  period  after  2020:  Analysis  of  stakeholder 
views", 2016 

  22 

 
 
 
 
                                                           
  
Flexibility and cooperation mechanisms (Art. 6-11) as means to facilitate cost effective RES target 
achievement  have  so  far  only  partially  been  used.  An  early  attempt  by  the  UK  and  Ireland  to 
conclude  an  agreement  on  an  ambitious  wind  energy  joint  project  was  shelved  in  2013  amid 
uncertainty on its financial support93. The Swedish and Norwegian joint green certificate scheme (not 
based  on  Guarantees  of  Origin),  in  place  since  2012,  has  constituted  the  only  renewable  energy 
cooperation mechanism (as set out in the RES Directive) in use so far.   

In July 2016, Denmark and Germany signed an agreement on the mutual opening of auctions for PV 
installations 94. In addition, at least two other Member States are considering partial opening of their 
support  schemes,  and  at  least  four  Member  States  are  currently  in  cooperation  agreement 
negotiations for statistical transfers, with a view of concluding such agreements in 2016 and 2017.  

Such delay in the use of cooperation mechanisms is partly due to the fact that 2011/2012, 2012/2013 
and 2015/2016 interim targets were set at relatively low levels and, for that reason, there was no need 
for  Member  States  to  make  use  of  those  tools  yet.  However,  as  the  trajectory  grows  steeper  after 
2015, this is very likely to change shortly. Many of the Member States interviewed for a study on 
cooperation  mechanisms95  in  2013  indicated  that  they  might  consider  applying  cooperation 
mechanisms in the future.  

Public  consultation  results  reveal  reluctance  to  see  taxpayers  or  consumers'  money  used  for 
investments  abroad96  and/or  uncertain  benefits  for  individual  Member  States97  as  main  reasons  for 
the limited use of cooperation mechanisms. Indeed, the majority of respondents within two thirds of 
the stakeholder groups, including RES industry, support such view, arguing that benefits in the form 
of  employment,  economic  and  industry  growth,  tax  income  and  security  of  supply  are  thus  not 
created  within  own  country.  Finally,  amongst  the  factors  that  hindered  their  uptake,  stakeholders 
cited the fact that RES cooperation mechanisms were government, not market driven process.98  

Current  barriers  may  be  overcome  by  providing  Member  States  with  further  information  on  long-
term cost-efficiency benefits of cooperation and better guidance on design options and cost-benefits 
measurements methods. Stronger incentives for regional cooperation, such as financial ones, or the 
establishment of an obligation to partially use these mechanisms would likely be more effective.  

The role of the Guarantees of Origin (GOs)  

The  system  of  Guarantees  of  Origin  provides  a  means  of  guaranteeing  the  origin  of  electricity 
produced from renewable sources, as a means of proving to final consumers the share of renewable 
energy  in  a  suppliers  mix.    The  system  as  adopted  in  the  2009  Directive  was  not  intended  as  a 
support scheme to promote the uptake of renewable electricity99, nor to serve as an optional tool for 
Member States to enable renewable electricity capacity in another Member State to be counted for 

93  

94  
95  
96  
97  
98  
99  

The  two  countries  signed  a  memorandum  of  understanding  in  January  2013.  The  aim  was  to  establish  an 
intergovernmental agreement on energy trading, to be signed in 2014 
See: http://www.bmwi.de/DE/Themen/Energie/Erneuerbare-Energien/pilot-oeffnung-fuer-eu-staaten.html. 
"Cooperation between EU Member States under the RES Directive", Ecofys, 2013 
94% of public consultation respondents cite this factor as important or very important 
90% of public consultation respondents cite this factor as important or very important 
77% of public consultation respondents cite this factor as important or very important 
There are no published indices of GOs prices but GOs have a relatively low value, generally trading for under a 
Euro for each MWh of electricity. One publically available source is the results of the auctions made by GME 
which  sells  GOs  on  behalf  of  the  Italian  Government.    Prices  achieved  in  the  three  2016  auctions  averaged 
between 15-29 cents per MW/h. 

  23 

 
 
 
 
                                                           
target compliance, both of which were the original intention set out  in the Commission's proposal. 
Guarantees  of  Origin  are  used  in  some  Member  States  as  a  transferable  scheme  to  meet  the  legal 
requirements of the Electricity Market Directive (Directive 2009/72/EC) for disclosure that require 
electricity  suppliers  to  inform  their  customers  about  their  energy  mix100.  However,  there  is  no 
obligation  for  Member  States  to  make  use  of  GOs  mandatory  for  disclosure  purposes,  effectively 
resulting in a non-harmonised situation in the EU.  

GOs are traded  separately  from the physical flows of renewable energy. At the  EU level, the GOs 
systems exist for electricity produced from renewable sources under the Renewable Energy Directive 
and from high efficiency combined heat and power (CHP)101 under the Energy Efficiency Directive, 
but do not cover other energy sources. Some Member States, notably Austria and Sweden, have gone 
further than EU law to implement a GO system that covers all sources of electricity generation. It is 
important  to  note  that  not  all  renewable  electricity  (RES-E)  production  comes  with  GOs  since 
guarantees of origin were not issued for electricity covered by support mechanisms in order to avoid 
double compensation. To address this, Italy has developed a system of auctioning the GOs associated 
with supported production.  The EU GO system also applies to the EEA-EFTA countries.   

GOs have  helped  to  bring about limited product-based innovation  in  the  EU power market. Today 
one can usually see two types of offers across the EU: conventional production contracts and the so 
called "green offers". The latter are normally backed up by suppliers purchasing GOs on top of the 
separate  purchase  of  electricity  (of  any  source).  While  the  guarantee  of  origin  market  is  still 
developing in countries such as Portugal and the United Kingdom, where it approximately represents 
only 0.5% of the retail market, in Belgium it already covers 13.36% of electricity contracts and in 
Austria and The Netherlands nearly all supply contracts to households are GO based102.  

The  fact  that  GOs  are  disconnected  from  the  physical  flow  of  electricity  allows  suppliers  to  offer 
"green" contracts by purchasing guarantee of origin anywhere in the EU, even if the local electricity 
generation  mix  is  not  renewable.  This  could  be  perceived  as  creating  a  discrepancy  between  the 
product bought by the customer and the information provided on the production mix of the electricity 
supplier if they own and operate generation assets. Such perception is confirmed by stakeholders in 
the public consultation who highlighted low consumer awareness of the guarantee of origin system, 
pointing to the need for more transparency and accuracy (quoted in 36% of stakeholder replies). This 
can be regarded as an issue that the Renewable Energy Directive did not resolve. A full mandatory 
disclosure  system  coupled  with  a  requirement  for  suppliers  to  purchase  an  equal  amount  of 
guarantees of origin to match their supplied electricity could help to reinforce the guarantee of origin 
system  and  the  attributes  given  to  the  various  energy  sources,  thereby  making  the  system  more 
meaningful. Whilst 40% of public consultation respondents supported the idea of issuing GOs to all 
electricity sources, including non-renewable sources, 42% of respondents – notably think tanks and 

100  

101  
102  

The legal basis for the GO system is split across a number of pieces of legislation, where the RES Directive sets 
out a framework for GOs for renewable electricity for the purpose of disclosure and Directive 2012/27/EC on 
energy efficiency creates guarantees of origin for high efficiency co-generation but does not prescribe a use for 
them.  Use  of  GOs  is  driven  in  part  by  energy  disclosure  requirements  set  out  in  Article  3(9)(a)  of  Directive 
2009/72/EC  on  the  internal  market  for  electricity  requiring  a  supplier  to  specify  to  final  consumers  the 
contribution of each energy source to the overall fuel mix of the supplier.  This information must be reliable.  It 
does not specifically mention that GOs are to be used to achieve this, so it gives flexibility for other methods to 
be used. In addition, the Unfair Commercial Practices Directive (2005/29/EC) provides protection to consumers 
and prohibits traders from creating a false impression of the nature of products.  It also requires that information 
provided is specific, accurate and unambiguous 
For CHP only SE has a GO scheme in place 
CEER "Public Consultation Paper on Advice on green electricity", 2013 

  24 

 
 
 
 
                                                           
the RES industry – supported the idea of extending the GO system to other energy carriers such as 
green  gas  and  green  district  heating.  Around  24%  of  respondents  were  of  the  opinion  that 
information  on CO2  emissions should be added  in  the GO system to  create more awareness of the 
impacts of electricity consumption. 

The 2009 RES Directive helped to standardise the GO systems for electricity throughout the EU and 
clarified  their  rules,  reducing  risk  of  fraud  and  inaccuracies.  It  is  required  that  each  and  every 
Member State recognises Guarantees of Origin issued by another Member State. A common hub, the 
Association of Issuing Bodies, has been developed by Member States to enable such recognition and 
transfers. The role of the Association of Issuing Bodies (AIB) and the use of a system compliant with 
the European Energy Certificate System (EECS) are important in underpinning the integrity of GOs 
as internationally traded commodities. However, not all Member States are yet connected to the AIB 
hub or apply the EECS system.  

Although  significant  progress  has  been  made  since  2009  RES  Directive  came  into  force,  there  are 
still  varying  levels  of  implementation  across  Member  States  in  terms  of  system  coverage,  system 
features  and  the  extent  to  which  Guarantees  of  Origin  are  issued  and  traded.  Prior  to  the  2009 
Renewable Energy Directive, some Member States used GOs for disclosure purposes, while others 
simply  recommended  such  practice,  or  still  used  them  to  qualify  for  support  schemes.  Despite  the 
strengthened  requirements  in  the  RES  Directive,  large  variations  in  the  interface  between  the 
issuance of GOs and Member State national support schemes still remain across the EU. 

Self-consumption 

Policies in several Member States have provided incentives for energy  consumers to generate their 
own electricity. Although no official statistics on self-consumption in the EU and Member States is 
currently  available,  it  is  estimated  that  photovoltaic  systems  installed  in  the  residential  sector 
represented  about  18%  of  the  total  PV  electricity  production  in  2014103.  The  lack  of  specific 
provisions  on  self-consumption  in  the  RES  Directive  gave  Member  States  wide  discretion  to  deal 
with this emerging development. This resulted in a broad range of different policies across Member 
States and fragmentation of the market.  

Respondents  to  the  public  consultation  on  the  RES  Directive  considered  that  the  most  important 
barriers to self-consumption were the following: surplus electricity that is not self-consumed onsite is 
not valued fairly104; complex and/or lengthy administrative procedures, particularly penalising small 
self-consumption  systems105;  and  the  design  of  electricity  tariffs106.  National  grid  charges  for  self-
consumption applied in Member States  do not often find an appropriate balance between the costs 
for the use of the grid and the benefits of self-consumption. 

The  revised  RES  Directive  will  have  to  assess  the  need  for  framework  principles  on  self-
consumption at the EU level.  

103  

104  
105  
106  

DG ECFIN, Draft "Report on investments in solar panels in the residential sector in EU Member States", to be 
published in Q4 2016. 
79% respondents consider this barrier important or very important 
79% respondents consider this barrier important or very important 
78% respondents consider this barrier important or very important 

  25 

 
 
 
 
                                                           
6.1.2.  Has  the  RES  Directive  effectively  led  to  better  planning  and  streamlining  of  the  approval 

and licensing procedures for RES producers at national and local level?  

Long  waiting  times  ranging  from  a  minimum  of  one  to  a  maximum  of  twelve  years  for  planning, 
licensing  and  permitting  procedures,  also  in  relation  to  grid  connections,  were  already  noted  as  a 
clear obstacle to renewable energy investments in the 2008 Impact Assessment. Therefore the 2009 
RES  Directive  required,  in  its  Art.  13(1),  that  regulatory  procedures  are  "proportionate  and 
necessary",  but  without  further  detailing  how  to  accomplish/assess  conformity.  Member  States  are 
also  required  to  ensure  that  national  and  local  authorities  in  charge  of  permit-granting  coordinate 
their  work  and  ensure  timely  and  transparent  treatment  of  permit  requests.  Simplified  and  less 
burdensome  approaches  are  encouraged  for  smaller  projects  and  decentralised  RES  devices 
(conditional to national regulations allowing such simplified procedures). 

The  REFIT  evaluation  study  indicated  that,  despite  the  reinforcement  of  provisions  related  to 
administrative simplification, compared to those that were already in place as a result of the previous 
Renewable  Electricity  Directive  (Directive  2001/77/EC),  these  provisions  were  only  partially 
effective  in  reducing  the  length  of  authorisation  procedures  for  RES  projects,  and  an  important 
number of administrative steps had been taken by promoters to have their projects approved.  

Despite existing awareness of clear benefits stemming from a one-stop authorisation point at national 
level,  the  RES  Directive  did  not  include  this  measure  as  a  mandatory  requirement107,  leaving  its 
establishment in the hands of Member States. The Directive (Art. 22) only required Member States 
to report in their first 2011 biennial renewable energy progress reports on their intentions to establish 
a  "one-stop  authorisation  agency"  for  renewable  energy  project  approvals.  In  2013  and  2015 
reporting  cycles,  the  majority  of  Member  States  noted  continuous  improvements  with  respect  to 
simplification  of  administrative  procedures.  However,  and  despite  visible  improvements,  these 
measures  are  still  perceived  as  inadequate  to  the  majority  of  RES  industry  and  project  developers. 
Only ten Member States in 2014 had "one-stop shop" for RES projects approvals in place108.  

The  REFIT  evaluation  study  confirmed  that  despite  continuous  improvements  in  the  majority  of 
Member States109, lengthy administrative procedures still act as barriers to investment. This is mainly 
occurring  due  to  complex  licensing  procedures,  unclear  administrative  responsibilities,  multiple 
bodies involved, municipalities involved without clear rules set for their responsibilities at national 
level  and  lack  of  one-stop  shops110.  With  rapidly  decreasing  technology  costs,  the  costs  stemming 
from administrative procedures are proportionally gaining weight and can, in some cases, represent 
up to 15% of the overall development costs of projects like the wind sector111.  

Administrative barriers can also create distortions in the allocation of investments within the EU, and 
therefore hamper the building up of a unified market for renewable energy and reaching cost-optimal 
RES deployment. Despite the existing best practice sharing among Member States in the Concerted 
Action for the RES Directive, only practices like online application and maximum time-limits (and, 

107  
108  
109  

110  

111   

SEC (2008) 85 Vol. II 
“Draft Renewable Energy Progress Report”, Öko Institute [to be published] 
See "Renewable energy progress report", 2015, COM(2015) 293 final, and CE Delft , "Mid-term evaluation of 
the  Renewable  Energy  Directive.  A  study in  the  context  of  the  REFIT Programme",  2015,  and Öko  Institute, 
"Report on Renewable Energy" [to be published] 
In some cases, administrative procedure can delay RES projects by many or even years (for example, in Italy, 
France  and  Cyprus  large  RES  projects  can  take  up  to  seven  years  to  get  permits).  CE  Delft  ,  "Mid-term 
evaluation of the Renewable Energy Directive. A study in the context of the REFIT Programme", 2015 
“Draft Renewable Energy Progress Report”, Öko Institute [to be published] 

  26 

 
 
 
 
                                                           
to  a  lesser  extent,  automatic  permission  after  deadline  passed)  have  seen  substantial  progress 
between 2010 and 2014. In the meantime, as shown in the graph below, other relevant barriers still 
remain. As a result, lead times for renewable energy project development differ significantly across 
Europe.  For  major  technologies,  like  onshore  wind,  permitting  processes  can  last  from  less  than  5 
weeks in  Denmark, to  3-7 months  in  Germany and up to  a  maximum  of 7 years in some southern 
European Member States. This creates significant barriers to internal market and investments. 

The  Commission  has  received  a  number  of  complaints  on  Art.13  (1),  citing  unclear  allocation  of 
competences  between  national  and  local  levels  and  arbitrary  permit  granting  practice  in  some 
Member  States.  However,  due  to  the  large  discretion  margin  given  in  Art.  13  (1)  and  the  lack  of 
more detailed requirements, these cases have not resulted in legal action against any Member State.  

Figure 3:  Overview of administrative barriers in 2010 and 2014 (% of Member States) 

Source: “Renewable Energy Progress Report”, Öko Institute [to be published] 

The "one-stop-shop" approach, including clear provisions on single administrative decision and clear 
rules on "single entry point", is applied since 2013 to energy projects of common interest112 and has 
been  noted  as  best  practice113.  The  Commission  has  committed  to  exploring  the  possibility  of 
designing  a  single  EU  authorisation  framework  for  large  investment  projects,  while  also  clearly 
noting  a  need  for  further  action  to  tackle  investment  bottlenecks,  such  as  regulatory  and 
administrative barriers and cumbersome and lengthy approval procedures, at national level.114  

Similar  to  administrative  barriers,  concerns  arise  when  it  comes  to  grid  access  procedures  for 
renewables (Art.16).  

Figure 4: Overview of barriers for grid integration in 2010 and 2014 (% of Member States) 

112  
113  
114  

Regulation 347/2013 on guidelines for trans-European energy infrastructure  
"Europe investing again: Taking stock of the Investment Plan for Europe and next steps", COM (2016) 359 final 
"Europe investing again: Taking stock of the Investment Plan for Europe and next steps", COM (2016) 359 final 

  27 

0%10%20%30%40%50%60%70%80%90%100%2010 - present2010 - partly present2012 - present2014 - present2014 -partly presentOne Stop Shop not implementedMissing online applicationNo maximum time limit for proceduresNo automatic permission after deadline passedNo facilitated procedures for small-scale projectsNo dedication of geographic sites 
 
 
 
 
                                                           
Source: “Renewable Energy Progress Report”, Öko Institute [to be published] 

It can be seen that the number of States with the barriers "Lack of stakeholder communication" and 
"Long lead times" increased between 2010 and 2012, while the other barriers remained on a similar 
level. However, in 2014, a smaller number of severe barriers can be observed. "Long lead times" and 
the "Lack of grid capacity" were present in a smaller number of States compared to previous years. 
Also, an obligation to connect was introduced in five Member States. 

The REFIT evaluation study identified ‘lengthy procedures or delays, lack of grid capacity, complex 
procedures and a weak legal position of plant operators’ as the main barriers for RES integration in 
the  electricity  grids.  Stakeholder  interviews  carried  within  this  study  equally  noted  concerns  about 
the duration and complexity of the process and requirements from network operators for new RES 
producers and lack of grid capacity. Regarding grid access, it was indicated that there were inter alia 
no  priority  access,  which  leads  to  curtailment  and  even  discrimination  against  RES.  Most  of  the 
Member States identified a need for investment both in distribution and transmission grids.  

6.1.3.  Has the RES Directive been effective in achieving the binding 10% renewable energy target 

in transport by 2020?  

The Directive established a separate RES target for transport at the same 10% level for all Member 
States,  thus reflecting the  shared  need  to  reduce  reliance  on  fossil  fuels  in  the transport  sector  and 
presuming  that,  in  the  absence  of  a  separate  RES  transport  target,  the  market  alone  would  fail  to 
develop  the  sector.  This  required  significant  renewable  energy  deployment  efforts  in  the  transport 
sector  in  all  the  Member  States.  The  Directive  was  successful  in  its  encouragement  of  blending 
mandates in the vast majority of the Member States. 

Nevertheless, it is too soon to assess if the RES Directive has been effective in achieving the uniform 
10% renewable energy target in transport. This target must be met by 2020 and there is no binding 
trajectory  against  which  Member  States'  current  performance  can  be  compared.  Even  if  there  are 
national  indicative  trajectories  set  out  by  Member  States  in  their  NREAPS,  they  cannot  be  used 
either to assess progress towards the 10% target since these trajectories, if respected, would lead to a 
higher share of renewable energy in transport. 

  28 

0%10%20%30%40%50%60%70%80%90%2010 - present2012 - present2014 - present2014 - partly presentLack of stakeholder communicationLack of grid capacityLong lead timesNo obligation to connect 
 
 
 
 
As  noted  in  Section  5,  with  a  6.2%  estimated  share  of  renewable  energy  in  transport  in  2015 
(compared  to  4.9%  in  2010),  it  can  be  argued  that  the  EU  is  moving  towards  the  10%  target. 
However, this target will not be met unless the EU progress rate towards the 10% target is increased. 
The main reason for this slow progress has been, on the one hand, the regulatory uncertainty caused 
by  several  factors,  such  as  the  long  political  discussion  on  ILUC,  the  late  adoption  of  the 
amendments on ILUC to the RES Directive and the lack of a post-2020 policy for transport, and, on 
the other hand, the lack of commercial availability of alternative fuels and advanced biofuels at the 
needed scale and pace. 

By  excluding  the  production  of  biofuels  on  areas  of  high  biodiversity  and  carbon  value,  the  EU 
biofuels  criteria  avoided  some  risks  of  direct  environmental  impacts  of  biofuel  production115  – 
impacts  that  can  be  measured  and  managed  directly  at  project/farmers  level116.    The  sustainability 
criteria  also  contributed  to  improving  the  GHG  performance  of  biofuels  (e.g.  from  the  field  to  the 
tank)  through  the  setting  of  minimum  GHG  saving  targets  (e.g.  35%  savings  compared  to  fossil 
fuels). As of today, biofuels achieve often more than 60% of direct GHG emission savings117.  

However,  in  some  cases,  sustainability  criteria  may  have  been  misused  by  Member  States  for 
protectionist measures (e.g. favouring certain feedstocks to the disadvantage of imported ones). This 
led to complaints and legal proceedings at national and European level against some Member States. 

While the Renewable Energy Directive initially anticipated potential indirect effects from increased 
biofuel production related to indirect land-use (ILUC) and included additional incentives to address 
this issue118, it did not introduce measures that would sufficiently address the ILUC effects, which 
could limit the GHG reduction benefits of food-based biofuels. This regulatory failure was addressed 
with  the  adoption  of  the  2015  ILUC  amendments119.  Trying  to  address  such  indirect  risks  by 
including quantitative ILUC factors in the EU GHG methodology is widely considered too uncertain 
(mainly because ILUC is not exactly measurable since it is unobservable) and complex (e.g. factors 
could  change  depending  on  modelling  assumptions),  and  would  possibly  cause  further  investors 
uncertainty. This was the reason behind the 7% cap on food-based biofuels introduced through the 
ILUC  amendments  to  the  RES  Directive.  Furthermore,  as  foreseen  in  the  Directive,  the  GHG 
performance of biofuel production can be further improved by raising the GHG saving threshold for 
new installations, while protecting those installations already in operation on 1 July 2014. The long 
and  technically  complex  inter-institutional  discussion  on  ILUC  amendments120  ultimately  created  a 
considerable degree of uncertainty in the market, preventing investments in both food-based biofuels, 
as well as in advanced biofuels. The impact of the indicative sub-target for advanced biofuels which 
was introduced with the ILUC amendments will only become visible in the coming years. 

115  

116  

117  

118  
119  

120  

The Fitness Check of EU Nature Legislation mentions the sustainability criteria for biofuel production as one of 
the  EU  policies  aimed  at  preventing  biodiversity  loss.  Some  stakeholder  groups  in  that  Fitness  Check,  noted, 
among other, the lack of similar provisions for biomass used in non-transport applications as a major gap 
The impact of EU consumption on deforestation: Comprehensive analysis of the impact of EU consumption on 
deforestation, VITO, CICERO, IIASA, 2013 
Bundesanstalt für Landwirtschaft und Ernährung, Biokraftstoffe: 60 Prozent Treibhausgasminderung und höher 
nachweislich erfüllt 
Recital (85), Articles 18 (4) and 19(6) of the Directive 2009/29/EC 
Directive  (EU)  2015/1513  amending  Directive  98/70/EC  relating  to  the  quality  of  petrol  and  diesel  fuels  and 
amending  Directive  2009/28/EC  on  the  promotion  of  the  use  of  energy  from  renewable  sources.  OJ  L  239/1, 
15.9.2015 
The Commission presented the proposal for the Directive amending Directive 98/70/EC relating to the quality of 
petrol  and  diesel  fuels  and  amending  Directive  2009/28/EC  on  the  promotion  of  the  use  of  energy  from 
renewable sources on 17 October 2012. This Directive was adopted almost two years later, on 9 September 2015 

  29 

 
 
 
 
                                                           
The biennial monitoring and reporting requirements of the Member States and the Commission, as 
well  as  the voluntary  certification  schemes  recognised  by  the  Commission  have  overall  effectively 
helped to address additional environmental, economic and social sustainability issues related to the 
production of biofuels and bioliquids that cannot easily be linked to individual consignments, nor be 
addressed in isolation from other policies and legislation.  

Specific  requirements  on  the  impacts  on  water,  air  and  soil  protection,  as  well  as  social  issues, 
including  human  rights  and  land  use  rights  or  food  security,  have  increased  the  awareness, 
information  and  data  availability  in  the  EU  Member  States.  This  has  played  in  favour  of  greater 
cooperation at the national and EU levels with third countries on sustainability issues.121  

Most  of  the  voluntary  certification  schemes  recognised  by  the  Commission  and  active  in  third 
countries address environmental and social issues, thus contributing significantly to the improvement 
of a global sustainability framework for the production of biofuels and bioliquids. The sustainability 
certification has been established as a new norm in the industry globally. Sustainability criteria for 
biofuels have evolved at world level mainly through voluntary certification schemes compliant with 
legislation  adopted  in  major  markets,  including  in  the  European  Union,  and  principally  due  to  the 
RES Directive.122  

The 2009 RES Directive did not include harmonised EU level sustainability rules for biomass used 
for generating power or heating. In absence of clear rules at the EU level, Member States introduced 
such  sustainability  requirements  at  national  level.  In  2010,  the  Commission  issued  non-binding 
recommendations to Member States on sustainability criteria for solid and gaseous biomass123.  

Stakeholders  have  raised  two  types  of  concerns  in  view  of  the  fact  that  no  harmonisation  of 
sustainability criteria exists at the EU level for solid and gaseous biomass. First, the increased use of 
biomass, particularly for power generation, may lead to  negative sustainability impacts both  in the 
EU  but  especially  in  third  countries  producing  biomass  feedstock  for  the  EU.  Second,  the  lack  of 
sustainability rules may result in the fragmentation of the internal market.  

In 2014, the Commission published a report reviewing the state of play of sustainability of solid and 
gaseous  biomass124.  The  Commission  decided  not  to  introduce  EU  binding  sustainability  criteria 
given  that  the  vast  majority  of  the  biomass  used  in  the  EU  for  heat  and  power  was  considered  to 
provide  significant  GHG  savings.  However,  the  report  acknowledged  that  further  research  was 
needed on a number of biomass pathways which could lead to negligible or negative GHG savings or 
other sustainability impacts. The report also found that there was limited risk of barriers to trade of 
biomass  in  and  to  the  EU,  although  existing  EU  legislation  could  for  the  time  being  prevent  such 
barriers stemming from diverging national sustainability standards. However it did not exclude the 
possibility of such barriers developing in the future as a result of increasing trade in biomass. 

Furthermore,  it  should  be  noted  that  under  the  RES  directive,  the  same  feedstock  (e.g.  maize  or 
wood) is subject to EU sustainability criteria if it is used for biofuel production while it is exempted 
from  compliance  with  such  criteria  if  it  is  used  for  heat  and  power  generation.  A  number  of 
stakeholders have highlighted this issue and called for coherent land use criteria to apply to the same 

121  
122  

123  
124  

"EU 2013 Report on Policy Coherence for Development (PCD), 2013 
UNCTAD, "Second-Generation Biofuels Markets: State of Play, Trade and Developing Country Perspectives", 
2016 
COM(2010)11 final 
SWD(2014)259 final 

  30 

 
 
 
 
                                                           
feedstocks,  regardless  of  their  final  energy  use  (e.g.  heating/cooling,  electricity  and  biofuels  for 
transports). 

Finally, the regulatory uncertainty over sustainability rules for biomass for heat and power created a 
risk  for  the  energy  industry  in  sourcing  fuel  supplies  and  a  potential  financing  risk  for  bioenergy 
project developers.  

6.1.4.  Has the RES Directive triggered sufficient progress in RES deployment in the heating and 

cooling sector, which was previously not covered by renewable energy targets? 

It  has  only  been  since  2009  that  the  RES  Directive  has  regulated  the  use  of  renewable  energy  in 
heating and cooling sector and buildings, unlike electricity and transport promotion measures, which 
were  already  in  the  scope  of  the  preceding  EU  legislation.  The  RES  Directive  required  Member 
States,  through  the  adoption  of  National  Renewable  Energy  Action  Plans,  to  lay  down  sectorial 
targets for each of the three relevant sub-sectors, including heating and cooling. In addition, Articles 
13 (4-6) and 16 (9) and 16 (11) required Member States to effectively promote the use of renewables 
in  new  and  renovated  buildings,  in  heating  systems,  and  in  local  energy  infrastructure,  including 
district  heating.  The  use  of  renewable  energy  in  the  heating  and  cooling  systems  and  buildings  is 
further  (indirectly)  promoted  by  the  Energy  Performance  for  Buildings  Directive125  and  Energy 
Efficiency Directive126.  

Given  that  heating  and  cooling  represents  nearly  half  of  the  EU  final  energy  use127,  it  is  not 
surprising  that  the  highest  deployment  in  renewable  energy  from  2004  to  2014  comes  from  the 
heating and cooling sector128. 

Figure 5: EU renewable energy deployment by sector 2004-2015 (Mtoe) 

125  
126  
127  
128  

OJ L 153, 18.6.2010, p. 13–35 
OJ L 315, 14.11.2012, p. 1–56 
"An EU Strategy for Heating and Cooling", COM (2016) 51 final 
“Draft Renewable Energy Progress Report”, Öko Institute [to be published] 

  31 

 
 
 
 
                                                           
Source: “Renewable Energy Progress Report”, Öko Institute [to be published] 

However, this growth should be considered in relation to the remaining fossil fuel use in the heating 
and  cooling  sector,  which  still  stands  at  nearly  75%.  Only  about  18%  of  the  current  EU  fuel 
consumption  in  the  heating  and  cooling  comes  from  renewable  energy,  of  which  86  %  from 
bioenergy  alone129.  Most  of  this  bioenergy  is,  as  of  2015,  sourced  within  the  EU,  with  bioenergy 
imports accounting for less than 5% of the total EU biomass use for energy130. Since 2010, the RES 
share in the heating and cooling has increased by 4% points passing from 14.8% in 2010 to 18.5% in 
2015. 

The  current  linear  growth  of  RES  in  the  EU  heating  and  cooling  is  largely  due  to  the  historical 
presence  of  large  biomass  use  in  Central,  Eastern  and  Baltic  Member  States,  and  to  dedicated 
policies in RES uptake in the district heating grids in Northern and Baltic Member States. It is also 
linked to building requirements and supportive policies at building level for RES uptake in new and 
renovated  buildings  (mainly,  heat  pumps)  in  a  limited  number  of  other  Member  States,  notably 
Finland,  France,  Germany,  Italy  and  Sweden.  The  legal  transposition  deadline  of  Article  13(4)  on 
minimum use of RES in buildings has only been applied in Member States since 2015, and the legal 
provisions on nearly-zero energy standards in buildings will only become applicable as of 2020. For 
these reasons, it is still too early to conclude on the relevance and impact of these requirements on 
the  RES  deployment  in  buildings.  However,  it  is  also  important  to  note  that  these  provisions  are 
aimed at RES promotion in new buildings, while most of the energy efficiency and decarbonisation 
potential  lies  in  existing  buildings,  where  two  thirds  of  the  energy  needs  are  sourced  from  fossil 
fuels131. Neither the RES Directive nor the energy efficiency legislation (2010 Energy Performance 
for Buildings Directive, 2012 Energy Efficiency Directive) have yet fully captured this potential at 
the current building renovation rate.   

129  
130  
131  

"An EU Strategy for Heating and Cooling", COM (2016) 51 final 
PRIMES, 2016 (data for 2015 reflecting current situation) 
"An EU Strategy for Heating and Cooling", COM (2016) 51/2 

  32 

39.241.243.145.548.351.355.459.865.069.473.480.161.064.566.871.474.977.984.480.286.089.287.591.23.04.36.68.911.112.914.49.912.913.514.714.90102030405060708090100200420052006200720082009201020112012201320142015Million tons of oil equivalentRES-E deploymentRES -HC deploymentRES-T deployment 
 
 
 
 
 
                                                           
6.1.5.  What  effects  (impacts)  has  the  implementation  of  the  RES  Directive  had  at  EU  and 

individual Member State’s level? 

The strong EU policy framework, established by the RES Directive, alongside  the mixture of high 
levels of investment in research and development coupled with favourable incentives and abundance 
of renewable energy potential in the EU, has provided enabling conditions to stimulate the growth of 
the  EU  as  a  major  global  renewable  energy  player132.  Furthermore,  it  has  directly  contributed  to 
enhance  the  EU  competitiveness  and  to  Lisbon  goals,  through  the  creation  of  high  quality  jobs  in 
Europe and in maintaining Europe's technological leadership. The initial EU leadership in promoting 
renewable  energy  eventually  triggered  a  global  move  towards  clean  energy  technologies:  173 
currently have renewable energy targets in place, compared to 44 in 2004133. The EU leading role has 
contributed to higher participation of renewable energy in the world's energy mix. According to 2016 
renewable capacity statistics by the International Renewable Energy Agency134, at the end of 2015 
global renewable generation capacity amounted to 1,985 GW (compared to 1,348 GW in 2010), after 
growing 8.3% in 2015, the highest rate ever recorded. Overall, RES capacity has increased by about 
one-third  from  2011  to  2015135.  The  International  Energy  Agency  has  projected  that  renewable 
energy will become the world's number one source of electricity generation in 2035136. 

Competitiveness of the EU renewable energy industry  

The  EU  has  developed  strong  value  chains  and  retains  considerable  competitive  advantage  across 
several renewable energy production sectors. The European renewable energy industry is leading in 
key sectors: 

  Wind turbine manufacture, with 4 European manufacturers among the top 6 of largest market 

shares in 2015137; 

  Offshore  wind,  with  91%138  of  all  offshore  wind  installations  located  in  the  waters  off  the 

coast of ten EU Member States; 

  Ocean energy, with Europe concentrating most of the  new projects on tidal stream and wave 

energy in open waters launched around the world in 2015139; 

  Concentrated Solar Power (CSP), with one Member States (Spain) being the global leader in 

existing CSP capacity, with 2.3 GW (almost half of the world capacity) in 2015140;  

  Lignocellulosic biofuels141, at innovation and demonstration stage, though not  yet at market 

deployment level.   

132  
133  
134  
135  
136  
137  
138  
139  
140  
141  

ICF International, 2014 
"Renewables 2016 Global Status Report", REN21. 2016 
"Renewable Capacity Statistics 2016", IRENA, 2016 
Idem  
"World Energy Outlook", IEA, 2014 
"Renewables 2016 Global Status Report", REN21, 2016 
GWEC, "Global Wind 2015 Report" Chapter on Global Offshore 
"Renewables 2016 Global Status Report", REN21,2016 
"Renewables 2016 Global Status Report", REN21, 2016 
"Towards  an  Integrated  Strategic  Energy  Technology  (SET)  Plan:  Accelerating  the  European  Energy  System 
Transformation" C(2015) 6317 

  33 

 
 
 
 
                                                           
In  some  areas,  such  as  solar  PV  and  onshore  wind,  the  EU  is  being  overtaken  by  Asian  and  US 
markets  in  recent  years.  The  dynamic  RES  growth  in  these  two  markets  influences  the  location  of 
RES  production  chains:  the  requirement  to  locate  key  parts  of  the  value  chain,  and  the  transport 
costs, encourage the localisation of manufacture closer to the deployment market142.   

The  EU  still  retains  its global  leadership  when  it  comes  to  RES  installed  capacity  per  capita,  with 
Denmark, Germany, Sweden, Spain and Portugal being the champions of installed renewable power 
capacity  per  capita  and  Austria,  Cyprus  and  Greece  being  the  champions  for  solar  water  heating 
collector  installed  per  capita.  As  regards  annual  investment  (except  the  United  Kingdom  currently 
ranking  n°3  globally)  and  total  installed  capacity,  the  EU  has  been  overtaken  in  recent  years  by 
China and the US143.  

RES technology cost-reductions  

According  to  IRENA's  report  on  "Renewable  Power  Generation  Costs  in  2014",  renewables  have 
benefited from a cycle  of falling costs  spurred on by accelerated deployment. The EU's renewable 
energy targets for 2020 are considered to have played a vital role in this fast deployment since they 
have  created  a  steady  demand  for  cost-effective  renewable  energy  and  led  to  an  unprecedented 
development  of  renewables  in  Member  States,  hence  being  instrumental  in  lowering  renewable 
energy  costs  globally.  The  Renewable  Energy  Directive  has  initiated  a  virtuous  cycle  in  which 
support  policies  stimulate 
technological 
improvements, as well as continual cost reductions144. 

increased  deployment,  which 

turn  results 

in 

in 

From  2010-2015,  the  average  cost for  new  onshore  wind  plants  fell  by  30%  and  average  costs  for 
new  utility  scale  solar  PV  installations  decreased  by  75%.  Utility  scale  solar  PV  projects  are  now 
competitive against peaking gas generation (Figure 7). 

Figure 6: Levelised cost of electricity using various technologies, 2015 

142  
143  
144  

ICF International, 2014 
"Renewables 2016 Global Status Report", REN21. 2016 
"Renewable Power Generation Costs in 2014", IRENA, 2015 

  34 

 
 
 
 
 
                                                           
Source: OECD calculations, based on IEA (2015) 

Other impacts 

GHG: the deployment of renewables resulted in around 380 Mt of gross avoided CO2 emissions at 
EU  level  in  2014145.  Commission's  Joint  Research  Centre,  based  on  a  different  methodology,  has 
evaluated substantially higher CO2 emission reductions - 767 Mt of gross avoided CO2 emissions at 
EU level in 2014. More than 65% (512.5 Mt CO2 eq) of net GHG emission savings were attributed to 
renewable  electricity  and  the  rest  was  coming  from  renewable  heat/cold  (29%)  and  transport 
(4%)146.   The  use  of  renewable  energy  in  transport  resulted  in  137  Mt  of  gross  avoided  CO2 
emissions at EU level from 2011 to 2014147. Most of these savings in the transport sector stemmed 
from the use of biofuels, while only a small fraction stemmed from the use of renewable electricity in 
transport, especially in the rail sector148,149.  

Fossil fuel displacement and avoided fuel import costs: renewables' production allowed the EU to 
cut  its  demand  for  fossil  fuels  by  110  Mtoe  in  2013,  and  by  an  estimated  114  Mtoe  in  2014150, 
respectively (i.e. representing approximately 10 % of total fossil fuel consumption)151, thus bringing 
a  solid  contribution  to  the  goal  of  security  of  energy  supply.  Avoided  imported  fuel  costs  due  to 
increasing use of renewable energy are estimated to be around €20bn in 2014152,153. 

Employment and GDP: The influence of RES policies on GDP growth is difficult to isolate and to 
compare with the results of the expected impacts in 2008 impact assessment, principally due to the 
fact that the effects of the 2009-2010 economic crisis have not been initially factored in. However, 
the  impacts  of  RES  policies  on  GDP  are  deemed  to  have  been  relatively  limited.  A  first  rough 
estimation,  based  on  the  volume  of  investment  and  the  avoided  imports154,  confirms  that  the 
influence of RES policies on GDP remained below 0.5% in 2014155. Employment in the RES sector 
has  grown  in  the  EU  despite  the  economic  crisis,  with  almost  half  a  million  additional  jobs  in  the 
EU-27  between  2008  and  2014156.  Renewable  energy  industry  employed  1.11  million  workers  in 
2014157. The largest sectors in terms of employment creation have been the wind (314 000 jobs) and 
biomass (306 000 jobs) sectors. These sectors were also the ones with the largest employment gains 
in  absolute  terms.  The  EU  is  one  of  the  key  global  players  with  regard  to  employment  in  the 

145  
146  

147  
148  
149  
150  

151  
152  
153  

154  
155   

156  
157  

"Renewable Energy in Europe 2016 – Recent growth and knock-on effects", EEA, 2016, No 4/2016 
JRC, 2016 available at: http://iet.jrc.ec.europa.eu/remea/news/third-progress-reports-renewable-energy-
development-    eu2013-2014 
Direct emission savings, therefore not including emissions from indirect land use change 
"Renewable Energy in Europe 2016 – Recent growth and knock-on effects", EEA, 2016, No 4/2016 
"Renewable energy progress and biofuels sustainability", Ecofys, 2014 
This figure represents the total contribution of renewables to fossil fuel savings in a given year compared with 
the situation in 2005. This should not be compared with 234-300 Mtoe/year figure in 2020 from the 2007 impact 
assessment, which has been calculated for the whole energy system 
"Renewable Energy in Europe 2016 – Recent growth and knock-on effects", EEA, 2016, No 4/2016 
“Draft Renewable Energy Progress Report”, Öko Institute [to be published] 
This figure represents the total contribution of renewables to fossil fuel import savings in a given year compared 
with the situation in 2005. This should not be compared with 50-57 billion EUR/annum from the 2007 impact 
assessment, which has been calculated for the whole energy system 
Based on EEA, PRIMES and EUROSTAT 
This  figure  has  to  be  considered  carefully  and  as  gross  effect,  since  it  doesn't  factor  in  the  reduction  of 
investment in conventional generation and other variables 
Based on EurObserv'ER database.and EurObserv'ER 2015 report. 
EurObserv'ER, 15th Eurobserv'ER report, 2015  

  35 

 
 
 
 
                                                           
renewable  energy  sector.  In  2014,  it  had  the  second  highest  per-capita  employment  in  the  area  of 
renewable energy behind Brazil158.  

6.1.6.  Which factors have hindered the achievement of objectives of the RES Directive?  

In  some  Member  States,  favourable  remuneration  schemes  led  to  high  investments,  sometimes 
reaching  levels  rather  unexpected  by  Member  States.  A  combination  of  high  investor  appetite  and 
generous schemes in these cases led to budget concerns, pushing Member States towards unexpected 
policy  changes,  sometimes  with  retrospective  impacts.  Such  action  in  a  number  of  Member  States 
caused a great deal of uncertainty amongst investors, including building owners investing in on-site 
renewables, and RES technology suppliers. 

Investments and national RES support schemes 

Total investments in renewable energy in Europe strongly increased from 2004 to 2011, and sharply 
declined in 2012 and 2013 mainly due to undermined investor confidence159. Investments rose again 
slightly  in  2014.  This  increase  in  2014  was  mainly  caused  by  large  offshore  wind  projects  in 
Germany,  The  Netherlands  and  the  United  Kingdom  and  does  therefore  not  necessarily  point  to  a 
reverting trend across the whole of the EU160.  

Figure 7: Investment in renewable energy sources in the EU from 2004 – 2015 

New investment in clean energy in Europe ($bn) 
(source : Bloomberg New Energy Finance) 

140

120

100

80

60

40

20

0

2004

2005

2006

2007

2008

2009

2010

2011

2012

2013

2014

2015

Source: Bloomberg New Energy Finance 

Despite initial investment boom in 2009 and 2010, following the adoption of EU Energy and Climate 
Package,  including  the  RES  Directive,  with  the  binding  20%  EU  level  RES  target  and  binding 
national  RES  targets  for  2020,  investments  in  renewable  energy  in  Europe  were  influenced  by  a 
number of external factors, leading to eventual investment decline after 2011: 

158  
159   

160  

EurObserv'ER, 15th Eurobserv'ER report, 2015  
Bloomberg New Energy Finance, "How to attract new sources of capital to EU renewables", 2013, and UNEP, 
"Green energy 2013 – Key Findings", 2013 
RES Mainstreaming study, 2016 

  36 

 
 
 
 
 
                                                           
  Abrupt  policy  changes  and  reduction  in  RES  support:  major  changes  to  the  support 
schemes for renewable energy also created investment uncertainty and altered the investment 
landscape. A number of Member States (e.g. Bulgaria, Czech Republic, Italy, Spain) adopted 
unexpected  changes  to  the  financial  incentives  for  existing  renewable  energy  projects  and 
suspended support for new projects, sometimes with retrospective effects. In addition, most 
Member  States  reduced  the  feed-in  tariff  for  solar  PV  or  decided  to  move  into  feed-in 
premium (e.g. the United Kingdom) in order to adapt support to the reduction in technology 
costs and make schemes more market-based. 

  The  economic  and  financial  crisis  had  a  double  impact  on  the  renewable  energy  sector. 
Firstly,  investors  became  more  reluctant  to  invest  in  RES  projects,  causing  the  investment 
level to drop. A second impact of the financial crisis originates prior to the economic crisis in 
2008,  when  the  total  installed  power  capacity  (also  fossil  fuel-based)  in  Europe  expanded, 
based on optimistic economic forecasts including e.g. a 2.5% growth rate in PRIMES 2007. 
During  the  crisis  (2007-2009),  power  demand  in  Europe  dropped  by  5%161,  causing  an 
overcapacity  of  power  production  and  lower  electricity  prices  for  all  fuels.  These  lower 
electricity  prices  impacted  on  the  viability  of  renewable  energy  projects,  undermining 
previous business cases and resulted in lower investments in RES projects162. 

  The  decreasing  renewable  energy  technology  costs,  especially  for  solar  PV,  also  caused 
lower  investment  levels  in  monetary  terms,  while  not  necessarily  reducing  investment 
volumes in the EU, as a whole. 

  Oversupply  of  ETS  allowances  and  limited  pricing  of  other  externalities  such  as  air 
polution.  The  EU  ETS  places  a  price  on  emissions  of  greenhouse  gases  in  the  power  and 
industrial  sectors.  The  anticipated  impact  of  ETS  as  an  instrument  that  would  trigger  low 
carbon investments did not deliver as planned (2015 ETS prices are around 7.7 €/t and 2020 
prices are currently expected to reach only 15 €/t163, substantially below the expected prices 
for 2020 according the projection made  in  2008164).  The current imbalance  between supply 
and demand in the ETS has limited the ETS impact to incentivize investments in less carbon 
intensive technologies such as renewables. 

6.2. 

Efficiency 

6.2.1.  To  what  extent  has  the  RES  Directive,  and  the  binding  targets  included  therein,  been 
efficient  means  of  developing  the  European  renewable  energy  sector?  Could  the  use  of 
other policy instruments, or mechanisms, have provided better efficiency?  

The question of how to achieve the 20% EU renewable energy target in the most cost-effective way, 
while ensuring even growth of renewables across the EU and fair approach to effort sharing amongst 
the  Member  States,  was  thoroughly  considered  in  the  2008  Impact  Assessment.  A  political  choice 
had  to  be  made  between  an  effort  sharing  set  on  the  basis  of  Member  States  national  resource 
potential (considered as more cost-effective option at the EU level), and an effort sharing set on the 

161  
162  
163  
164  

Based on Eurostat table on total gross electricity generation in 2007 and 2009 
"World Energy Outlook", IEA, 2014 
PRIMES Ref2016 
2008 Climate and Energy Package Impact Assessment - SEC(2008) 85 

  37 

 
 
 
 
                                                           
basis of a flat-rate increase in the share of renewable energy in each Member State weighted by GDP 
and modulated to account for earlier development of RES.  

At the time of the adoption of the 2009 RES Directive, based on previous experience with indicative 
targets and softer policy measures, the option of voluntary industry agreements and continuation of 
previous approach with indicative targets was discarded as it was considered a less effective means 
for achieving the ambitious 2020 climate and energy policy objectives. Instead, the political choice 
was made in favour of binding EU level and national renewable energy targets and assuming that the 
higher  costs  of  the  flat  rate/GDP  method  would  be  mitigated  through  effective  and  efficient 
transferable mechanisms trade in renewable energy.  

When  assessing  the  current  renewables'  share  at  Member  State  level,  the  REFIT  Evaluation  study 
found that some Member States165 which had relatively low starting points for their 2020 target and 
targets above their potential166 are those currently the furthest from reaching their target. The opposite 
is also true, where Member States with high historical starting points and high assessed potential, but 
lower targets, are often over-achieving, or close to achieving their 2020 national targets167. However, 
when  assessing  the  gap  between  Member  States  projected  achievements  by  2020  and  initial 
potentials  as  estimated  back  in  2008,  higher  discrepancies  are  evident  than  when  comparing 
projected achievement with GDP-based targets168 (Figure 10). It can therefore be deducted from the 
analysis that the GDP-based breakdown was the approach which has been the closest to the actual 
potential at Member State level. 

Figure 8: Gap between 2020 projections, targets and potentials 

Source: based on PRIMES ref2015 and 2008 climate package impact assessment 

165  
166  
167  
168  

This correlation is particularly true for FR, NL, UK, and LU 
Based on flat-rate and GDP 
This is particularly true for AU, FI, CZ, LI, EE, BG 
This is particularly true for CZ, ES, HU, LA, LI, where 2020 projected deployment is way lower than assessed 
potential back in 2008 

  38 

 
 
 
 
 
                                                           
In the above graph, the red bars represent the gap between projected 2020 RES-shares and potentials 
as assessed in the 2008 Impact Assessment. The blue bars represent the gap between projected 2020 
RES-shares and GDP-based targets as assessed in the 2008 Impact Assessment. Red bars below zero 
mean  that  the  expected  achievement  by  2020  is  lower  than  the  potential  assessed  in  2008.  This 
demonstrates the difficulty that several Member States would face to reach their target if this target 
had been defined taking into account only the potential, and excluding the GDP-based modulation. 

6.2.2.  Have  the  RES  Directive  and  its  national  implementation  measures,  including  support 
schemes,  been  cost-efficient  means  of  achieving  the  RES  targets  at  the  EU  and  national 
level?  Have  the  expected  results  been  obtained  at  a  reasonable  cost?  Are  results 
proportionate  to  the  benefits?  Could  the  same  results  have  been  achieved  with  less 
funding/lower cost? 

As  already  mentioned,  the  initially  intended  legal  provisions  permitting  Guarantees  of  Origin  as  a 
transferable means  for facilitating the RES target  achievement, did  not find  their place in  the RES 
Directive as a result of political resistance. Instead, alternative provisions on the use of cooperation 
mechanisms  were  included  in  the  Directive  as  means  to  facilitate  renewable  energy  trade  between 
Member States. However, as also already explained in the previous sections, these tools have as of 
2016 not yet been used to any significant extent, thus placing higher effort level on those Member 
States with high GDP and low RES potential as a starting point before 2010. 

Cooperation mechanisms 

Despite  the  apparent  benefits  deriving  from  engaging  in  cooperation  in  order  to  achieve  the 
renewable  energy  targets  jointly  and  in  a  more  cost-efficient  manner,  the  use  of  RES  cooperation 
mechanisms  remains  limited.  The  only  existing  joint  mechanisms  currently  in  place  is  a  support 
scheme  based  on  green  certificates  between  Norway  and  Sweden169  (in  operation  since  January 
2012). Statistical transfers and joint projects have, so far not been used.  

This means that the benefits in terms of cost effective deployment (only presented qualitatively, not 
quantified) in the 2008 Impact Assessment, have not yet materialised. Consequently, there is not a 
significant  base  of  evidence  to  evaluate  if  the  original  estimations  were  indeed  appropriate.  A  full 
cost-benefit analysis of the mechanisms is therefore not feasible.  

First  of  all  there  is  the  question  on  why  these  mechanisms  were  not  triggered  as  originally 
anticipated.   

The  2016  Public  Consultation  reveals  that  the  main  reasons  for  the  limited  use  of  cooperation 
mechanisms  to  date,  according  to  stakeholders,  have  been  Member  States'  reluctance  to  see  their 
taxpayers, or  consumers'  money, being used  for investments outside their  country170, together with 
the lack of cost-effectiveness or uncertain benefit for individual Member States171.  

The  2015  mid-term  REFIT  Evaluation  study  indicated  that,  although  the  ultimate  rationale  to  use 
cooperation mechanisms is  to exploit renewable energy sources in the most  cost-efficient way, the 

169  

170  
171  

Discussions between Sweden and Norway on a joint support scheme already started in 2003, but came to a halt 
in 2006 when no agreement could be settled on the burden sharing aspect. Sharing the costs and benefits of the 
joint scheme turned out to be an insurmountable hurdle by that time. The second round of negotiations led to a 
signed agreement in 2009 and the start of the scheme in 2012 
94% respondents consider this factor as important or very important 
90% respondents consider this factor as important or very important 

  39 

 
 
 
 
                                                           
vast majority of Member States considered their use primarily as an alternative instrument for target 
achievement and substitute for national effort. The referred study also indicates possible reasons for 
their limited use, adding to the ones above mentioned the uncertainty about the scope and shape of 
the  EU  framework  beyond  2020  and  the  insufficient  interconnection  capacities  between  Member 
States.  

The  recurrent  thought  among  network  operators,  professional  organisations  and  RES  industries  is 
that  the  governance  system  of  the  2030  framework  needs  to  be  clarified  to  enable  an  improved 
understanding of whether cooperation mechanisms will remain relevant beyond 2020. 

The  2013  Commission's  Guidance  on  Cooperation  Mechanisms172  aimed  to  provide  additional 
orientation to Member States, by clarifying the criteria to choose one cooperation mechanism over 
the  others  and  providing  with  a  checklist  for  each  type.  Moreover,  a  dedicated  study  was 
commissioned  to  help  Member  States  willing  to  engage  in  such  cooperation  agreements173.  This 
study  presented  quantitative  and  qualitative  analysis  to  assist  Member  States  in  cooperation 
mechanism design, cost-benefit allocation and the cost savings potential of cooperation.  

Furthermore,  this  study identified  three  types  of  barriers  for  using  cooperation  mechanisms:  firstly 
political  barriers,  including  public  acceptance  for  cooperation  mechanisms,  the  determination  of 
governments to engage in cooperation on RES target achievement and uncertainty on the continuity 
of the RES framework beyond 2020; secondly technical barriers, such as high degree of uncertainty 
on  quantifiable  costs  and  benefits,  design  options  of  cooperation  mechanisms,  difficulties  for 
Member States to forecast their own RES target fulfilments and lacking transmission infrastructure 
and  market  integration;  and  thirdly  legal  barriers,  such  as  potential  incompatibility  of  cooperation 
mechanisms with national and EU legislation. 

The second major question is whether, based on the experience of the currently operational joint 
support scheme between Sweden and Norway, the original expectations were duly justified.   

The  anticipated  benefits  of  such  schemes  include174:  1)  better  functioning  of  the  green  certificate 
market, 2) increased cost efficiency and 3) increased long term stability. Referring to the first benefit, 
the increase in the number of parties trading green certificates was assumed to reduce the volatility of 
the market. It was also understood that a joint and larger market would increase liquidity. As regards 
the  second,  access  to  a  larger  production  base  would  increase  cost  efficiency  as  the  market  would 
have  more  opportunities  to  determine  where  the  electricity  production  capacity  would  be  built. 
Finally, on the third, the joint support scheme was assumed to provide a politically stable system that 
can  only  be  substantially  changed  with  the  agreement  of  both  countries,  which  was  expected  to 
improve long term predictability to investors.  

After 5 years of being operational, the initial efficiency assessment of the joint scheme has led the 
Norwegian government to announce its intention to phase-out the joint green certificate system after 
2021.  It  is  understood  that  cost-effectiveness  assumptions  have  only  partially  materialised  due  to 
differences  in  tax  regimes  and  depreciation  that  resulted  in  a  different  than  expected  investment 
pattern, with RES investments mainly going to Sweden175. 

172  
173  
174  
175  

"Guidance on the use of renewable energy cooperation mechanism", 2013, SWD(2013) 440 final 
"Cooperation between EU Member States under the RES Directive", Ecofys, 2013 
 "Cooperation between EU Member States under the RES Directive", Ecofys, 2013 
Norwegian Energy Department announcement of 15.04.2016 

  40 

 
 
 
 
                                                           
This experience shows that having a harmonised support scheme can help exploring better the RES 
potential  where  it  is  most  cost  effective  and,  therefore,  increase  flexibilities  for  Member  States. 
However  a  joint  support  scheme  does  not  imply  that  the  entirety  of  the  criteria  relevant  for  an 
investment decision is uniform. And those differences can matter, even between two States such as 
Sweden  and  Norway  that  are  relatively  similar  in  terms  of  investment  conditions.  Administrative 
procedures  that  were  already  discussed  can  be  an  influencing  factor,  as  can  be  Member  States 
specific  weighted  average  cost  of  capital  (WACC),  network  costs,  or  even  other  non-cost  barriers, 
notably in the area of taxation and depreciation.  

Estimations based only on a national technology cost and technology resource efficiency in a given 
Member  State  that  do  not  factor  in  these  non-cost  national  circumstances  tend  to  overestimate  the 
benefits to be reaped and the cost-effectiveness of EU-wide "optimal" resource exploitation (which 
implies use of cooperation mechanisms).   

National measures, including RES support schemes 

Pursuant to Article 3(3) of Directive 2009/28/EC, support schemes are but one instrument - amongst 
others - that can be chosen by Member States to achieve the binding national targets established by 
the Directive. Effectively though, the majority of the Member States use them as part of their RES 
policies.  

In 2009, the majority of Member States were promoting renewable energy production either by green 
certificate  regimes  or  quotas  (23  Member  States),  or  by  feed-in-tariff  system  (21  Member  States). 
Premiums were used in 7 Member States and tendering was not common practice at the time176.  

As  already  mentioned,  Member  States  retained  full  discretion  over  their  use  of  support  schemes, 
including their design, structure and the level of support. The Directive provided no guidance on how 
or when using support schemes, nor even on their eventual revision or reform, in spite of the fact that 
a  majority  of  Member  States  already  had  such  support  schemes  in  place  well  before  the  2009 
Directive. As a result, each and every Member State provided its own support, used different models 
for support schemes and all Member States started off by excluding non-domestic renewables from 
access to the support schemes.  

When  these  limitations  started  to  become  apparent,  the  Commission  issued  Guidance  on  RES 
support schemes design and their reform in 2013177. The move towards more market-based support 
mechanisms  was  then  further  complemented  by  the  Guidelines  on  State  aid  for  Environmental 
Protection and Energy (EEAG)178 and both paved the way for the design of future support schemes, 
which  should  be  market-based  and  granted  through  a  competitive  process.  For  this,  the  EEAG  set 
two  major  deadlines  in  2016  and  2017,  respectively  for  market-based  support  and  competitive 
bidding, which is already in place in 13 Member States179,180.   

Not all national support schemes were found to be equally efficient and responsive to market signals 
and that difference mattered even more when adjustments were not done fast enough in line with the 

176  
177  

178  
179  
180  

Renewable Energy: Progressing towards the 2020 target, COM (2011) 31 
"European Commission guidance for the design of renewable energy support schemes", 2013, SWD (2013) 439 
final 
"Guidelines on State aid for environmental protection and energy 2014-2020", OJ 2014/C 200/01 
DE, ES, ET, FR, HR, HU, IT, LT, LV, MT, PT, SL, SK 
RES-Legal 

  41 

 
 
 
 
                                                           
(unexpected)  technological  cost  decreases.  After  the  entry  into  force  of  the  RES  Directive,  the 
investment  boom  in  renewable  energy  occurred  partly  due  to  the  generosity  and  rigid  design  of 
national support schemes. As the cost of renewable energy technologies fell, several national support 
schemes were unable to be adapted rapidly enough. As a result, technology bubbles were encouraged 
by national support schemes, unregulated by any EU Directive or State aid rules. This is evidenced 
by, for instance, the rapid overshooting of solar production in Spain, Italy or Germany.  

Spain's long term policy objectives resulted in a sizeable domestic renewable sector. However, this 
development was achieved at relatively high policy costs with annual feed-in premium/feed-in tariff 
payments  of  around  EUR  6.8  billion  in  2013  to  support  73.8  TWh  of  generated  electricity.  As  a 
result of support scheme reform, this has been reduced to EUR 5.4 billion in 2015 to support 56.9 
TWh181.  Germany  spent  EUR  20.4  billion  for  the  EEG  surcharge  in  2013  and  EUR  21.8  billion  in 
2015 for approx. 160 TWh of generated electricity182.   

Early  subsidies  at  Member  State  level  have  been  a  necessary  step  to  ensure  renewable  technology 
roll-out  and  cost  reduction,  and  therefore  to  pave  the  way  for  the  next  generation  of  enabling 
policies.  This  is  particularly  relevant  for  solar  PV,  where  the  cost  of  support  per  unit  of  generated 
energy  has  been  constantly  diminishing  between  2009  and  2014.  Solar  PV  module  prices  in  2014 
were around 75% lower than their levels at the end of 2009 and the LCOE of utility-scale solar PV 
has fallen by half in four years183. 

With less than 5 years to go to 2020, the overall trend in Member States indicates a clear shift away 
from  feed-in  tariff  to  more  market  based  approach,  and  following  the  phase-out  of  early  support 
allocations, the total annual cost of Member support payments to renewable electricity production is 
also  expected  to  decrease  after  2020.  Furthermore,  this  phase-out  has  been  eased  by  technological 
progress and further technology cost reductions.  

The story record of the bust and boom cycles of national support schemes illustrates the importance 
of providing clear and transparent framework principles in legislation. 

Electricity wholesale and retail prices 

Since  2012,  wholesale  energy  prices  have  been  decreasing  in  the  EU.  A  key  driver  in  falling 
electricity  prices  has  been  the  pass-through  of  reduced  coal  and  gas  prices,  but  there  are  other 
drivers, such as market coupling and growing inter-connector capacity. 

Reduced demand for CO2 allowances and further decreases in CO2 prices have also been important 
inducing factors. Furthermore, in some Member States, lower demand linked to subdued economic 
growth, combined with capacity expansion and the rise of solar and wind powered electricity, played 
some  role.  In  perfectly  competitive  markets,  changes  in  wholesale  markets  should  pass  through 
rapidly  and  fully  to  retail  markets.  However,  in  Europe,  various  factors  have  restricted  this  pass-
through, the average household electricity price having increased at an annual rate of 3% from 2008 
to 2015184. 

181  
182  
183  
184  

Based on: CNMC, "Informe mensual de estadística sobre las ventas del régimen especial", 2016 
https://www.netztransparenz.de/de/file/20141015-Pressemitteilung_zur_EEG-Umlage_2015.pdf 
"Renewable Power Generation Costs in 2014", IRENA, 2015 
2016 Energy prices and costs report",  SWD (2016) Reference to be completed after adoption of the report 

  42 

 
 
 
 
                                                           
As the Commission's 2016 Communication on Energy Prices and Costs in Europe185 indicates, retail 
electricity price increases were mainly driven by State taxes, levies and network tariffs. The energy 
component of prices has diminished, both in absolute and relative terms. On average, EU household 
prices diverge by a factor of three between the cheapest and most expensive country.  These  major 
variations result  from differences in fiscal needs (incl.  undesignated taxes) and energy and climate 
policy  support  cost  shares  in  the  final  household  electricity  prices  (e.g.  renewable  energy  or  CHP 
expenditure  shares).  While  Value  Added  Tax  and  other  relevant  taxes  are  59%  in  Denmark,  they 
only amount to 5% in Malta. Similarly, RES & CHP levies range from as high as 22-23% in Portugal 
and Germany to as low as 0%-2% in Ireland and Hungary. In general, energy policy relevant levies 
were out weighted by taxes, including undesignated taxes which not necessarily finance energy, or 
climate,  related  policies.  Undesignated  taxes  cost  the  average  EU  household  15%  more  than 
designated policy support costs (Figure 11)186. 

Figure 9: Share of sub-components in the weighted average EU taxes and levies component 
(household prices) 

100%
90%
80%
70%
60%
50%
40%
30%
20%
10%
0%

23% 

21% 

48% 

45% 

14% 

2008

16% 

2010

19% 

42% 

24% 

2012

16% 

38% 

16% 

37% 

33% 

33% 

2014

2015

Other taxes

VAT

Other levies

Security of supply

Energy efficiency

Market

Concession fees

Nuclear

Social

RES & CHP

Source: 2016 Energy prices and costs report 

The EU 28 weighted average RES & CHP support cost tripled from 2008 to 2015. In 2015, Germany 
recorded the highest rate of RES & CHP support accounting for 6.3 €c/kWh (household prices). The 
smallest amount of the same cost, 0.45 €c/kWh, was recorded in Croatia (Figure 12). 

Figure 10: Nominal amount of RES and CHP support cost by country 
in 2015 (household prices)187 

185  
186   
187  

2016 Energy prices and costs report",  COM (2016). Reference to be completed after adoption of the report 
2016 Energy prices and costs report,  SWD (2016). Reference to be completed after adoption of the report 
5 EU countries (Finland, Malta, Netherlands Poland, Sweden) did not report RES or CHP cost elements. It is 
important to note that consumers in these countries are also paying RES support costs despite the fact that such 
costs could not be reported explicitly in the course of the study 

  43 

 
 
 
 
 
                                                           
 
€c/kWh  
7

6

5

4

3

2

1

0

DE PT

IT

ES DK LV AT EL

LU CZ SK UK SI

FR BG RO BE LT EE CY

IE HR HU

Source: 2016 Energy prices and costs report 

While Germany recorded the highest nominal amount of RES & CHP cost to households, the cost 
share of supporting such policies was the highest in Portugal, accounting for almost a quarter of the 
total price. The smallest share of 3% was reported by Ireland. 

As per industry prices, energy policy relevant components (e.g. RES & CHP levies) out-weighted the 
component of general fiscal measures. In 2015, Germany recorded the highest rate of RES & CHP 
support, accounting for 61 €/MWh. The smallest amount of the same cost, 2.3 €/MWh, was reported 
by Ireland.  

Notwithstanding  the  above  analysis  on  the  energy  and  climate  policy  support  cost  impacts  on 
household and industry electricity prices, over 2008-2015 period the EU average industrial electricity 
price  was  relatively  stable  and  remained  around  the  average  paid  internationally  (ca  €110/MWh). 
They were higher than those paid in Russia, Indonesia, the USA and Mexico, but lower than those 
paid in Turkey, China, Brazil and Japan. 

6.2.3.  Has the RES Directive effectively improved grid access conditions for renewable electricity 

producers? Has it done so in a cost-efficient manner? 

The Directive has led Member States to implement priority dispatch and priority access provisions 
for renewable electricity in their relevant legislation. Such provisions have effectively supported the 
dispatch  of  renewable  electricity  sources,  supporting  the  economics  of  renewables'  projects  and 
contributing  to  progress  against  the  national  targets  (expressed  in  terms  of  generation).  Priority 
access provisions have in most Member States effectively protected renewables against curtailment, 
here again providing greater certainty on dispatch and revenues for investors, and maximising output 
by renewables assets.   

However, grid access provisions contained in Article 16 of the Directive were found to be unclear by 
most stakeholders. This effectively left significant discretion to Member States in their interpretation 
of priority dispatch and priority access rules, and to have a wide range of technical implementations 
depending on Member States, or sub-national level.  

As  regards  grid  connection  costs,  Article  16  of  the  Directive  defines  general  principles  (charges 
should  be  defined  in  a  non-discriminatory  and  transparent  manner),  but  leaves  room  for  Member 
States  to  decide  on  which  components  should  be  included  in  the  cost  calculation.  This  has  led  to 
diverging  grid  connection  charges  being  applied  across  Member  States,  with  renewable  generators 

  44 

 
 
 
 
 
bearing in some Member States only the direct costs of connection  ("shallow" model), but in other 
countries the direct costs and any grid reinforcement costs as well ("deep" model). The gap between 
the two models has created significant distortions in investment decisions across Member States, in 
particular  for  those  projects  where  grid  connection  represent  a  high  fraction  of  total  project  costs 
(e.g. offshore wind).    

Furthermore, while priority provisions were adapted to the needs of emerging technologies (creating 
a framework with very high predictability of the total power generation thus increasing investment 
security),  they  do  not  ensure  a  cost-efficient  outcome  when  applied  to  increasingly  mature 
technologies  representing  a  large  part  of  the  electricity  market.  The  increasing  share  of  renewable 
electricity and priority rules also for other types of generation (CHP and indigenous resources) have 
resulted  in  a  situation  where,  in  some  Member  States,  very  high  shares  of  power  generation  are 
coming  from  "prioritized"  sources.  Against  this  background,  priority  provisions  can  have  very 
significant impact on the well-functioning of the electricity market. In particular:  

  Subsidy schemes based on priority dispatch (such as Feed-in Tariffs) are often based on high 
running hours and a mitigation of market signals to the subsidized generator ("produce and 
forget"). This means that non-subsidized generation is increasingly pushed out of the market 
even where this is not cost-efficient; 

  Situations in which more than 100% of demand is covered by priority dispatch become more 
prevalent.  This  lowers  the  investment  security  and  can  lead  to  unnecessary  curtailment  of 
renewable electricity;  

  Electricity  generation  should  be  guided  by  price  signals.  In  a  situation  where  the  clear 
majority  of  power  generation  does  not  react  to  price  signals,  market  integration  fails  and 
market signals cannot develop; 

 

Incentives to invest in increased flexibility, which would naturally result from price signals 
on  a  functioning  wholesale  market,  do  not  reach  a  significant  part  of  the  generation  mix. 
Priority dispatch rules can eliminate incentives for flexible generation (e.g. biomass) to  use 
its  flexibility  potential  and,  instead,  create  incentives  to  run  independently  from  market 
demand; 

  Priority dispatch and priority grid access limit the choice for transmission system operators to 
intervene  in  the  system  (e.g.  in  case  of  congestion  on  certain  parts  of  the  electricity  grid). 
This can result in less efficient interventions (e.g. re-dispatching power plants in suboptimal 
locations);  

  Priority dispatch rules for high marginal cost technologies (e.g. biomass) can result in using 
costly primary resources to generate electricity at a time where other, cheaper, technologies 
were available.  

Against this background, the provision of priority dispatch and priority grid access will need to be 
reassessed in the context of in the on-going Electricity Market Design initiative in view of the main 
policy objectives of sustainability, security of supply and competitiveness.  

6.2.4.  Has  the  RES  Directive  added  administrative  burden  to  Member  States'  public  authorities 
and  economic  operators?  Or,  on  the  contrary,  has  such  burden  been  reduced  [e.g. 
compared to previous EU legislation in the area of renewable energy Directive 2001/77/EC 

  45 

 
 
 
 
and  Directive  2003/30/EC]?  Have  Member  States  reporting  obligation  requirements 
become more efficient, or, on the contrary, has the reporting burden increased? 

The full quantification of the impact of the reporting and planning obligations under the 2009 RES 
Directive for Member States linked to the requirement to adopt National Renewable Energy Action 
Plans (once), as well as the biennial renewable progress reports (Art. 4) is to be found in the parallel 
REFIT exercise188.  

According  to  this  REFIT  on  reporting  and  planning  obligations,  for  the  Member  States'  planning 
obligation  contained  in  article  4  and  annex  VI  of  the  RES  Directive,  the  resulting  median  annual 
costs  would  be  at  a  medium  level  with  EUR  10,309.  The  benefits  overall  were  rated  high  for  the 
obligation  but  potential  was  also  found  for  further  improvement  in  reducing  the  administrative 
burden associated to this obligation. Concerning the reporting obligation for MS contained in article 
22, the study found the median annual costs to be at a medium level with EUR 4,407. This obligation 
was found to provide high benefits despite some incoherence identified with reporting obligations to 
Eurostat,  especially  concerning  indicators  on  the  actual  consumption  of  energy  from  renewable 
sources in the preceding two years and the sectorial and overall shares of renewable sources. 

The  public  consultation  of  the  parallel  REFIT  on  reporting  and  planning  obligations  revealed  that 
non-binding standard templates and guidance documents for the biennial RES reports, prepared by 
the Commission in close cooperation with EUROSTAT, effectively facilitated the reporting task to 
Member States.  

Part  of  the  legal  provisions,  with  potential  impact  on  Member  State  national,  regional  and  local 
administrations, as well as economic operators, such as provisions on Guarantees of Origin (Art. 15) 
and regular reporting requirements (Art. 22) were already covered in the previous EU legislation in 
the field of renewable energy. Therefore, the impact of the RES Directive on administrative burden 
related to these provisions, has not changed substantially. On the contrary, the RES Directive merged 
the previous two separate reporting streams (annual in  the case of Renewable  Electricity Directive 
and biennial in the case of Biofuels Directive) in a single biennial report, reducing the frequency and 
burden  of  national  reporting,  facilitating  the  reporting  task  through  standard  template,  and  visibly 
improving Member State compliance with their reporting obligations189.   

However,  the  RES  Directive  established  new  compliance  obligations  on  Member  States,  with  the 
national  plans  and  with  the  EU  biofuel  sustainability  criteria  (Art.  17-19).  The  latter  required 
establishing national sustainability verification and audit systems in the Member States, placing the 
burden of proof on biofuel producers and conventional fuel market operators, who were required to 
provide evidence on the sustainability of biofuels they placed on the market.  

At the same time, there is no available overview of the administrative costs placed on producers, as 
well as on Member States, stemming from the Guaranteed of Origin scheme. However, according to 

188  

189  

Fitness  check  of  the  Reporting,  Planning  and  Monitoring  Obligations  in  the  EU  energy  acquis.  Reference 
number to be added when this REFIT is adopted 
Under  the  previous  RES  legal  framework,  based  on  two  separate  directives,  38  infringement  cases  were 
launched in under article 3(3) of Directive 2001/77EC189 on the biannual renewables progress reports and 53 
infringement cases were launched in relation to article 4(1) of Directive 2003/30/EC189 on the annual progress 
reports and eight infringement cases in relation to article 3(1) of the same directive on the minimum proportion 
of  biofuels.  Under  the  new  Renewable  Energy Directive,  nine  infringement  procedures  were  launched  late  or 
partial compliance with articles 4(1) and 4(2) on the NREAPs. See REFIT for energy planning and reporting 

  46 

 
 
 
 
                                                           
external independent analysis190, whether or not the Guarantees of Origin are issued free of charge, 
differs  across  Member  States,  without  a  clear  rationale  as  to  why  some  charge  for  the  service  and 
others do not. Systems such as in Ireland, Lithuania or Sweden, do not necessarily apply a direct fee 
on users to finance the system, but costs can be recovered through other ways. Further, verifying the 
fees that are charged in the countries where the Guarantees of Origin are not issued for free, it turns 
out that, most of the time, there is a fee for getting an account in the system, a fee for registering a 
plant  and  fees  for  the  respective  activities  performed.  In  the  context  of  other  requirements  of  the 
Directive, it is important that those fees are cost-related as required by Article 13(2) e) of the RES 
Directive. 

6.2.5.  Has  the  establishment  of  the  sustainability  scheme  for  biofuels  and  bioliquids  led  to  the 
creation of a cost-efficient framework? Has it achieved its aim in a cost-efficient manner? 
What impact has such sustainability system had on the Member States administrations and 
the private sector?  

The administrative burden and cost for economic operators to prove compliance with the EU biofuel 
criteria  has  been  evaluated  as  quite  significant.  Such  burden  is  totally  associated  with  the  initial 
establishment  of  the  system  of  default  values  for  GHG  emission  calculation  included  in  the  RES 
Directive  and  the  international  certification  schemes  recognised  by  the  Commission.  Full  cost 
assessment of the EU sustainability scheme is not  available, but estimates from one Member State 
indicates  that  initial  compliance  costs  for  preparatory  work  for  the  sustainability  scheme  at  the 
Member State level  could amount  to ca.  120 000 EUR and the system establishment costs ca. 130 
000 EUR. As regards annual running costs, i.e. once systems are established, can amount to 40 000 
EUR  (incl.  scheme  auditing,  supplier  auditing,  follow-up  and  updating  the  scheme,  miscellaneous 
costs)191. 

The 2015 Fitness Check for the EU petroleum refining sector indicated that, for EU refineries, the 
most relevant implication of the RES Directive is the potential reduction of EU demand for fossil-
based fuels due to their substitution by biofuels. The same evaluation suggests an associated impact 
on average EU refining margins between EUR 0.01 and EUR 0.20 per barrel of throughput during 
the  period  2006  to  2012,  and  between  EUR  0.01  and  EUR  0.35  in  2012.  At  the  same  time,  the 
average effect (i.e. the forgone annual net earnings of the EU refineries) of a possible decrease in the 
utilisation rates of refineries because of a demand drop  due to the RES Directive was estimated at 
3.65 euro cents per barrel of processed crude oil192.  

A final impact on the refining sector consists of additional expenditures associated with the blending, 
storage, and transportation of biofuels. According to industry data (Concawe 2014), these amounted 
to  EUR  0.5  million  annually  per  refinery  during  2000-2012,  and  EUR  0.9  million  annually  during 
2008-2012. In relative terms, both numbers  correspond to about EUR 0.01 per barrel of refineries’ 
throughput.  

The sustainability scheme, however, has not achieved all of its objectives as by design it is not able 
to address GHG emissions due to ILUC which is caused by the additional demand for agricultural 
crops.  Against  this  background  the  EU  introduced  with  the  ILUC  Directive  (Directive  (EU) 

190 
191  
192  

Ecofys (2014) 
AEBIOM, 2016, based on Finnish Biomass association 
"Sectoral fitness check for the petroleum refining sector", 2015, (SWD (2015) 284) and "EU Petroleum Refining 
Fitness Check: Impact of EU Legislation on Sectoral Economic Performance", 2015, (JRC, 2015) 

  47 

 
 
 
 
                                                           
2015/1513)  a  7%  CAP  on  the  contribution  of  food  based  biofuels  towards  the  renewable  energy 
target in transport.  

6.3. 

Relevance 

6.3.1.  To  what  extent  were  the  objectives  of  the  RES  Directive  relevant  to  the  needs  of  the  EU 
Energy and Climate Change policy? To what extent does the RES Directive remain relevant 
for  the  Energy  Union  priorities,  the  2030  Energy  and  Climate  Framework  and  COP  21 
global climate commitments? 

The  2020  renewable  energy  targets,  and  the  whole  RES  Directive,  were  part  of  the  EUs  strategic 
energy  objectives  to  reduce  CO2  from  energy  use,  and  the  wider  objectives  to  limit  the  global 
average  temperature  increase,  make  the  EU  energy  more  energy  secure  and  contribute  to  the  EU 
competitiveness, in particular with respect to new energy technologies to stimulate a EU leadership 
position193.  Furthermore,  the  Energy  and  Climate  Change  policy  towards  2020  called  for  greater 
empowerment  of  consumers  and  stronger  collaboration  on  energy  policies  amongst  the  Member 
States, within a pan-European integrated energy market. 

The  RES  Directive  has  provided  the  legal  framework  to  achieve  the  above  objectives,  support 
cooperation  among  Member  States  and  provide  investors  with  confidence  to  invest  in  new 
production,  transport,  and  storage  options  for  renewable  energy  sources.  More  than  six  years  after 
the  entry  in  force,  the  RES  Directive  continues  to  be  relevant  to  address  these  objectives.  In 
particular, through increased renewable energy deployment, it has contributed to: 

  Reductions in CO2 emissions at EU level (at least 380 Mt of gross avoided CO2 emissions at 

EU level in 2014)194; 

 

Improved  security  of  supply  by  reducing  consumption  and  import  of  fossil  fuels  (demand 
reduction  for  fossil  fuels  by  114  Mtoe  in  2014195  and  avoided  imported  fuel  costs  around 
€20bn in 2014196); 

  Net  positive  impact  on  employment  (half  a  million  additional  jobs  in  the  EU-27  between 

2008 and 2014197); 

  Other  economic  and  climate  benefits,  such  as  better  health  and  reduced  local  air  pollution. 
The OECD has estimated that the economic cost of damage to health from poor air quality 
amounts to about 4% of GDP on average in the countries with the highest GHG emissions198.  

The  EU  ambition  to  move  towards  a  low-carbon  economy  and  a  more  sustainable,  secure  and 
competitive energy system has been confirmed within 2030 climate and energy objectives with the 
EU commitment to achieve at least an 27% binding EU level share of renewables by 2030, and as 
one of the five dimensions of the Energy Union.   

193  
194  
195  
196  
197  
198  

2006 and 2008 Impact Assessments, SEC (2006) 1719 and SEC (2008) 85  
"Renewable Energy in Europe 2016 – Recent growth and knock-on effects", EEA, 2016, No 4/2016 
"Renewable Energy in Europe 2016 – Recent growth and knock-on effects", EEA, 2016, No 4/2016 
"“Draft Renewable Energy Progress Report”, Öko Institute [to be published] 
Based on EurObserv'ER database and EurObserv'ER 2015 report 
OECD Business and Finance Outlook 2016, OECD, 2016 

  48 

 
 
 
 
                                                           
These EU commitments were renewed in the Paris COP21 Agreement, which "recognised the need 
for an effective and progressive response to the urgent threat of climate change" and required that 
"all  parties  formulate  long-term  low  greenhouse  gas  emission  development  strategies"  and  "foster 
sustainable development"199.  

In light of these developments, the RES Directive remains relevant not only to achieve the EU 2020 
energy  and  climate  objectives,  but  also  to  prepare  the  EU  for  the  new  approach  towards  the  2030 
targets, considering in particular the need to achieve the at least 27% RES target collectively at EU 
level  (without  recourse  to  national  binding  targets)  in  a  cost-effective  way,  and  to  fulfil  the  EU 
ambition  to  be  the  world  leader  in  renewable  energy.  Moreover,  it  is  a  necessary  stepping  stone 
towards the 2050 decarbonisation commitments assumed by the EU. 

This  calls  for  revisiting  and  reinforcing  specific  areas  covered  in  the  current  RES  Directive  in  the 
context of the forthcoming revision proposal of the Renewable Energy Directive for the post 2020 
period. These areas are: 

  Effort  sharing,  national  contributions,  Member  State  and  regional  cooperation,  and  their 

relevance for the new 2030 climate and energy target architecture;  

  National planning and governance of Member State contributions;  

  Framework conditions for greater encouragement of renewable energy investments; 

  Principles on the design of support schemes; 

  Market  integration  of  renewable  electricity,  cost-effectiveness  and  increased  role  for 

consumers, including, self-consumption;  

  Relevance  and  adequacy  of  the  current  provisions  on  renewable  energy  promotion  in  the 

energy heating and cooling and buildings, as well as in the transport sector; 

  Sustainability criteria for the bioenergy use, and 

 

Incentives for innovation in technology, processes and systems. 

In  the  light  of  the  new  2030  target  architecture  and  wider  EU  energy  legislative  reviews,  some  of 
these legal provisions will require simplification and integration within other EU energy legislation, 
while others will need to be adapted and eventually expanded to make them fit for a cost effective 
delivery  of  2030  energy  and  climate  targets,  the  Energy  Union  Strategy  priorities  and  the  EU 
ambition to be the world leader in renewables.   

Bearing  in  mind  the  impacts,  as  discussed  in  section  5.3  and  6.1.4,  the  RES  Directive  and,  most 
importantly, its adaptation to the new EU energy and climate framework for 2030 remain  relevant 
for  at  least  three  of  the  five  pillars  on  which  the  Energy  Union  is  built,  notably  energy  security, 
decarbonisation, research and innovation, and competitiveness. A continued and sustained renewable 

199  

Article 4.19 and Article 6.4a of Paris COP 21 agreement 

  49 

 
 
 
 
                                                           
 
development will be necessary for the EU to be able to continuously reduce costly energy imports 
and import dependency, reduce GHG emissions and develop an innovative and competitive industry. 

6.3.2.  To what extent is the RES Directive complementary to other EU initiatives in the field and 

has synergies with them? 

The  RES  Directive  complements  EU  initiatives  to  reduce  greenhouse  gas  emissions,  most  notably 
the European Emissions Trading Scheme (ETS), by increasing the share of low-carbon technologies 
in  the  energy  sector.  Similarly  renewable  fuels  contribute  towards  the  6%  reduction  in  the 
greenhouse gas (GHG) intensity of fuel required by Article 7a of the Fuel Quality Directive (FQD). 
Furthermore,  the  RES  Directive  supports  EU  initiatives  to  ensure  security  of  supply,  such  as  the 
energy security package presented by the Commission in February 2016200, by promoting the use of 
indigenous energy resources, promoting energy diversification and reducing the reliance on imported 
fuels. The RES Directive has also encouraged continuous deployment of RES technologies, therefore 
supporting  the  creation  of  new  opportunities  for  local  jobs,  economic  activity  and  improved 
competitiveness, while at same time contributing to technology development and bringing innovative 
technologies on the market. 

The  existing  synergies  between  the  RES  Directive  and  other  EU  initiatives  will  have  to  be 
strengthened  beyond  2020.  In  particular,  the  provisions  regarding  the  administrative  procedures, 
regulations and codes (Art. 13), and access to, and operation of the grids (Art. 16) in the electricity 
sector will need to be aligned and simplified according to the new electricity market design package. 
Similarly, future provisions regarding the achievement of the EU-wide renewable energy target will 
need  to  be  aligned  with  the  Governance  framework  for  the  Energy  Union.  The  synergies  between 
Article 13(4) of the RES Directive on increasing the share of renewable energy in the heating and 
cooling  and  building  sector  and  those  of  Energy  Efficiency  Directive  and  Energy  Performance  of 
Building Directive will also need to be improved and simplified. 

6.4. 

Coherence 

The analysis on coherence places the RES Directive into the wider context of energy market, energy 
and  climate  policy  legislation,  including  the  ETS.  The  2015  State  of  the  Energy  Union  report201 
confirmed  that  the  EU  climate  and  energy  legislation,  including  the  EU  Emission  Trading  System 
and Effort Sharing Decision, the RES Directive and the Energy Efficiency legislation, are effectively 
contributing in a consistent and coherent fashion to the achievement of the EU climate and energy 
objectives for 2020. Nevertheless, further work remains to be done in each of the areas at national 
and EU level in order to ensure their timely implementation. 

6.4.1. 

Is  the  RES  Directive  coherent  with  other  EU  policies  in  the  area  of  energy  and  climate 
change? 

The  evaluation  indicates  that  the  Renewable  Energy  Directive  has  been  coherent  with  the  EU 
policies  for  combating  climate  change,  reducing  greenhouse  gas  emissions,  achieving  sustainable 
development and ensuring security of supply and improved energy efficiency. These include: 

200  

201  

The  package  adopted  by  the  Commission  consists  of  proposals  for  a  Security  of  Gas  Supply  Regulation,  a 
Decision  on  Intergovernmental  Agreements  in  energy,  a  strategy  for  liquefied  natural  gas  (LNG)  and  gas 
storage, and a strategy for heating and cooling 
"State of the Energy Union 2015", COM (2015) 572 final 

  50 

 
 
 
 
                                                           
 

the  EU  Emissions  Trading  Scheme  (ETS)  before  and  after  2020202,  and  its  impact  on  the 
competitiveness of renewable energy resources; 

  Directive on internal electricity market; 

 

the requirements on State Aid; 

 

the  existing  and  revised  Directive  on  Energy  Efficiency203,  the  Energy  Performance  of 
Buildings (EPBD) Directive204,  

 

the Commission Communication on an European strategy for low-emission mobility205;  

 

the Commission Communication on global technology and innovation leadership206 

Coherence with ETS 

The  functioning  of  the  ETS  and  the  renewables  contribution  to  GHG  reductions  are  closely 
interlinked  and  complementary207.  Both  instruments  aim  at  decarbonising  the  energy  system.  The 
deployment of renewables induced by the Directive has contributed to a slight reduction in demand 
for EU ETS allowances. However, the overall surplus of allowances (2 billion allowances surplus at 
the start of 2013)  implies  that the price-dampening  effect of new renewable  energy was extremely 
limited. The overall deployment of renewables induced by the Directive has worked in synergy with 
the EU ETS by ensuring that regulatory, administrative and energy operating systems adapted to a 
low carbon energy future and allowed the ETS price signal to feed through to suppliers.   

Several economic and political developments (e.g. lasting demand reduction resulting from financial 
crisis  in  2008)  resulted  in  an  ETS  price  that  remained  lower  than  expected.  While  the  ETS  was 
successful  in  reaching  the  agreed  decarbonisation  targets,  the  carbon  price  remained  too  low  to 
achieve  also  a  substantial  shift  from  carbon-based  power  production  to  RES  generation.  The  RES 
Directive  therefore  is  an  important  complementary  instrument  to  ensure  the  shift  of  the  electricity 
generation assets towards RES production.  

The  strengthened  EU  ETS,  with  a  functioning  Market  Stability  Reserve,  should  contribute  to 
improving the investment signal for lower carbon technologies, including renewables, in the future, 
further enhancing the case of full consistency and mutually supportive instruments. 

Even though the ETS carbon price can be expected to increase as scarcity in the carbon market will 
resume,  the  uncertainty  on  long  term  CO2  price  development  seems  to  remain  an  impediment  for 
investors to fully factor in future prices in investment decisions. 

Coherence with internal electricity market legislation 

202  

203  
204  
205  
206  
207  

"Proposal  for  a  Directive  of  the  European  Parliament  and  of  the  Council  amending  Directive  2003/87/EC  to 
enhance cost-effective emission reductions and low-carbon investments", 2015, COM(2015)337 final 
2016/ENER/002- final references to be added 
2016/ENER/023- final references to be added 
Communication on an European strategy for low-emission mobility, 2016 
Final references to communication on Technology Innovation and Leadership Initiative to be added 
"A policy framework for climate and energy in the period from 2020 up to 2030", SWD(2014) 15 final 

  51 

 
 
 
 
                                                           
With significantly increasing volumes of RES production, the issue of consistency between internal 
market rules and RES Directive gained importance in recent years. National support schemes often 
incentivised  RES  production  without  sufficiently  taking  into  account  the  actual  demand  for 
electricity or the infrastructure situation. This led to increased electricity production in times when it 
was not needed and at places where it could not be transported efficiently. Support schemes which 
do  not  sufficiently  respond  to  market-signals  reduce  the  capability  of  the  electricity  wholesale 
electricity  market  price  to  act  as  central  steering  mechanism  for  effective  and  cost-efficient 
electricity  trade  and  investment  decisions.  Such  distortions  entail  the  risk  of  fragmenting  national 
markets,  thereby  counteracting  the  purpose  to  use  cross-border  trade  and  aggregation  of  variable 
RES across borders to drive down prices for consumers. The Commission has described this problem 
extensively in its Communication on State Interventions in energy markets208.  

There is also an interlink and coherence with the Internal Electricity market provisions to the extent 
that the RES Directive addresses grid system issues, such as a guarantee of access for RES into the 
grid and developed the role of the Guarantees of Origin, as well as with regard to the infrastructure 
development provisions in Art 16.  The 2009 RES Directive established priority access and dispatch 
for renewable energy to compensate for electricity market rules not providing renewable producers 
the opportunity to fully participate in the market209.  

In this light, the provisions in the RES Directive will need to be revised and streamlined to ensure 
continued coherence with the future design of the Electricity Market. Overall, this could result in a 
simplification of EU legislation as market related provisions could be integrated into one single piece 
of EU legislation. Furthermore, while transmission system operators (TSOs) set out their needs in the 
ten year national plans, distribution grid companies (DSOs) are less transparent regarding upcoming 
infrastructure  requirements.  An  interaction  in  the  investment  planning  process  between  TSOs  and 
DSOs could effectively increase the efficiency and effectiveness of the investments. In this regard, 
the REFIT evaluation study indicated that, due to the fundamental change of the energy system by 
integrating  decentralised  RES,  the  whole  planning  process  should  consider  switching  from  a  top-
down planning into an integrated process, where TSOs also consider the grid expansion at the DSO 
level210.  

Coherence with State Aid  

The  Commission's  guidance  for  the  design  of  renewables  support  schemes211,  followed  by  the 
Guidelines  on  State  Aid  for  Environmental  Protection  and  Energy  2014-2020  (2014  EEAG)212, 
triggered  the  emergence  of  more  market  based  support  schemes  and  slight  improvement  in  the 
convergence  of  national  support  schemes,  also  as  Member  States  started  learning  from  each  other 
relevant practices and experiences. However, the 2014 EEAG only apply until 2020. They are to be 
assessed  and  revised  in  the  coming  years,  which  is  raising  significant  uncertainty  amongst 
stakeholders  as  to  their  content  after  2020.  Binding  framework  principles  for  the  RES  support 
schemes do still not exist in EU energy legislation. Investors, Member States and other stakeholders 

208  

209  

210  

211  

212  

See Communication "Delivering the internal electricity market and making the most of public intervention" of 
5.11.2013 -  C(2013) 7243 final 
Due  amongst  other  things  to  the  lack  of  liquid  intraday  and  balancing  markets,  the  absence  of  rules  fit  for 
renewables, the lack of sufficiently flexible power systems 
"Mid-term evaluation of the Renewable Energy Directive. A study in the context of the REFIT Programme", CE 
Delft , 2015 
"Commission Staff Working Document - European Commission guidance for the design of renewables support 
schemes",  SWD(2013) 439 final 
"Guidelines on State aid for environmental protection and energy 2014-2020", OJ 2014/C 200/01 

  52 

 
 
 
 
                                                           
have  called  on  various  occasions  for  clarity  to  be  provided  on  the  future  framework  principles  for 
support  schemes  after  2020  through  the  revision  of  the  Renewables  Directive  in  complementarity 
with State Aid rules.213 

Coherence  with  the  Energy  Efficiency  Directive  (EED)  and  Energy  Performance  of  Buildings 
Directive (EPBD) 

The RES Directive requires Member States to introduce minimum levels of renewable resources in 
new buildings and in existing buildings that are subject to major renovations. This provision is set to 
fully  complement  the  requirements  for  nearly-zero  energy  buildings  and  energy  performance 
standards in the existing EPDB directive.  

Various  stakeholders  pointed  to  the  need  for  improved  alignment  of  the  national  measures  to 
implement relevant European directives in the area of energy efficiency and promotion of renewable 
energy  use  in  heating  and  cooling  and  buildings  (i.e.  the  Energy  Efficiency  Directive,  the  Energy 
Performance of Buildings Directive and the Renewable Energy Directive). 

Continued coherence will need to be ensured between the revised RES Directive, the revised Energy 
Efficiency  Directive  and  the  revised  Energy  Performance  of  Buildings  Directive,  particularly  as 
regards possible future provisions on renewables deployment in the heating and cooling sector. 

Coherence with other policies  

The development of a market for renewable energy sources has a clear positive impact on regional 
and  local  development  opportunities,  rural  development,  export  prospects,  social  cohesion  and 
employment opportunities, especially as it concerns small and medium-sized undertakings as well as 
independent  power  producers.  Renewables  (especially  solar  PV  technologies)  usually  create  more 
jobs than conventional energy per unit of energy generated, capacity installed or investment. In the 
EU,  this  is  amplified  by  the  fact  that  the  RES  value  chain  is  mostly  European  (manufacturing, 
construction,  maintenance,  agriculture,  tertiary  and  research….),  while  the  largest  share  of 
employment in the oil, natural gas and coal sectors is found in resource extraction and tertiary214. 

6.5. 

Added value 

The  following  three  evaluation  questions  on  added  value,  given  that  they  are  closely  interlinked, 
have been addressed jointly.  

213  

214  

This  was  precisely  highlighted  by  Member  States  and  stakeholders  in  the  conclusions  of  the  Electricity 
Regulatory Forum held in Florence on 13-14 June 
"Renewable energy jobs: Status, Prospects & Policies ", IRENA, 2011 

  53 

 
 
 
 
                                                           
6.5.1.  What is the EU added value of the RES Directive (can the objectives be better achieved by 

action at the EU level)?  

6.5.2.  Why could the RES Directive objectives be better achieved by EU action? 

6.5.3.  Would it be possible to achieve the same results in the absence of the RES Directive? 

The  Renewable  Energy  Directive  as  whole  and  its  specific  requirements  (e.g.  national  binding 
targets,  national  renewable  energy  action  plans,  grid  access)  had  an  added  EU  value  effect  on  the 
renewable  energy  deployment  in  all  Member  States.  Former  experience  with  2001  and  2003 
indicative  targets  for  renewable  electricity  and  transport  proved  that,  without  binding  targets, 
substantial  RES  deployment  would  have  remained  very  low  and  limited  in  few  Member  States215. 
Furthermore, the added value of the indicative interim trajectory consisted in ensuring that measures 
to  achieve  the  national  binding  targets  are  introduced  timely,  with  clear  benchmarks  for  following 
the progress and assessment of Member State actions.  

The Directive as a whole and its provisions on the national binding targets, together with the national 
measures  adopted  by  Member  States  to  achieve  these  targets,  resulted  in  economies  of  scale  and 
technology cost reductions and  development of  new on-shore and  off-shore wind and  photovoltaic 
capacity and the rise in PV deployment for self-consumption as already elaborated in this document. 
This EU added value effect remains valid and will become even more relevant as the EU prepares to 
move  from  the  current  national  binding  target  framework  to  an  EU  level  binding  target  of  at  least 
27% for 2030. In the absence of national binding targets for 2030, the achievement of this target will 
ultimately rely on Member States contributions to the EU level target. 

The  National  Renewable  Energy  Action  Plans,  required  by  the  RES  Directive,  increased  the 
transparency  of  the  measures  and  expected  renewable  energy  technology  choices  planned  by 
Member  States  in  the  area  of  renewable  energy  deployment,  and  this  information  on  national 
strategies  and  technology  choices  provided  a  considerable  added  value for  investors.  Even though, 
actual policy measures and technology deployment rates by 2015 eventually started to differ from the 
initial  Member  State  intentions  outlined  in  the  plans,  they  still  served  as  useful  reference  in  the 
assessment of actual RES market developments in Member States and the EU as a whole. Overall, 
the  benefits  of  this  national  planning  obligation  were  rated  high  for  all  five  Better  Regulation 
criteria216. 

Despite their slow uptake, the renewable energy cooperation mechanisms (Articles 6-12) eventually 
provided an EU added value and incentive for exploring regional cooperation and joint initiatives in 
renewable energy development. Best-practice sharing amongst Member States in different stages of 
advancement in RES policies and previous RES development record through the Concerted Action 
for the Renewable Energy Directive is just one such example of the EU added value. Member States' 
working  parties  on  RES  support  schemes,  including  RES  cooperation  mechanisms,  and  biofuel 
sustainability  have  been  amongst  the  most  active  working  formats  in  the  Concerted  Action  on  the 
Renewable Energy Directive.  

215  
216  

CE Delft, 2015 
See Fitness check of the Reporting, Planning and Monitoring Obligations in the EU energy acquis. Reference 
number to be added when this REFIT is adopted 

  54 

 
 
 
 
                                                           
The  evaluation  also  indicated  that  unexpected  and  eventually  retroactive  changes  in  national 
renewable  energy  support  schemes  occurring  in  some  Member  States  had  a  cross-border  effect  on 
investments  in  other  Member  States.  Whilst  this  was  already  addressed  through  the  Commission's 
Guidance  on  the  support  schemes217  and  the  revised  Energy  and  Environment  State  Aid 
Guidelines218 and it is still up to Member States to decide which specific renewable energy support 
measures  they  use,  a  need  for  some  of  principles  on  renewable  energy  support  across  all  Member 
States is emerging from the views expressed in the public consultation and the continuous exchanges 
on the RES support schemes in the Concerted Action for the RES Directive219. A number of Member 
States  are  already  moving  towards  increased  regional  cooperation  on  renewable  energy  support, 
including  partial  opening  of  their  support  schemes  to  RES  producers  from  neighbouring  Member 
States.  

By excluding the production of biofuels on areas of high biodiversity and carbon value and by laying 
down  biofuel  sustainability  criteria  and  methodology,  the  RES  Directive  has  equally  established 
common EU sustainability criteria, preventing market fragmentation and potential trade barriers that 
could have been created in case of diverging national sustainability rules.  

The  RES  Directive  (and  the  energy  efficiency  legislation)  served  as  a  reference  for  establishing 
dedicated investment priority lines supporting Member State investments in transition to low carbon 
economy in the European Structural and Investment funds, and for the EIB group lending, including 
in the framework of the European Fund for Structural Investments. These priorities remain valid, as 
the  EU  prepares  itself  for  achieving  the  2030  energy  and  climate  targets  in  line  with  its  COP21 
commitments and renewed commitment to foster sustainable and green investments220. 

Finally, the RES Directive (together with other parts of 2009 climate and energy package) and the 
EU  global  leadership  role  on  renewable  energy  contributed  to  the  global  spill-over  of  renewable 
energy  policies.  In  2015,  at  least  173  countries  had  adopted  renewable  energy  targets  (not 
considering the intended nationally determined contributions prior to COP21), and an estimated 146 
countries had renewable energy support policies221. 

7. 

CONCLUSIONS AND RECOMMENDATIONS   

The comprehensive REFIT evaluation study of the Renewable Energy Directive carried out between 
2014 and 2015 concluded that the objective of sustainably increasing the share of renewable energy 
in the EU final energy consumption has been successful. The binding national targets, the National 
Renewable  Energy  Action Plans and the biennial monitoring222 provided for by the RES Directive 
have  been  particularly  effective  for  promoting  transparency  for  investors  and  other  economic 
operators,  and  have  ensured  high  quality  information  on  renewable  energy  markets  and  policies  in 

217  

218  

219  

220  
221  
222 

"Commission Staff Working Document - European Commission guidance for the design of renewables support 
schemes",  SWD(2013) 439 final 
Communication from the Commission "Guidelines on State aid for environmental protection and energy 2014-
2020", OJ 2014/C 200/01 
This  was  precisely  highlighted  by  Member  States  and  stakeholders  in  the  conclusions  of  the  Electricity 
Regulatory Forum held in Florence on 13-14 June 
"Europe investing again: Taking stock of the Investment Plan for Europe and next steps", COM (2016) 359 final 
Renewables 2016 - Global Status Report, REN21, 2016. 
National  Renewable  Energy  Action  plans  and  biennial  national  renewable  energy  progress  reports  are  legal 
requirements set out in Art. 4 and Art.22 of the Renewable Energy Directive  

  55 

 
 
 
 
                                                           
the Member States. This is illustrated by the rapid deployment increase after the date of adoption of 
the Directive, passing from 10.4% share of renewables in 2007 to 17% in 2015223.  

These legal provisions, together with additional national policies and other non-regulatory measures, 
have  contributed  to  the  overall  achievement  of  EU’s  energy  and  climate  policy  goals,  resulting  in 
greenhouse  gas  emission  saving,  increased  security  of  energy  supply,  innovation  leadership, 
employment  creation,  public  acceptance  and  regional  development.  They  have  proved  their 
relevance,  coherence,  efficiency,  effectiveness  and  added  value  for  the  overall  EU  energy  and 
climate  change  objectives.  Renewable  energy  is,  currently,  the  only  decarbonisation  option  in  the 
power  sector  deployed at  a  rate that  is  close  to  what  is  required  under long-term  IEA  scenarios  to 
limit global temperature rise to 2◦C above pre-industrial levels224. 

However, even  if the EU and all  but  one  Member  States  are currently on track  towards  its overall 
renewable energy 20% target for 2020, target achievement by 2020 will only be secured if Member 
States  continue  to  meet  their  increasingly  steep  trajectories.  Furthermore,  the  sectorial  10% 
renewable  energy  target  in  transport  will  not  be  met  at  the  current  progress  rate.  The  regulatory 
uncertainty caused by the long political discussion on ILUC, the late adoption of the amendments on 
ILUC to the RES Directive and the lack of a post-2020 policy for transport, together with the lack of 
commercial availability of alternative fuels and advanced biofuels at the needed scale and pace, have 
had a negative impact in the deployment of renewables in the transport sector. 

In addition, the effectiveness of the national targets, based on a flat-rate/GDP approach (as opposed 
to  an  approach  based  on  national  potential,  which  would  have  been  more  cost  effective,  but 
considered  less  equitable225)  was,  however,  compromised  by  the  fact  that  flexibility  and  trading 
options were not utilised by the Member States as expected during the reference period. However, 
intergovernmental negotiations that were held in 2015 and 2016 amongst several potential "selling" 
and "buying" Member States, demonstrate increasing mobilisation of efforts towards concluding the 
first renewable energy cooperation agreements.  

Another  issue  which  requires  follow-up  is  the  level  of  investments  in  renewable  energy.  Their 
decline after 2011 due to undermined inverstor confidence and some external factors highlights the 
need to reflect on how investors' legitimate interests can be better protected. 

The REFIT evaluation study of the RES Directive has also pointed to a number of shortcomings in 
the Renewable Energy Directive: 

  National  renewable  energy  action  plans:  While  the  national  renewable  energy  action  plans 
provided transparency and information for investors on Member States' plans for  renewable 
energy development, they eventually became outdated as the RES Directive does not require 
their  regular  updating  to  adjust  them  to  policy  and  global  economic  changes.  This 
shortcoming  was  largely  compensated  by  biennial  national  RES  progress  reports  that 
provided  regular  updates  on  national  regulatory  and  financial  measures  in  the  renewable 
energy  space.  In  the  context  of  the  new  2030  Climate  and  Energy  Framework  and  Energy 
Union  Governance  process,  the  current  legal  provisions  on  the  planning  and  reporting  will 
need to be revised for post 2020 period. 

223  

224  
225  

EUROSTAT 
IEA, 2015 
"Package  of  Implementation  measures  for  the  EU's  objectives  on  climate  change  and  renewable  energy  for 
2020", 2008, SEC(2008) 85 

  56 

 
 
 
 
                                                           
  Cooperation mechanisms: The cooperation mechanisms set out in the RES Directive have not 
yet  been  used  to  any  significant  extent  by  Member  States,  with  exception  of  the  joint 
Swedish-Norwegian  support  scheme.  In  the  RES  Directive,  the  use  of  cooperation 
mechanisms is voluntary and Member States have so far, for various reasons, preferred to use 
national renewable energy sources for target achievement. The opportunity given by the RES 
Directive  to  share  the  efforts  to  achieve  the  renewable  energy  target  cost-effectively  has, 
therefore,  been  rather  underused.  However,  as  national  interim  trajectories  become  steeper 
after 2015, a number of Member States are currently in active phase of negotiations aiming to 
conclude such cooperation mechanisms, in the form of a partial opening of national support 
schemes,  or  statistical  transfers.  Even  so,  revised  provisions  providing  Member  States  with 
financial incentives or obliging them to resort to cooperation mechanisms might be needed to 
foster regional cooperation and ensure that the 2030 renewable target is achieved collectively 
and cost-effectively.   

  Renewable  energy  support  schemes:  Pursuant  to  Article  3(3)  of  Directive  2009/28/EC, 
support  schemes  are  but  one  instrument  -  amongst  others  -  that  can  be  chosen  by  Member 
States to achieve the binding national RES targets. The majority of the Member States though 
used them as part of their RES policies. In the absence of clear principles established in the 
RES Directive, Member States had wide discretion in their decisions on the design and scope 
of  renewable  energy  support  schemes.  As  the  cost  of  renewable  energy  technologies  fell, 
several  national  support  schemes  were  unable  to  be  adapted  rapidly  enough.  As  a  result, 
technology bubbles were encouraged, resulting in market distortion and fragmentation. 

  Administrative procedures: Administrative and planning systems are very diverse across the 
EU  Member  States  and  progress  in  simplifying  them  has  been  hampered  due  to  the  large 
margin of discretion left in the legal provisions of Art. 13(1). Clear and transparent rules are 
not yet in place in all Member States and at all necessary levels. The absence of clear legal 
requirements  to  establish  one  administrative  entity  (one-stop  shop)  for  the  permit  granting 
procedures  and  the  absence  of  maximum  time-limits  for  permit  granting  in  Member  States 
are still perceived as major administrative obstacles and an additional cost burden to project 
developers.  In  view  of  tackling  investment  bottlenecks  and  lengthy  project  approval 
procedures,  further  reinforcement  of  these  provisions  might  need  to  be  considered  for  the 
amended post 2020 legislation226.  

  Renewable  energy  in  heating  and  cooling  supply  and  buildings:  The  RES  Directive 
recommended  Member  States  to  promote  and  integrate  renewable  energy  in  the  urban  and 
local environment (e.g. newly developed areas, district heating and cooling systems), and to 
mandate renewable energy use through buildings codes for new buildings as of 2015, while 
leaving  full  discretion  to  the  Member  States  as  regards  implementation  modes.  Despite  the 
long term decarbonisation goal in the heating and cooling sector and in buildings, the existing 
framework  did  not provide sufficient  incentives for fuel switching from fossil to renewable 

226  

Building on the previous rather general requirement set out in Directive 2001/77/EC for Member States to take 
action to reduce and simplify administrative procedures, the impact assessment accompanying the proposal for 
the RES Directive considered a reinforced "national action" approach without specific EU guidance as the most 
appropriate way forward. However, the REFIT evaluation study concluded that even the reinforced provisions 
of Article 13(1) of the RES Directive have not substantially improved the situation and the public consultation 
for the present Impact Assessment demonstrated clear support for a more stringent approach and harmonised EU 
minimum rules in the post-2020 period 

  57 

 
 
 
 
                                                           
energy in the heat supply and buildings. Further reinforcement of these provisions might need 
to be considered in the revision of the Directive for post-2020. 

  Grid  access  rules:  Certain  provisions  of  the  RES  Directive  are  not  specific  enough  (e.g. 
providing deadlines for their implementation) for the purpose of enabling better monitoring 
and enforcement. The Directive also leaves discretion to Member States on whether shallow 
or  deep  grid  charging  is  applied,  which  considerably changes  the risk and  thus  the  cost  for 
new renewable installations across Member States. In view of the intended wider electricity 
market reform, some of the current legal provisions on RES electricity integration might need 
further streamlining and integration with the electricity market legislation.  

  Self-consumption:  The  RES  Directive  does  not  contain  specific  provisions  on  self-
consumption,  which  has  given  Member  States  a  wide  discretion  to  regulate  this  type  of 
emerging  form  of  renewable  energy  generation.  This  has  led  to  a  wide  range  of  policies 
across  the  EU,  some  of  them  hampering  self-consumption  development.  The  benefits  of 
introducing  framework  principles  on  self-consumption  to  guarantee  the  Energy  Union's 
objective  of  empowering  consumers  could  be  assessed  in  the  revision  of  the  legislative 
framework for post-2020. 

  Guarantees of origin (GO): The regulatory framework in the RES Directive has not provided 
sufficient  clarity  and  suitable  provisions  for  the  creation  of  a  comprehensive,  liquid  and 
harmonised GO system for all energy sources throughout the EU. It allows for the provision 
of  "green"  supply  contracts  which  are  dissociated  from  the  physical  delivery  of  renewable 
electricity. The revision of this provision in the context of the legislative work for the post-
2020  energy  framework  could  look  at  improving  the  consistency  in  the  application  of  the 
system by Member States as well as extending their use. 

  Bioenergy  sustainability:  Indirect  effects  of  biofuels  were  not  included  from  the  very 
beginning  in  the  legal  sustainability  scheme  for  biofuels  and  bioliquids,  creating  policy 
instability and a serious slowdown in investments, including in advanced biofuels. Different 
national  implementation  modes  of  the  criteria,  including  a  lack  of  mutual  recognition  of 
national  certification  schemes,  have  led  to  some  market  fragmentation.  Harmonized  and 
comprehensive  EU  sustainability  criteria  for  uses  of  all  solid  and  gaseous  biomass  in  the 
energy  sector  (electricity,  heating  and  cooling  and  transport)  were  not  included  either.  In  a 
post-2020  scenario  consideration  should  be  given  to  the  opportunity  of  revising  the 
sustainability criteria to account, not only for biofuels and bioliquids as it is already the case, 
but  also  for  solid  and  gaseous  biomass,  in  a  cost-efficient  way.  Furthermore,  the  future 
framework should give consideration to effective and pragmatic ways to enhance renewables 
deployment, notably advanced biofuels, in the transport sector, building on current practices 
of most Member States, including through improved incorporation mandates across the EU. 
Improved information and tracking systems are also needed to prevent fraud and abuse. 

  Synergies  and  coherence  with  other  EU  policies:  the  RES  Directive  complements  EU 
initiatives  to  reduce  greenhouse  gas  emissions,  such  as  the  European  Emissions  Trading 
Scheme (ETS) and the Fuel Quality Directive, and to ensure security of supply. Nevertheless, 
there is a need to review consistency given that many other legislative acts are in process of 
being  revised.  In  particular,  the  provisions  regarding  the  administrative  procedures, 
regulations  and  codes  (Art.  13),  and  access  to,  and  operation  of  the  grids  (Art.  16)  in  the 
electricity  sector  will  need  to  be  aligned  and  simplified  according  to  the  new  electricity 
market  design  package.  Similarly,  future  provisions  regarding  the  achievement  of  the  EU-

  58 

 
 
 
 
wide renewable energy target will need to be aligned with the Governance framework for the 
Energy Union. The synergies between Article 13(4) of the RES Directive on increasing the 
share of renewable energy in the heating and cooling and building sector and those of Energy 
Efficiency  Directive  and  Energy  Performance  of  Building  Directive  will  also  need  to  be 
improved  and  simplified.  Last  but  not  least,  clarity  should  be  provided  on  the  future 
framework  principles  for  support  schemes  after  2020  through  the  revision  of  the  RES 
Directive in complementarity with State Aid rules. 

  59 

 
 
 
 
 
 
Annex 1: Table on Member States' performance towards their renewable energy targets (%) 

Share of energy from renewable 
sources in gross final 
consumption of energy 

Targets 

Member States 

2014 

Indicative trajectory 
for 2013-2014 

2020 Target 

Belgium 

Bulgaria 

Czech Republic 

Denmark 

Germany 

Estonia 

Ireland 

Greece 

Spain 

France 

Croatia 

Italy 

Cyprus 

Latvia 

Lithuania 

Luxembourg 

Hungary 

5,4 

11,4 

8,2 

20,9 

9,5 

20,1 

7 

10,2 

12,1 

14,1 

14,8 

8,7 

5,9 

34,8 

17,4 

3,9 

6,9 

7,9 

18 

13,4 

29,2  

13,8 

26,5 

8,6 

15,3 

16,2  

14,3 

27,9 

17,1 

8,9 

38,7 

23,9 

4,5 

9,5 

  60 

13 

16  

13  

30  

18  

25  

16  

18  

20  

23  

20  

17  

13  

40  

23  

11 

13  

 
 
 
 
 
 
Malta 

Netherlands 

Austria 

Poland 

Portugal 

Romania 

Slovenia 

Slovak Republic 

Finland 

Sweden 

United Kingdom 

4,7 

5,5 

33,1 

11,4 

27 

24,9 

21,9 

11,6 

38,7 

52,6 

7 

3 

5,9 

26,5 

9,5 

23,7 

19,7 

18,7 

8,9 

31,4 

42,6 

5,4 

10  

14  

34  

15  

31  

24  

25  

14  

38  

49  

15  

Source: Eurostat  

  61 

 
 
 
 
 
 
Annex 2: Procedural information 

Directorate  General  for  Energy  (Unit  C1,  Renewables  and  CCS  policy)  was  the  lead  DG  on  the 
evaluation. A dedicated external study was commissioned in support of the evaluation process.  

A study Mid-term evaluation of the Renewable Energy Directive: A study in the context of the REFIT 
programme was commissioned to CE Delft, with the Final Report of this study completed in April 
2015. The interservice group with representatives from the following DGs met on the 2nd July 2015 
and took part in the quality assessment of the external study:  DG ENER, SJ, SG, AGRI, CLIMA, 
COMP, GROW, JRC, RTD and TAXUD. 

The Interservice Group recalled that the new Better Regulation Guidelines were adopted on 19 May 
2015. The Guidelines list five evaluation criteria (effectiveness, efficiency, coherence, relevance and 
EU added value of the intervention), which must be the basis of all evaluations, or evaluations must 
provide due justification why this has not been the case. Due the fact that evaluation study in support 
of REFIT Evaluation of the Renewable Energy Directive was carried out from 1 April 2014 (before 
the  new  Better  Regulation  Guidelines)  were  adopted  until  April  2015,  the  assessment  on  the  5th 
element, coherence, was not sufficiently well considered in the external evaluation study. The inter 
service group concluded that the analytical work for the assessment of coherence should therefore be 
carried  out  by  DG  ENER  experts,  and  a  full  assessment  based  on  all  5  assessment  elements  as 
required by the Better Regulation Guidelines should be fully reflected in the final evaluation SWD.  

The present evaluation SWD  includes  full assessment based on all  5 Better Regulation assessment 
criteria,  whereby  the  results  of  the  underlying  external  study  only  form  part  of  this  complete 
assessment. The rest of data and analysis constitutes a result of additional analysis carried out by DG 
ENER experts and results of stakeholder consultation.    

  62 

 
 
 
 
 
 
 
 
Annex 3: Synopsis report of stakeholder consultation in the context of the Study 

The  stakeholder  consultation  was  intended  to  get  feedbacks  of  the  RED  as  well  as  learn  about 
barriers and potential new ideas for REDII, through accessing the experiences of those most closely 
engaged in implementing the Directive, either as Member States, regional administrations, renewable 
and non-renewable industries, or as NGOs whose work is directly affected by it. The responses from 
these stakeholders form a major part of the analysis in the study. The consultation reflects the key 
principles  of  providing  'a  simple  consultation  strategy  identifying  the  encountered  barriers  and 
proposing potential solutions'. 

Implementing  the REDII Directive does  not  only engage the energy authorities in  Members  States 
but has implications for many other functions of government such as planning, economic, and rural 
development.  Because  they  have  implications  for  any  plan  or  project  affecting  the  grid  no  matter 
what its position (producer, TSO, DSO, end-user), and have a wider implications, they are of interest 
to  a  very  wide  range  of  private  sector  and  civic  in  fields  such  as  transport,  electricity,  heating  & 
cooling, commercial development.  

The  Study  applied  a  range  of  approaches  to  collect  feedbacks  but  also  allowed  for  unsolicited 
contributions of evidence from groups or interests. The main approaches were: 

  Meetings with EU stakeholders groups; 

  A public on-line questionnaire using EU Survey; 

  A dedicated High-level Conference (05.02.16). 

Meetings with EU stakeholders groups 

Thirteen EU focus group meetings were held: EGEC (17/12/2015), RESCoop (17/12/15), Eurelectric 
(15/01/2016),  Norsk  Industri  (20/01/2016),  IBEC  (21/01/2016),  GRDF  (01/02/2016),  SolarPower 
Europe,  European  Wind  Energy  Association,  Ocean  Energy  Europe,  European  Geothermal  Energy 
Council  (04/02/2016),  EWEA  (12/02/2016),  Greenpeace  (25/02/2016),  EGEC  +  AEBIOM 
(25/02/2016),  Euroheat & Power (02/03/2016), Danish Energy Agency (16/06/16), Spanish Energy 
Ministry (16/06/16). This provided an opportunity to explain and discuss the mandate questions with 
a  view  to  promoting  a  good  response  rate  from  the  different  stakeholder  groups.  In  total,  13 
organisations  participated  in  these  meetings.  Discussions  covered  various  range  of  topics  in  each 
case based around practical experiences of the operation of the Directive and ideas about improving 
the upcoming one.  

Open Public Consultation 

A  number  of  dedicated  evaluation  questions  were  included  in  the  public  consultation  on  the  new 
Renewable Energy Directive for the period after 2020 that took place from the 18th November 2015 
until 10th February 2016227.   

The  questionnaire  was  divided  into  five  sections:  general  approach,  empowering  consumers, 
decarbonising the heating and cooling sector, adapting the market design and removing barriers and 

227  

"Public consultation on the Renewable Energy Directive for the period after 2020: Analysis of stakeholder 
views", 2016 

  63 

 
 
 
 
                                                           
 
enhancing  renewable  energy  use  in  the  transport  sector.  This  questionnaire  asked  30  questions. 
Concerning questions on the RED and used for the present REFIT evaluation, eleven questions were 
relevant: 1, 2, 7, 10, 12, 15, 16, 24, 25, 28, 29, including some indirect questions as describing the 
barriers.  All  five  sections  were  covered.  The  questionnaire  did  limit  the  length  of  response  from 
stakeholders to 3600 characters, and was thus designed to allow scope for as much significant and 
pertinent information and evidence to be provided. 

The Commission received replies from 11 Member States. Most stakeholders answered most of the 
questions. The general distribution of stakeholder's responses is detailed in the following pie chart: 

Stakeholder categories 

NRAs 
0% 

Academia/Think-tanks 
1% 

Network operators 
1% 

Individuals 
6% 

Public Authorities 
6% 

Associations 
58% 

Undertakings 
30% 

NGOs 
13% 

Professional 
associations 
8% 

Industry 
18% 

RES industry 
15% 

Cooperatives  
2% 

Link to the Public Consultation Website: 
https://ec.europa.eu/energy/en/consultations/preparation-new-renewable-energy-directive-period-
after-2020 

Link to the Public Consultation survey and Link to the Individual submissions: 
(accessible via RES Public Consultation website): 
https://ec.europa.eu/energy/en/consultations/preparation-new-renewable-energy-directive-period-
after-2020 

Link to Public Consultation results (Summary): 

https://ec.europa.eu/energy/sites/ener/files/documents/Summary%20RED%20II%20Consultation.pdf 

High-Level Conference – 5th February 2016 

On  5th  February,  the  European  Commission,  DG  Energy,  organised  the  meeting  "EU  leading  on 
renewables  –  Consulting  stakeholders",  set  in  the  context  of  the  public  consultation  on  the 
Renewable Energy Directive for the post-2020 period. The encounter gathered over 100 officials and 
experts, representing industry, energy sector associations, consumer and energy users' organisations, 

  64 

 
 
 
 
 
 
 
 
 
regulators,  transmission  system  operators,  energy  efficiency  organisations,  governments,  local 
authorities,  renewables'  cooperatives,  financiers  and  project  developers,  NGOs  and  academia. 
Several  Commission  services,  the  European  Parliament  and  the  Dutch  Presidency  were  also 
represented (list of participants provided in annex). 

The  discussion  focused  on  three  points:  "Making  Renewables'  Happen",  i.e.  how  to  get  to  a 
minimum 27% share by 2030, "Empowering consumers and communities to reap off the benefits of 
renewables at local level", and "Financing renewables' deployment over 2020-2030". The exchanges 
were enriching throughout all three sessions, as acknowledged by many of the participants.  

Key messages from the RED Public consultation228 

Achieving a share of 20% of renewable energy by 2020 and binding national renewable targets 

The  vast  majority  of  the  responders  that  commented  on  the  evaluation  of  the  RES  Directive 
acknowledged  its  success  in  promoting  RES  deployment,  in  reducing  the  cost  of  technologies 
(especially PV) and in engaging MSs towards a decarbonised system. Indeed, there was a consensus 
among Member States and public authorities on the success of the RED helping to achieve the EU 
energy  and  climate  change  objectives.  These  views  are  also  supported  by  other  categories  of 
stakeholders, including non-conventional energy industries.  

With respect to the cost-efficiency of renewable energy incentives in Member States, among those 
stakeholders  who  answered  the  question  on  effectiveness  and  efficiency  of  the  Renewable  Energy 
Directive,  some  stakeholder  groups  criticized  the  RES  support  incentives  for  their  impact  on  the 
electricity prices. Others noted the absence of a competitive market environment as a barrier to RES 
investments. Most stakeholders tend to agree on the need to avoid retroactive changes in legislation 
that have harmful impact on investors trust. Some stakeholders stress the need to avoid mistakes like 
imposing taxes on PV imports and replace them e.g. with quality tests for such products. 

Overall stakeholders praised the importance of the EU renewable energy target and national binding 
targets as an effective stimulus for the renewable energy sector. Member State replies noted that in 
the absence of legally-binding national RES targets in the 2030 framework, cooperation mechanisms 
would be more relevant after 2020 and will have a more significant role in achieving the objective. It 
will provide the needed flexibility for the Member States while reaching overall European Union's 
climate and energy goals. 

Achieving  10%  target  for  the  2020  share  of  renewable  energy  in  the  transport  sector,  and 
sustainability scheme for biofuels 

There is a general agreement among different stakeholder groups that the RED has contributed to 
addressing the EU transport policy objectives.  

Renewable  energy  measures  for  transport  sector  (RES  targets,  mandates)  were  considered  as 
successful  means  to  address  the  EU  transport  policy  objectives  initiating  the  process  of  the 
decarbonisation of the EU transport sector, and the EU biofuel sustainability scheme is regarded as  
very  successful  at  increasing  efficiency  and  sustainability  of  biofuel  production  and  agriculture 

228  

Precise  quantification  of  stakeholders'  replies  in percentage  shares  was  not  possible  due  to the  fact  not all  questions  were 
answered  by  all  respondents.  In  some  cases,  only  half  of  respondents  replied  to  the  specific  question.  Quantification  of 
partial responses would lead to distorted representation of views.  

  65 

 
 
 
 
                                                           
sector. The producers of agriculture commodities, traders, biofuel  producers and  renewable  energy 
associations/ centres believe that the RED has contributed to the development of biofuel market and 
industry, with benefits also in terms of employment and rural development. But NGOs consider that 
the  RED  was  not  been  successful  due  to  indirect  land  use  change  (ILUC)  impacts  of  crop-based 
biofuels.  

However,  appreciation  of  the  Directives  success  with  respect  to  10%  renewable  energy  target  in 
transport, is less pronounced in the public consultation replies. The main reasons for the slow EU and 
Member State progress towards 10% renewables in transport, according to stakeholder views, is the 
slow uptake of advanced biofuels, biomethane, renewable electricity and hydrogen in transport sector 
so  far  (based  on  2015  data).  The  political  and  legal  uncertainty  linked  to  the  long  ILUC  Directive 
process was also quoted. Also the complexity, lack of clarity of the legal provisions of the RED, and 
the delay and lack of consistency of the RED implementation in the Member States were criticised. 
According some stakeholders, the RED could have delivered more, particularly as regards reduction 
of oil imports and air pollution.   

National Renewable Energy Action plans and national measures 

When asked about the main lessons from RED, the three most mentioned instruments contributing to 
the  Directive's  effectiveness  were  national  renewable  energy  action  plans  (NREAPs),  binding 
national renewable energy targets and biennial reporting. Altogether, these provisions are considered 
to  have  provided  clarity  on  national  renewable  energy  deployment  potential  and  have  driven 
investments in renewables across the EU. 

With  regards  to  national  plan,  many  stakeholders  consider  it  as  an  important  element  and  some 
believe that national plans have been useful and have contributed to target achievement.  

Considering  binding  national  renewable  energy  targets,  many  stakeholders  believe  that  national 
binding  target  is  the  best  method  to  ensure  compliance  with  the  EU  wide  target.  On  the  reporting 
obligation, many  stakeholders  concede  that  the  standardised  reporting  facilitated  the  monitoring  of 
the Member State actions and increased transparency for investors. Providing a detailed template for 
planning and reporting is a key lesson from RED.  

However, some stakeholders have pointed out that national plans would have been more effective if 
they  had  taken  environmental  sustainability  and  impacts  into  consideration,  have  had  a  spatial 
planning dimension and had to be periodically updated.  Overall, there is a broad consensus among 
stakeholders on the fact local RES is very much underexploited.  

Cooperation mechanisms 

The public consultation shows that the main reasons for the limited use of cooperation mechanisms 
to  date  according  to  stakeholders  have  been  Member  States'  reluctance  to  see  their  taxpayers  or 
consumers'  money  used  for  investments  outside  their  country  and  the  lack  of  cost-effectiveness  or 
uncertain benefit for individual Member States. Indeed, the majority of the respondents within 75% 
of the stakeholder groups - including the larger stakeholder groups like the RES industry - described 
as a key barrier the difficulties in communicating to the electorate that tax money has been spent on 
development  of  RES  projects  abroad,  as  this  implies  that  benefits  in  terms  of  for  instance  jobs, 
economic/  industrial  growth,  tax  income  and  security  of  supply  are  not  created  within  national 
borders. 

  66 

 
 
 
 
Besides,  the  administrative  and  regulatory  barriers  associated  with  making  use  of  cooperation 
mechanisms like for instance a joint support scheme is a core reason for why the use of cooperation 
mechanisms  has  been  limited.  Indeed,  network  operators  and  public  authorities  consider 
administrative  complexities  as  a  major  factor  explaining  the  limited  recourse  by  Member  states  to 
cooperation mechanisms whereas, non-renewable energy industries did not consider this factor as a 
major obstacle. 

The role of the guarantees of origin (GOs)  

Around 36% of stakeholders highlighted the low consumer awareness of the GO system, pointing to 
the need  for  more  transparency  and accuracy. A lack of consistent  basis for an effective European 
disclosure system with GOs has been pointed out. 

Strengthening the disclosure and the GO systems would generate more competition in the electricity 
market, lead to better offers for final customers, and facilitate the promotion of renewables. Around 
40%  of  the  respondents  to  the  stakeholder  consultation  supported  the  idea  that  GOs  should  be 
extended  to  all  kinds  of  production  (for  example,  coal,  gas  and  nuclear)  and  around  24%  were  in 
favour that information on CO2 emissions should be added to GOs in order to create more awareness 
of the origin of electricity. 

Administrative procedures  

Around  60%  of  all  respondents,  including  30%  of  the  Member  States,  have  not  replied  or  have 
expressed no option regarding the administrative burden and cost of compliance with the Renewable 
Energy Directive. 

Among those stakeholders that replied to the question on administrative barriers, the prevailing view 
is  that  progress  on  removal  of  administrative  barrier  has  been  limited  and  that  Art.  13  (1) 
provisions should be strengthened.  

Most  stakeholders  participating  in  the  public  consultation  believe  that  administrative  burden  and 
compliance costs for national and local authorities due to the Directive have been important or very 
important  (60%).  This  view  is  also  shared  by  the  majority  of  the  Member  States.  Administrative 
burden of the current legislation is associated with the development of the national renewable energy 
action plans (NREAPs) and the introduction and implementation of new legislation, including on the 
sustainability  scheme  for  biofuels,  system  of  Guarantees  of  Origin  etc.  Cooperatives  and 
representatives  of  local  communities  and  municipalities  point  out  that  there  seems  to  be  too  much 
administrative  burden  for  small  projects  as  administrative  barriers  weigh  more  on  small  local 
companies with a small portfolio then for big ones. 

Slightly  more  than  ½  of  the  respondents  that  expressed  an  opinion  (54%)  and  the  majority  of  the 
Member States (particularly smaller Member States) also believe that the cost of compliance with the 
RED  were  very  important  or  important.  Highest  costs  of  compliance  (for  final  consumers)  are 
associated  by  the  Member  States  with  support  schemes.  As  for  the  RES  and  conventional  energy 
industries,  it  is  the  lack  of  transparency  and  harmonised  EU  market  that  increased  both,  the 
administrative burden and costs of compliance for industry.   

RES in buildings and district heating and cooling  

The public consultation  highlighted an overwhelming  consensus  about the need to remove  barriers 
hampering  the  deployment  of  renewable  heating  and  cooling.  A  high  number  of  respondents, 

  67 

 
 
 
 
including  Member  States  and  renewable  energy  industry  regard  the  absence  of  a  functioning  heat 
market as an important barrier. 

Listing the barriers and measures in order of their importance, the vast majority of respondents quote 
the lack of energy strategies and planning at the national and local levels (for 84% of stakeholders), 
the lack of targeted financial resources and financing instruments (for 80% of stakeholders) and the 
lack  of  electricity  market  design  supporting  demand  response  as  very  important,  or  important, 
barriers hampering the deployment of renewable heating and cooling in the EU. 

Importance of barriers in hampering the deployment 
of RES H&C in the EU 

Negative public perception

Lack of tools and information to compare the…
Lack of mapping tools to identify the resources…
Lack of electricity market design supporting…
Lack of definition and recognition of renewable…
Lack of targeted financial resources and…
Heating and cooling equipment installers lack…
Lack of requirements in building codes and other…
Lack of physical space to develop renewable…
Lack of energy strategy and planning at the…
Lack of administrative capacity and/or expertise/…
Real or perceived incoherence in existing EU…

0%

20%

40%

60%

80%

100%

  68