C 152/132
EN
Official Journal of the European Union
6.4.2022
4.11.
With regard to the promotion of Power Purchase Agreements (Article 15), establishing guidelines coupled with financial support for small and medium-sized enterprises should encourage the development of such a scheme, which provides long-term visibility on the sale price of green electricity.
More generally, this initiative illustrates the need to strengthen cooperation and coordination between stakeholders in the sector in order to provide a long-term vision for economic actors.
4.12.
Another initiative welcomed by the EESC is the obligation for Member States to launch a test phase on cross-border cooperation by setting up a pilot project within the next 3 years.
The EESC would like clarification, however, on the arrangements for setting up such cooperation.
In particular, it wonders about the administrative procedures involved in such an initiative and calls on the European Commission to assist Member States (by translating documents relating to the procedure, etc.) to ensure they can meet the deadline that has been set.
4.13.
The EESC believes that the time has come to consider the relevance of a European electricity regulator.
In order to prepare properly for this important position, it is time to launch a conceptual system planning activity that will forecast the growing energy demand by area and type, as well as energy type transformations.
4.14.
The EESC also endorses the initiative in Article 9(7a) to introduce joint spatial planning per sea basin, between Member States, to facilitate the development of offshore capacity.
This approach would make it possible to maximise the potential of each maritime basin while ultimately strengthening the objective of electricity interconnection between countries.
The establishment of a one-stop shop is also welcome and must be an opportunity to learn from the best practices implemented in the different Member States in order to reduce the time needed to complete a project.
Setting a total production capacity per basin by 2030, 2040 and 2050 should also make it possible to take better account of each Member State’s offshore wind energy potential, and encourage its development.
In purely operational terms, the increase in cross-border renewable energy projects, in particular offshore wind, leads the EESC to call on the European Commission to reopen discussions on a European transmission system operator, as this would be the most appropriate level for the real-time management of electricity flows.
This is ultimately the most legitimate level for coordinating market mechanisms in relation to supply and demand, while ensuring the security of the system, which will come under increasing pressure with the greater penetration of renewables.
4.15.
The EESC has repeatedly stressed the need for new market structures to balance energy production and consumption at the micro level.
These structures would facilitate the integration of smaller storage devices into the energy system.
For example, the growth of electromobility should benefit from the role of batteries to enable smart charging and to provide storage capacity at the local level.
However, the revision proposal does not address this issue.
4.16.
The Clean Energy Package pays particular attention to self-consumption and energy communities.
These mechanisms are powerful vehicles for ensuring citizens’ participation and for making them conscious full actors in the energy transition by increasing their sense of ownership and by strengthening decentralised structures that are beneficial in both and economic and social terms.
As highlighted by the European Commission in its assessment of national energy and climate plans, Member States are not taking sufficient account of the potential of ‘energy citizenship’, thus contravening one of the raisons d’être of the 4th energy package.
There is an urgent need to clarify the applicable rules, in particular for concepts such as energy sharing, net metering and P2P energy sales, in order to meet the objectives of the Clean Energy Package and the Energy Union.
The EESC is disappointed that the proposed revision does not attempt to improve the regulatory framework on these aspects.
This will be all the more important as the proposed revision of the guidelines on state aid for the climate, energy and the environment sets a much lower threshold for exceptions to the obligation to grant aid and to determine the level of aid through a competitive procedure.
4.17.
The EESC in principle supports the Commission’s proposal calling on Member States to take into consideration ‘the maintenance of the national forest carbon sinks and ecosystems’ as well as the principles of ‘biomass cascading use’ and the circular economy.
This means prioritising the use of residual wood, such as small branches, tree stumps and other by-products, as well as recycled wood products for bioenergy.
Therefore, it makes sense to re-evaluate support for bioenergy plants in this area, bearing in mind that residues from sawmills and the pulp and paper industry are sources of energy.
Furthermore, as highlighted in the proposal, it is reasonable to redirect biofuels towards transport sectors that are difficult to electrify, such as the maritime, long-distance transport and aviation modes.
Problems of availability and cost should also be taken into account in this regard.
In order to implement this idea, Article 25 should differentiate between bio-based biofuels and renewable electricity by measuring greenhouse gas reductions.
Priority is thus given to renewable electricity and biofuels based on residues in the transport sector.
This results in greater pressure to decarbonise the transport sector through direct electrification.