Objecting to the draft RES Law in Brussels
I posted this item to summarize the next steps and the arguments at http://forum.wnp.pl/topic/162416-nowe-wsparcie-oze-do-notyfikacji-przed-uchwaleniem/
I am working on the biogas sector's comments to the Commission to object to major parts of the law in its draft form.
1. Continued support for co-firing;
2. Requiring small projects to go through an auction, contrary to the Guidelines of the Commission;
3. Defining small projects at 1 MW which discriminates illegally against biogas plants from 1-2 MW (the majority of those now built in Poland);
4. The absence of any details on the Green Certificate coefficients that will be used and no clear criteria or formula for setting them;
5. The absence of any reference prices for the auctions and no clear criteria or formula for setting them;
These issues all go to the DG Competition approval of the law as state aid. Other issues go to the approval of the law as a correct transposition of the RES directive. It is clear that the proposal will cause Poland to miss its mandatory 2020 target for RES. The only way to meet the DG Competition's desire to go to auctions for big projects and the DG Energy's requirement to meet 2020 RES levels is to extend Green Certificates for new projects an additional period after the Commission approval of whatever plan is finally agreed to. Otherwise, we will have a cut-off of projects under Green Certificates and huge delays in doing the actual auctions and getting winning projects into operation. Twenty-four months or even longer should be the window, not the twelve months from approval by the Commission now in the law. DG Competition wants 5% of the capacity competitively awarded by 2017, which will be a challenge in any event for Poland.
The Government also assumes that the DG Competition will be sitting on the enforcement case on illegal support for co-firing and old hydro while all this plays out. I don't think it is likely that everything will stop because the Polish PM wants to delay things until after the election.
Anyone interested in the biogas package to the Commission should contact me.
Randy Mott
CEERES
Vice President, Polish Biogas Association
Policy Committee, European Biogas Association
1. Continued support for co-firing;
2. Requiring small projects to go through an auction, contrary to the Guidelines of the Commission;
3. Defining small projects at 1 MW which discriminates illegally against biogas plants from 1-2 MW (the majority of those now built in Poland);
4. The absence of any details on the Green Certificate coefficients that will be used and no clear criteria or formula for setting them;
5. The absence of any reference prices for the auctions and no clear criteria or formula for setting them;
These issues all go to the DG Competition approval of the law as state aid. Other issues go to the approval of the law as a correct transposition of the RES directive. It is clear that the proposal will cause Poland to miss its mandatory 2020 target for RES. The only way to meet the DG Competition's desire to go to auctions for big projects and the DG Energy's requirement to meet 2020 RES levels is to extend Green Certificates for new projects an additional period after the Commission approval of whatever plan is finally agreed to. Otherwise, we will have a cut-off of projects under Green Certificates and huge delays in doing the actual auctions and getting winning projects into operation. Twenty-four months or even longer should be the window, not the twelve months from approval by the Commission now in the law. DG Competition wants 5% of the capacity competitively awarded by 2017, which will be a challenge in any event for Poland.
The Government also assumes that the DG Competition will be sitting on the enforcement case on illegal support for co-firing and old hydro while all this plays out. I don't think it is likely that everything will stop because the Polish PM wants to delay things until after the election.
Anyone interested in the biogas package to the Commission should contact me.
Randy Mott
CEERES
Vice President, Polish Biogas Association
Policy Committee, European Biogas Association
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