Mott's Blog

This youtube video brings it all together. https://www.youtube.com/watch?v=h2iyQcXQUSw I expect to be in this market in Poland in 90-120 days. I hope to form the Polish Energy Storage Association at the same time.  Interested parties should contact me!  randymott (at) envirosolutions.co. Note: I am still in the biogas business and environmental consulting business.

The Ministry for Infrastructure is raising issues about the announced intention of the Polish Government not to notify Brussels on the new law. [They never notified on the existing law and are in an enforcement case with the Commission on the subject]. The Ministry's point is not one of mine and may even be a "stalking horse" for the real arguments which are harder to admit (i.e. the auction is not technologically neutral, the procedure is not transparent, Green Certificates are still used without necessary Commission approval, and the whole exemption relied upon is not even finalized yet). Failure to notify will lead to a Commission complaint and the review will be done by Brussels whether the Polish Government seeks it or not. The ruling coalition seems to be convinced that it is somehow served by delaying the inevitable smack down. My own educated guess is that the smack down will occur in time to be an issue in the elections next year, so their timing is totally ...

The draft RES law in Poland provides for an auction for electricity support for green energy beginning sometime in 2017. There is a faint hope that this will be 2016 if the Government is successful in bypassing the EU notification process (an unlikely contingency). When the auction day does arrive, if at all, the small auction for under one MW projects will have a result completely at odds with the announced objectives of the Government. If and when the day comes, the Government will reserve 25% of the auction for small producers, i.e. under 1 MW. While I have objected to the 1 MW and to the requirement that an auction be used, it is interesting to speculate on the effects of this proposal if it is realized. Pre-qualification of bids will be required, which will include the need to have planning permission, environmental approval, gird connection conditions and a building permit for your project. A deposit with the bid and penalties for failure to build the project if your bid is...

As the situation is developing in the Polish RES market, everyone with a viable project is rushing to build it. Construction in the next 18-24 months, means that a project can opt for the auction or Green Certificates (which ever appears more advantageous. While uncertainties are keeping the biggest and most conservative investors and banks on the sidelines, the most entrepreneurial folks are jumping in. Smart investors know that the certificate values will go up dramatically due to the European Commission future actions. The small developers will have big problems with an auction system, but well-funded developers will win support and the small auction (now under 1 MW) will create a situation of limited competition. I have argued without a break that the auction mechanism is bad for small projects. Over 90% of the Polish biogas developers are small investors, often only doing one or two projects. Biogas has difficulties in the auction experiences from other countries. I will conti...

I have organized a panel of legal experts to discuss the issue surrounding state aid to renewable energy and the new Guidelines. Unfortunately, we have been unable to obtain any sponsors. As readers know from my posts and articles, this issue is huge and will decide the future of renewable energy in Poland. I think we urgently need a dialogue on the issues and solutions. Now that there is a more public discussion of the issues, including UKOK's correspondence, maybe the situation has changed? It is impossible to discuss the future of the RES bill without taking this issue into account. Some of us think that it has already been one of the major factors in the delays and decisions made by the Polish Government. Any companies or organizations that would like to be sponsors for a conference with the leading legal experts in Europe on the subject should contact me. randymott  @  envirosolutions.co.

     To anyone who has even a casual acquaintance with gambling, “doubling down” is a well-known and often dangerous strategy. The Oxford Dictionary defines it as to “ strengthen one’s commitment to a particular strategy or course of action, typically one that is potentially risky.”  Doubling down or increasing your bet when you know that your cards are losers probably goes by a more generic name, say “stupidity.” Operating since 2005 under a renewable energy support system that is unquestionably state aid, while ignoring the obligation to notify and obtain approval in Brussels under its treaty obligations, the Polish Government now seems poised to plunge ahead with more aid and no more notification. The Green Certificate program is totally intertwined with the new program since it can still be opted into by existing RES producers and since the reference price in the auction for existing sources is pegged to its value. Nor does the form of auction pr...

Thanks to all to stop by and read my blog! I hope that you will start posting comments. Let me know what you think and how my posts can provide you the information, links, and analysis that you would like to see to the future.

I will have a detailed analysis this week of the changes in the new RES law and how they affect (do not affect) the need to have Brussels approve of the law. The central fact to remember as I argued last week is that the Green Certificates are state aid and have never been notified or approved. Doing so is critical to their long-term viability. Existing plants can still opt to continue Green Certificates, so they remain part of the support scheme and cannot be indefinitely run as illegal aid. More later, including an analysis of other parts of the proposal law against the new Guidelines and EU rules on competition....... UPDATE:  I am waiting for a translation of the UKOK letter that defends the lack of a need to notify. I can tell immediately from the references that they make that they have grossly misread the law. The substitution fees that go to NFOSGW have always been held to be state aid, even in the decisions that they cite. UPDATE: They conclude that green certifica...

     The press is filled with new accounts of an admission by the Prime Minister's office that we may not have a renewable energy law in place and approved by Brussels before 2017. This squares up pretty well with my predictions on the process early this year. Almost no one understood that the renewable energy support program will not ultimately be written in Warsaw, but in Brussels. Due to the need to approve state aid, the European Commission has a major role to play in determining what can occur in every Member State.       While the Directorate General for Competition in Brussels is rewriting the rules to be applied in 2017 and thereafter, Poland has not completed the required procedure for state aid that started in 2005. The new State Aid Guidelines for Environmental Protection announced on April 9, 2014 require that changes be made by 2017. The Prime Minister's staff person mentioning a review in 2017 while speaking at a conference this week sig...

From the Polish Institute for Renewable Energy: Poland stresses the importance of the coal sector and at the same time fighting for "the rehabilitation of coal" in Europe and improve the operation of coal mining in Silesia. The role of coal in the economy is not so big. Revenues from the sale of coal in the national GDP is less than 1.4%, while that for the renewable energy market in 2013 exceeded 1.3% of GDP. Gramwzielone Every year this trend will get stronger and it is occurring despite the Polish Government, not because of it. The underlying factors strongly favor the continuation of the increasingly role of green energy and the declining role of coal. Beyond the problems of Polish coal  (which are themselves impossible to underestimate), it is quicker to build green energy production than any conventional plant (except natural gas, which is largely moot now). The premium for green energy is less each year as the "cross over" point nears on many RES techno...

     The new European Commission Guidelines on State Aid for Renewable Energy , adopted on April 9, 2014, are quite controversial in the RES industry and even elsewhere in Brussels. Many believe that the shift to "competitive mechanisms" in RES support will mean that the targets for 2020 will become impossible to achieve. Remember that the targets were set by the European Parliament for renewable energy and the guidelines are simply an expression of policy by one Directorate of the European Commission. It is possible that the lobbying in Brussels will push changes in the guidelines' most objectionable features, including an unrealistically low ceiling for small project exemptions from auctions. However, the first nine years of Polish RES support under an unnotified Green Certificate system will be evaluated under the rules existing at the time, not the new guidelines. This spells continued major problems for the Polish Government.    Several parts of the new ...

My analysis of the benefits of co-digestion of organic wastes was just publishe d in Poland. You will have to hit google translate for the link. A full English language version is available and will be up on the new CEERES website in a month. The goal is to get the draft Polish law cleaned up to allow this approach to biogas without the current restrictions in the bill, i.e. on the size of plant and substrates used.