The US also now has several active or soon-to-be-active regional REC tracking platforms: NEPOOL GIS in the Northeast, PJM GATS in the mid-Atlantic, ERCOT in Texas, WREGIS in the west and M-RETS in the midwest (and Canada). These have demonstrated that regional green certificate markets do not need to have harmonized mechanisms between individual participants in order to function.
A few questions that I have are: what lessons could the US experience with regional TGC markets among states with widely varying mechanisms have for the EU? Even though feed-in tariffs don't explicitly involve TGCs, could it be said that TGCs are implicitly bundled with electricity during a feed-in tariff transaction similar to the long-term contracts for TGCs and electricity that exist in many US RPS states? But that one of the primary differences being that US long-term RPS contracts must be negotiated on a case-by-case basis, rather than being standard and transparent? Could there be a case made for regional green certificate tracking (rather than a harmonized super-policy) in the EU that would allow for different mechanisms to co-exist like they do in the US?
Wilson
EPIA is one of the entities writing the letter to the Commissioners,
Let me give you a small overview on the situation from our perspective at EPIA:
A first draft of the framework directive is being discussed for the moment within Energy Commissioner Piebalgs cabinet that is responsible to elaborate the proposal of the directive. Within this draft the EC expresses the wish to introduce a mandatory, unlimited trading system for electricity and for heat (installations above 10MWth) with harmonized guarantees of origins. The Commission does not intend to ask for harmonization of support schemes at this stage.
In addition, the 1st draft foresees:
- Plans to introduce intermediate targets (2012, 2014, 2016.) with reporting obligations from Member States. There is a mechanism introducing flexibility in the intermediate targets.
- The Commission wants to strengthen provisions on administrative barriers and maintain provisions on grid access from the RES-E directive
- No calculation method on target sharing has been chosen yet. They still hesitate between flat-rate and potential approach.
- The target of 20% by 2020 refers to final energy consumption. On electricity, it considers production.
- The draft will entail sustainability criteria for bio fuels.
Representatives from 27 national ministries and DG TREN and DG Environment will meet on the 12th of October to discuss target sharing.
The draft directive is scheduled to go in inter-service consultation by the end of October.
What does it mean for the PV sector?
Mandatory trade means cross border trade of tradable green certificates in order to permit to the different countries to reach the 20% target by 2020. As green certificates are technology neutral, the cheapest and competitive technologies will benefit.
In addition, The Commission intents to link ETS (Emission Trading Schemes) with support schemes. This idea is supported especially by the UK government which is hostile to 2020 targets of the EU and always favorable to green certificates and quota systems. We work effectively with the European Parliament but very important role will be played by the Member States of the EU during the voting procedure for the co-decision process. As many Members States as possible have to be in favor of feed-in tariffs.
Both measures are putting in high danger feed in tariff, as amongst the countries only few countries (Germany, Spain, Slovenia, Cyprus, Greece) are in favour of feed-in.
National positions:
- In Germany, discussions are being held with BMU in order to allow Germany to have very strong position in the EU Council.
- Spain has high concerns regarding cost of FiT.
- Spain and Germany would probably be the only ones standing up in favor of feed-in (with Spain's position depending on Iberdrola). Maybe Slovenia as well.
- UK, Portugal (Presidency), most central European States and most Scandinavian states (Sweden in particular) and Belgium will be against it.
For more insight see EREC's position paper : http://www.erec-renewables.org/fileadmin/erec_docs/Documents/Position_Papers/EREC_Position_Framework_Directive.pdf
Marie Latour
European Photovoltaic Industry Association
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