- Eurelectric supports the increased 2030 EU RES target of at least 40%. The key role of renewable electricity is recognised through different amendments, for example, MSs setting up RES-E frameworks, the issuance of GOs for every MWh of renewable energy produced upon request from producer independently of benefitting or not from a support scheme, the enhanced requirement for promoting PPAs, better coordination in offshore planning, labelling of industrial products, the promotion of charging infrastructure able to interact with the grid.
- The amended REDII proposes a new architecture of sub-targets which poses the risk of transforming this directive into a very complex piece of legislation. Further clarification is needed on the interactions between the different sub-targets, and it should be ensured that renewable electricity can count for the Heating and Cooling (H&C), District Heating and Cooling (DHC) and industry targets.
- Regarding transport, the way renewable electricity is accounted for concerning battery electric mobility is welcomed and should be complemented where technically possible with additional flexibilities backed by robust verification/traceability to avoid double counting. The shift to an emissions-based target coupled with the new obligation of implementing a fuel-neutral credit mechanism needs to be further clarified. The credit mechanism should also cover, where possible, private and semi-public charging points, and it should be possible for it to be applied to other types of transport.
- Getting the enabling framework right is crucial to achieving the increased RES ambition: more needs to be done on speeding up permitting procedures, supporting RES-based electrification, including through making full use of article 15 in the existing Energy Taxation Directive, and cooperation on joint RES projects should be incentivised without adverse impacts on market-based investments and made available for projects developed under international consortia or joint ventures.
- Facilitating the system integration of renewable electricity is welcome but disclosing the RES-E and GHG content of the electricity supply is a complex exercise and should be recognised as such, through an optional rather than mandatory provision.
- A stable rulebook for sustainability and GHG savings criteria for bioenergy should be ensured. Priority should be given to the implementation of existing criteria in REDII and data gathering to gain further insights into biomass markets.