Joint Letter Power Sector on Nature Restoration Regulation
EU power sector calls to avoid restrictions and constraints to renewable electricity generation in the Nature Restoration Regulation
Against the backdrop of the war in Ukraine, the European Union (EU) faces the complex challenge of balancing energy security, affordability and competitiveness while making the transition to a decarbonised economy. Simultaneously, the world is facing an unprecedented environmental crisis. Climate change is no longer a distant threat but a pressing issue that requires immediate action. Biodiversity loss is proceeding at an alarming rate, further accelerated by rising temperatures, which will become the main cause of habitat and species loss by 2050. As climate change is one of the biggest threats to biodiversity, promoting decarbonisation of the EU energy system and achieving climate neutrality is crucial.
The EU is seeking a massive deployment of renewable energy to achieve climate targets and independence from fossil fuels. In parallel, ambitious goals for protecting and restoring nature are being pursued.
As an essential enabler for achieving these objectives, the EU power sector calls for a balanced approach between these parallel public interests. The Nature Restoration Regulation must not hamper the implementation of the Fit for 55 and REPowerEU plans. Safeguarding existing renewable generation and accelerating the development of additional renewable capacities can and should be compatible with the EU’s nature restoration objectives. Preserving and expanding renewable electricity generation is in the Overriding Public Interest. Therefore, new and contradictory provisions that could restrict electricity generation or storage from renewable sources like wind, solar PV and hydropower must be carefully evaluated and avoided. A coordinated approach between restoration plans and national energy and climate targets, including renewables acceleration areas, is essential.
The proposed Nature Restoration Regulation requires Member States to put measures in place to achieve “good condition” in at least 90% of listed habitat areas on land and sea by 2050 and to avoid deterioration. Considering the overall benefits of renewables, adapted targets are required in areas used or designated for power generation, storage, connections to the grid and the grid itself to achieve the energy transition. It is essential that the already complex permitting procedures are not further complicated, as this would result in additional delays in phasing out fossil fuels and reaching net zero.
This call for a balanced approach is part of the European power sector’s commitment to adopt all feasible measures to keep the impact on nature as low as possible and achieve a net positive outcome. How this is implemented and how innovative and integrated solutions benefiting nature and climate look are reflected in projects such as Eurelectric’s Power Plant.
The European power sector also contributes significantly to biodiversity enhancement through compensation measures. In this context, it is emphasised that the sector supports the removal of obsolete barriers to improve the longitudinal and transversal connectivity of rivers. According to an AMBER Study, of the total 1 million barriers in European rivers, a significant share is obsolete. By removing these obsolete ones, the target of 25,000 km of free-flowing rivers can be achieved without adverse impacts on actual or potential activities being essential for sustainable human development, such as power generation. In this regard, it must be recognised that less than 10% of all barriers are used for electricity generation (20,000 hydropower plants in the EU). Similar results are delivered by the EU-wide assessment of the 2nd River Basin Management Plans, observing that 34% of the rivers in the EU are affected by impaired hydromorphology, however, only about 6% are affected by hydropower. We, therefore, urge that existing barriers used or usable for hydropower generation are explicitly left outside the scope of the Nature Restoration Regulation. Indeed, they not only provide renewable energy and flexibility, but have further multi-purpose benefits for society, such as supporting the mitigation of floods and droughts, providing potable water and water for irrigation and industrial needs, promoting tourism and navigation, and removing waste from our rivers.
We trust that our concerns will be given due consideration. The European power sector stands ready to further develop and implement innovative and integrated solutions that work simultaneously for climate and biodiversity.
 Eurelectric – European Power Sector Association (2022). Power Plant Project
 AMBER - Adaptive Management of Barriers in European Rivers (2020). The Barrier Atlas
 WISE Water Framework Directive (2018). Database: Data reported by EU Members States according to article 13 of the Water Framework Directive (WFD) - 1st and 2nd River Basin Management Plans