10^th Plenary Meeting, 6^th - 7^th May 2026, Online

Session 8: NZIA Art. 26: Cybersecurity and resilience criteria

The DG ENER presentation set out the overall framework for implementing Article 26 of the Net Zero Industry Act (NZIA), with a particular focus on the resilience and cybersecurity non-price criteria in renewable energy auctions. Article 26 is intended to ensure that auctions support wider policy objectives beyond price, including:

• responsible business conduct
• cybersecurity and data security
• the ability to deliver the project fully and on time
• sustainability
• contribution to resilience 

While responsible business conduct, cyber security and the ability to deliver the project fully and on time are pre-qualification criteria, the contribution to resilience criterion may be applied as a pre-qualification or award criterion. The NZIA applies to at least 30% of annual auction volumes, or alternatively 6 GW per year per Member State. It was also noted that further Commission guidance to help Member States interpret and apply the implementing regulation in practice will be published in Q2 of 2026.

A central part of the presentation concerned the resilience criterion. DG ENER explained that its application follows a structured, layered logic. First, authorities must determine whether there is dependency at final-product level. If such dependency exists, the relevant requirements for the specific technology — for example photovoltaics, onshore wind, offshore wind or electrolysers — must be applied. Dependency is assessed using thresholds, in particular whether imports from a third country exceed 50%, or whether they exceed 40% and have increased significantly over the previous two years.

If there is no final-product dependency, the assessment may move to the level of main specific components. In such cases, sourcing limits may apply to single components originating from a third country on which the EU is excessively dependent. Additional rules apply for onshore wind, offshore wind and electrolysers, regarding components originating from the People’s Republic of China. Although the system is complex, the intention is to provide a harmonised method for applying resilience requirements across Member States. The importance of EU-wide harmonisation was strongly emphasised. Member States should not independently set different maximum numbers of components from third countries or define different strategic components, as this could distort competition within the internal market. However, Member States may reward bidders that go beyond the minimum resilience requirements by granting additional points. Where resilience is used as an award criterion, bidders meeting the NZIA minimum requirements must receive at least the minimum points foreseen. Compliance may initially be declared at bid stage, usually through a self-declaration or commitment, while detailed verification would normally take place later, for example when the installation is built. Customs documentation is expected to play a central role in proving origin, supplemented by additional evidence where necessary.

The second part of the presentation focussed on the cybersecurity criterion. DG ENER explained that its purpose is to ensure that bidders apply cybersecurity risk management when designing, building and operating renewable energy installations. This is increasingly important because renewable installations are becoming more digitalised, which creates potential risks for plant operation and system reliability. Particular attention is given to bidders which are subject to jurisdictions where vulnerability information may have to be reported to authorities before it is made public or corrected by manufacturers, as well as jurisdictions linked to previous malicious cyber activities against the EU. In such high-risk cases, bidders may need to provide a detailed cybersecurity plan ensuring that data used or generated by the installation is stored in the European Economic Area and not transferred outside.

A further key point was the requirement for operational control by an operator established in the EEA. DG ENER clarified that this is not primarily about ownership or the physical location of facilities, but about who has authority over day-to-day operating policies and activities. The aim is to ensure oversight within the EU and the ability to restore control in the event of a cyberattack or service disruption.

The Irish implementation approach presented focused on its renewable electricity support scheme (RESS). Ireland prepared for NZIA implementation by early stakeholder engagement and a dedicated public consultation resulting in an initial decision published in December 2025. 

The Irish approach is comparatively broad: 100% of the auction volume in the onshore scheme is intended to be subject to NZIA requirements. Ireland also plans to use separate subsidy pots for different technologies. Both the resilience as well as the sustainability criteria are implemented as award criteria, with the focus on energy-system integration for the sustainability criterion. 

Documentation for pre-qualification criteria will need to be submitted at the time the bid is placed. Some verification documents which are used to proof compliance with ability to deliver the project fully and on time like bid bonds, grid connection agreements, planning permissions, performance securities, etc. already had to be submitted in earlier auctions. For cybersecurity and responsible business conduct, self-declarations will be used to ensure compliance at the stage of bid submission. Bids are ranked using a combined score: 85% of the score is based on the price, while the remaining 15% will be based on non-price criteria, namely 5% for resilience and 10% for energy-system integration. This means that price will remain the most important factor, but projects can improve their ranking if they also perform well in regard to the NZIA criteria. Ireland is taking this cautious approach to avoid making the first auction too difficult for developers, while still signalling that future auctions will place more importance on non-price criteria; the weighting of these criteria may therefore be adjusted in later auction rounds.

Cybersecurity is seen as one of the most challenging aspects of implementation, especially from an operational and administrative perspective. Ireland plans to use a self-declaration model at pre-qualification stage. For requirements linked to NIS2, Ireland would ideally rely on national NIS2 certification once available. However, because the next auction may take place before the national certification framework is fully operational, Ireland is considering the interim use of other recognised standards, including ISO and IEC frameworks. A second cybersecurity challenge concerns bidders linked to high-risk jurisdictions. It was noted that applying this requirement may be difficult where bidders have complex investment structures or where ownership changes before or after commercial operation. The initial approach is therefore to rely on self-declarations, supported by further case-by-case review where needed. Ireland expects this to be one of the more difficult aspects of NZIA implementation because compliance may need to be reassessed over time. A third key issue is operational control. This is particularly relevant for Ireland because many companies in the Irish market operate on a UK - Ireland basis, and operational control arrangements may currently involve the UK, which is outside the EEA. Ireland’s emerging approach is to focus on whether applicants can demonstrate business continuity through an EEA-based operational structure. Material changes, such as a transfer of operational control or a change in key ICT provider, would have to be notified. Evidence may be requested not only before commercial operation, but also periodically during the support period.

For resilience, Ireland intends to follow the structure of the implementing regulation. Projects will first be assessed against the minimum Article 7 requirements for the relevant technology. Projects failing to meet the minimum requirements will receive no resilience points. Ireland is considering whether to award additional points for going beyond the minimum but will initially keep the system simple by awarding the 5% resilience score to all projects that meet the minimum requirements. Compliance will be declared at auction stage and later verified mainly through customs and import certificates, supported where necessary by OEM documentation, supplier declarations and other evidence. 

The Austrian presentation outlined a concept for implementation prepared by Austrian Energy Agency. No final legislation has been adopted yet in Austria. The intended legal vehicle is the Austrian Renewable Energy Expansion Act and associated legislation, which are currently being amended. The proposed structure is designed to be flexible. The main legislation will set the general framework, affected technologies and the use of pre-qualification and award criteria, while more detailed elements — such as auction shares, documentation requirements, verification timelines, weighting factors and ranking methodology — will be defined in market premium orders. This will allow Austria to adjust the system more easily if implementation challenges arise.

The concept proposes applying NZIA criteria to 30% of the total annual auction volume, corresponding to the minimum NZIA requirement. The targeted technologies are photovoltaics and onshore wind. The concept differentiates between technologies: while for both PV and onshore wind, the price criterion will account for 70% of the ranking, the weighting factors of the non-price criteria differ:

• For PV, more emphasis is put on sustainability (implemented via energy system integration), while resilience is at 5% 
• For onshore wind, resilience receives a weighting of 25%, while energy system integration is weighted lower at 5%

This reflects the assessment that resilience is currently much harder to achieve in PV due to supply chains being heavily dominated by Chinese production, whereas wind supply chains are more diversified. At the same time, better system integration of PV is considered particularly important for Austria’s electricity grid.

On cybersecurity, the Austrian concept relies on the national implementation of NIS2 through the Network and Information Systems Security Act 2026 (“NISG”). Austria interprets compliance with this national NIS2 framework as fulfilling the Article 5(a) cybersecurity requirements. Bidders outside the scope of NIS2 may use alternative certifications, such as ISO 27001 or Cyber Trust labels. Where bidders or operators have links to problematic third countries, Austria proposes an enhanced “cybersecurity-plan-plus” which must be approved by a certification body.

The proposed cybersecurity verification system has three stages. At bid submission, bidders will mainly submit self-declarations, including commitments on security by design and security by default, confirmation that they are not subject to problematic third-country jurisdiction, commitments covering suppliers and service providers, and confirmation that the operator is based in the EEA. If links to a “problematic” third country exist, the certified cybersecurity-plan-plus already needs to be provided at bid stage. At the start of operation, more detailed evidence will be required, such as certification from the national NIS2 authority or an alternative certification body, company register extracts and updated cybersecurity documentation where relevant. During the project’s lifetime, changes in operators, suppliers or service providers will need to be reported, certifications need to be updated regularly, and non-compliance could lead to the loss of the funding agreement.

A few challenges with implementation of the cybersecurity criterion were mentioned: 

One major challenge is how to identify problematic third countries. It is considered legally risky for bidders to assess the legal situation in every supplier country themselves. An official EU-level list or guidance would therefore be preferred.

For resilience, a two-stage approach is proposed. At bid submission, bidders will provide a self-declaration that they will comply with the resilience criterion. For PV, this will be a simple yes/no approach. For wind, where resilience is proposed to be weighted at 25%, Austria envisages a more graduated system. Half of the resilience points will be awarded for meeting the minimum requirements, while additional points will be granted where further main specific components originate outside high-dependency countries.

At the start of operation, Austria will verify the component’s origin through customs documents for international products and supplier declarations for EU or Austrian products. Composite products, especially PV modules, remain a difficult issue because the origin of upstream components such as silicon may be hard to prove. Austria therefore sees a strong need for EU-wide harmonisation, including common templates, whitelists or shared certification approaches. This would reduce administrative burden for developers, manufacturers and authorities, and would be especially useful for smaller Member States. 

Session 14: Co-location of Battery Energy Storage Systems and renewable electricity generation

At the European level, co-location of battery energy storage systems (BESS) with renewable energy sources (RES) is gaining strong relevance as part of the broader effort to integrate high shares of renewables into the electricity system. The EU’s target of reaching at least 42.5% renewable energy by 2030 (with ambition for 45%) requires enhanced system flexibility, where storage plays a key role. 

It was highlighted, that flexibility challenges arise from temporal mismatches between generation and demand, leading to increasing negative price periods and renewable curtailment. Storage facilities—including BESS —can mitigate these inefficiencies by shifting energy from periods of excess generation to times of higher demand. 

Deployment trends confirm this need: while a large share of current storage is still pumped hydro, future expansion is dominated by battery technologies. Co-location is becoming more common, particularly with solar PV, as reflected by the rising share of hybrid installations. 

However, several barriers persist across Member States:

• High investment costs and uncertain revenue streams
• Double grid tariffs and taxation issues
• Grid constraints and limited connection capacity
• Fragmented or unclear legal and permitting frameworks 

At EU level, policy developments aim to address these issues through:

• Streamlined permitting rules under the Renewable Energy Directive
• Electricity market reforms promoting flexibility
• Development of flexible connection agreements and targets for non-fossil flexibility 

Overall, the EU perspective highlights strong momentum for co-location, but also the importance of harmonized frameworks and better market integration.

Germany presents a dynamic but complex environment for co-located battery storage. The rapid expansion of renewable energy, particularly solar PV, has led to increasing price volatility and a growing number of negative price hours, especially during midday periods. This creates strong incentives to combine renewable generation with storage facilities, many new projects are therefore being developed as co-located systems. 

At the same time, grid constraints are a major challenge. A large number of battery projects are seeking connection, leading to strong competition and significant bottlenecks in grid access. Possibilities such as allowing overbuilding of grid connection points have been introduced to alleviate these issues and enable BESS to be added without increasing connection capacity. 

However, the regulatory framework remains highly fragmented and complex. The large number of distribution system operators results in non-harmonized procedures, while the diversity of co-location configurations makes it difficult to establish clear rules. In addition, current regulations assess electricity from the grid and from renewable sources differently, limiting the possibility of fully flexible multi-use storage operation.

Reforms are currently underway to address these barriers, including new rules to separate electricity in front of and behind the grid connection point as well as discussions on dynamic grid tariffs and grid-oriented operation. Bundesnetzagentur is currently designing a proposal for a multi-use framework (MiSpeL) for co- located BESS in Germany. 

France adopts a market-based and neutral approach to co-located battery storage, focusing on ensuring that batteries respond to undistorted price signals rather than promoting specific configurations. The central principle is that storage should have full access to all relevant markets—such as energy, balancing, and capacity markets—and be able to optimize its operation based purely on economic signals. This is seen as the best way to ensure that batteries provide maximum value to the electricity system.

To achieve this, France has carefully designed its renewable support schemes to avoid interfering with storage behavior. Public support is granted only to electricity directly produced by renewable generation, and not to electricity that is stored and later discharged. This is ensured through dedicated metering arrangements that clearly separate renewable output from storage operations. By doing so, the system avoids creating artificial incentives for batteries to prioritize certain activities, such as spot market arbitrage, over potentially more valuable services like balancing. 

From a system perspective, France does not consider co-location inherently more beneficial than stand-alone BESS. Instead, the value of storage depends on how it is operated and how well it contributes to system needs. Co-location can still offer advantages for project developers, such as easier access to grid connections and reduced investment costs, but these are not explicitly promoted through policy design.

At the same time, France makes strong use of locational signals to guide the deployment of storage. These include dynamic grid tariffs, fast-track grid access in areas with particular needs, and targeted flexibility tenders organized by system operators. Together, these measures ensure that storage systems are installed where they provide the greatest benefit to the grid. Overall, the French approach emphasizes market efficiency, technological neutrality, and system optimisation over targeted support for co-location.

Spain is pursuing a highly pragmatic and policy-driven approach to co-location, driven by the rapid expansion of renewable energy and the urgent need to integrate it efficiently into the electricity system. With a very large pipeline of solar and wind projects and increasing grid congestion, storages have become a key solution, and co-location in particular is seen as a way to accelerate its deployment. 

One of the main challenges in Spain has been the complexity and duration of permitting procedures. Large numbers of projects, multi-level administrative responsibilities, environmental constraints, and growing local opposition have led to significant delays. To address this, Spain recently introduced a new regulatory framework specifically designed to facilitate co-located storage. The central element of this reform is a simplified permitting procedure for batteries that are added to existing renewable installations.

Under this framework, co-located storage projects benefit from a single authorization process and do not need to go through a full permitting procedure again if the original renewable plant has already been approved. In addition, projects may be exempted from new environmental impact assessments, provided that the storage installation is located within the already authorized site. These measures significantly reduce administrative burdens and shorten development timelines.

The impact of this reform has been immediate, with several gigawatts of BESS projects already entering the permitting pipeline shortly after its introduction, particularly in regions with large solar capacities. Co-location also provides practical advantages by allowing developers to use existing grid connections and avoid connection queues, while helping to reduce curtailment and shift generation to more valuable periods. Overall, Spain demonstrates how targeted regulatory simplification can rapidly unlock deployment, making co-location a key tool for managing the transition to a renewable-based electricity system. 

9^th Plenary Meeting, 12^th - 13^th November 2025, Sofia

Session 2: Contracts for Difference and Power Purchase Agreements

According to Article 19a Regulation (EU) 2024/1747 EU Member States must use two-sided Contracts for Difference (CfDs) or equivalent systems when providing public financial support for new installations generating energy from low-carbon, non-fossil fuels. These support schemes must:

•     Guarantee minimum revenue (via a fixed “strike price”).

•     Set a cap on market revenues, meaning producers must return excess profits to the state when market prices exceed the strike price.

Given this background, DG ENER gave a presentation on the current development of guidance on two-sided CfDs, which is expected to be published in Q4 2025. This guidance will provide recommendations for Member States (MS) on the design of two-sided CfDs.

Frontier Economics gave a presentation on CfDs and Power Purchase Agreements (PPAs) for renewable electricity in Europe. Currently, most two-sided CfDs are generation-based. However, there are ongoing discussions about the advantages and disadvantages of generation-based versus non-generation-based two-sided CfDs, especially in MS planning to implement two-sided CfDs in the near future.

Inputs from the MS showed that the individual starting points and the stage for shaping country-specific two-sided CfDs vary significantly. While in the Netherlands the pillars of the upcoming CfD scheme were developed through a long consultation process, Germany is still at the stage of discussing different designs.

Furthermore, the combination of two-sided CfDs and PPAs is still at a very early stage within the MS. Although certain Member States already allow such a combination, there are general concerns that CfDs may crowd out the PPA market. As PPAs are purely based on private law, legal issues can also arise when combining CfDs and PPAs. Often, very little is known about possible PPA contracts of parties receiving CfD payments. Portugal, for example, wants to establish a registration platform for PPAs. The premise is to avoid any market distortions caused by the combination of CfDs and PPAs.

Session 14: Non-price auction criteria for renewable electricity – role of Energy System Integration

In July 2025, the Commission Implementing Regulation (EU) 2025/1176 went into force. The regulation defines different non-price criteria (NPC) that have to be applied in national auctions for renewable energy technologies. NPC have to be applied to at least 30% of the yearly volume auctioned per year (or at least 6 GW per year) in every member state. This session focused on the energy system integration (ESI) aspects of NPC, namely the temporal flexibility and the locational impact on system needs, and their (planned) consideration in national auctions. Locational impacts thereby include generation capacity, the selection of the site and of the grid connection point considering network development plans.

Presentations were given by DG ENER on the legal framework for EU requirements for implementing NPC and ESI aspects in national auctions. Furthermore, the impact of locational signals and their potential to lower consumer prices and system costs was presented. Another presentation illustrated how locational signals can boost the expansion of renewable electricity and reduce redispatch needs. To establish a system with locational signals, grid modelling requires a European dimension to capture interzonal effects. It is important to ensure a high degree of transparency to make locational signals (and thereby locational impacts) visible before auctions are conducted.

Inputs from the MS made clear that ESI criteria are highly relevant in amending existing auction schemes. In some MS, ESI criteria are already indirectly in place (e.g. capacity limitations for grid-connected generation). Germany already has so-called “Innovation tenders,” conducted since 2017. Renewable technologies applying for these tenders must be coupled with battery storage, which cannot be charged from the grid (only from the plant). The upsides and downsides of these tenders were described in detail, downsides are namely the insufficient usage of the battery in winter and the impossibility of charging the battery from the grid during periods with negative market prices. 

8^th Plenary Meeting, 21^st - 22^nd May 2025, Warsaw

Session 2: Energy system integration/Power Purchase Agreements

Session 2 was divided into two parts, each covering a different topic. The first part focused on energy system integration, particularly the integration of electric vehicles into the grid. The second part covered Power Purchase Agreements (PPAs).

1st part: Energy system integration

Article 20a of the RED III includes provisions to facilitate energy system integration. More specifically, the second subparagraph of paragraph 3 of the Article requires vehicle manufacturers to make the following data available in real time and free of charge: data related to the battery state of health (SoH), the battery state of charge (SoC), the power set point, the battery capacity, and, where appropriate, the location of electric vehicles. This data must be made available to electric vehicle owners and users, as well as third parties acting on their behalf, on non-discriminatory terms. Commission Communication C (2024) 5041 of 2 September 2024 provided guidance to Member States on the transposition and implementation of this Article.

Against this background DG ENER gave a presentation on the e-mobility aspects of the energy system integration. The Commission presented the outcome of the dialogue with stakeholders within the framework of the Motor Vehicle Working Group, outlining the next steps. The presentation also provided an update on the latest activities of DG ENER regarding data sharing for V2G.

This was followed by a presentation from a French Regulator on the upcoming regulatory sandbox for vehicle-to-grid (V2G). Regarding smart and bidirectional charging, he provided an overview of the state of play. He also showed an example of negative grid tariffs for injection or withdrawal (in time slices selected by the network operator) for storage connected to the medium and high voltage grid.

2nd part: Power Purchase Agreements (PPAs)

The revised Renewable Energy Directive calls on Member States to lift barriers to renewable Energy Purchase Agreements (EPAs), including Power Purchase Agreements (PPAs) and agreements for other renewable fuels. Member States must also report on their efforts in their National Energy and Climate Plans. The revised Electricity Market Regulation also includes provisions relating to PPAs.

In this context, the first presentation of Part 2 was given by DG ENER. The Commission analysed the existing barriers to EPAs and PPAs and provided Member States with guidance on the EU legislation for PPAs and upcoming activities. The main barriers to PPAs are: regulatory uncertainty; a lack of creditworthiness and bankability of off-takers; risk aversion of off-takers; limited in-house knowledge of buyers; project and administrative delays; contract complexity; and long negotiation processes. Additionally, the inability to combine PPAs with Guarantees of Origin (GOs) has been identified as a barrier. Furthermore, the Commission presented the existing provisions in EU legislation and provided an overview of the current situation.

The second presentation was from Bosbank in Poland, it provided a bank's perspective on the topic and discussed possible measures to remove barriers to PPAs. The banking perspective illustrated conflicting interests due to differences in company size, creditworthiness, and the duration of PPAs required for investment stability. Another perspective on PPAs from Poland was presented by the Ministry for Climate & Environment, providing an overview of the PPA market in Poland, the types of PPA in Poland, and the related barriers.

7^th Plenary Meeting, 23^rd-24^th October 2024, Brussels

Session 9: Energy System Integration of renewable electricity in distribution grids

Session 9 focused on the integration of renewable electricity into the energy system, with a particular focus on distribution grids.

The session showed that distribution system operators across Europe are facing increasing challenges in terms of grid expansion. These challenges are influenced not only by the integration of renewable generation but also by general electrification trends such as the market penetration of battery electric vehicles and heat pumps and the need to produce green hydrogen by electrolysis. Not surprisingly, the session once again showed that flexibility in the electricity system is one of the key issues for the future. All flexibility tools on the demand side, such as smart charging, battery storage and general demand response mechanisms, will support the system integration of renewables. However, barriers remain to all these approaches.

There is also a need for flexibility in the grid access of renewables themselves, particularly with regard to the integration of intermittent renewables such as wind and solar PV. These sources are inherently variable, which can lead to grid stability issues, especially when there's a high penetration of renewables and limited grid capacity. To manage this, grid operators often need the flexibility to temporarily restrict access to the grid for renewables. This approach allows new installations to be connected without immediately overloading the grid. It buys time for grid operators to plan and implement the necessary grid upgrades to eventually allow full access for all installations.

Session 14: Non-price criteria for auctions for renewable electricity

In May 2024, the European Commission published a guidance and recommendations to Member States on auction design for renewable energy, including considerations on non-price criteria. (guidance document)

Member States are starting to make use of non-price criteria in auctions as pre-qualification and/or award criteria in order to pursue objectives that cannot be captured by price criteria. Non-price criteria are related, among others, to environmental, energy system integration objectives or the ability of the developer to complete the project on time. The results of the session are as follows.

• Technology neutral auctions are difficult to combine with non-price criteria
• It is easier to design non-price criteria for technology specific options
• Prequalification criteria are easier to implement and to assess than award criteria
• In 2023 nearly half of the PV auctions in the EU were undersubscribed. It is important that non-price criteria do not restrict competition.
• Industry recommends that sustainability and resilience must be used as award criteria and not as prequalification criteria.
• Industry recommends technology specific non-price criteria and a harmonisation of criteria within the EU.

6^th Plenary Meeting, 22^nd-23^rd May 2024, Budapest

Session 2: Improving the system integration of renewable electricity

Session 2 focused on renewable electricity system integration. Not only is system integration crucial to the transposition of the Renewable Energy Directive, but also interlinks with numerous other sectors, such as building, transport and industry.
Recommendations, such as supporting national and local authorities in coordination efforts, investing in research and development, as well as expanding on overall capacity building were identified to advance system integration of renewable electricity. Furthermore, the Austria’s Integrated Grid Infrastructure Plan was introduced. This plan ensures network development to be coordinated with best-suitable storage and flexibility options. The session was rounded off by looking at recently implemented storage solutions in Hungary and Greece.

Session 15: Support schemes for repowering

Session 15 granted perspective on support schemes for repowering, by exploring the evolution of auction design, in addition to looking at developments by selecting examples of Member States, Spain, Germany and Denmark.
In the example of Spain, support scheme grant programmes were presented, encompassing the scope and limitations of repowering existing wind farms. Furthermore, a representative from Germany spoke to the repowering of photovoltaic installations and wind power plants in Germany, advocating for the simplification of approval procedures needed. Lastly, insights into repowering of wind power in Denmark were also presented.

5^th Plenary Meeting, 18^th-19^th October 2023, Lisbon

Session 4: Joint Session CT2/CT4: Support schemes for RES electricity plants and RECs: levelling the playing field

This session addressed the interplay between support schemes for renewable electricity and renewable energy communities. This session was a joint session between CT2 (Renewable electricity) and CT6 (Consumer´s/Citizen’s Engagement). The main findings of the session were the following:

There are barriers for RECs to access finance and to participate in auction schemes such as:

• Prequalification criteria are hard to meet for RECs
• Auctions based on price criteria do not reward the social and environmental benefits created by RECs and their unique characteristics
• RECs have difficulties to design bidding strategies relying on market knowledge that large market players may have and they cannot realise economies of scale

Different solutions to these barriers were proposed, for example:

• Separate auction envelopes where only community projects compete against each other
• Exemption from competitive bidding for RECs
• Direct investment aid for RECs
• Guarantee schemes to provide assurance to lenders
• Solutions under revised EU State Aid rules
• Subsidies for one-stop-shops for REC
• Support for investment costs of first of a kind energy communities’ pilots
• Develop an enabling framework to allow for business models which are independent of public support

It is common that REC can also use the general subsidy schemes for renewable electricity (especially investment grants). Some countries have also subsidies for the planning, development and implementation of REC.

Auctions that may consider the specialties of RECs, so that they can compete under equal conditions with other participants (including special participation mechanisms just for RECs) have also been used by some member states.

Other MS (e.g. Austria) use special subsidies for the planning and implementation phase in combination with investment subsidies for the RES installations and general support of REC (reduced grid tariffs, reduced electricity taxes).

Session 10: Support schemes for RES electricity storage and flexibility

This session addressed aspects of flexibility and energy storage in the context of electricity generation from renewable energy sources.

A major element of the transformation of the European electricity market will be the huge increase of electricity generation capacity based on wind and solar power. These renewable energy sources have the biggest potentials in the future.

At the same time, these renewable potentials have temporal characteristics that differ substantially from the energy sources that are in use today. A huge part of today’s generation capacity is providing either base load production of electricity, or it can follow the load. In contrast to these technologies, the production of electricity from wind and solar power is intermittent, based on weather conditions or due to seasonal variations.

With growing share of these intermittent sources, matching the temporal profiles of electricity supply and demand requires additional attention, and power flexibility instruments as storage and DSM become more important. Nevertheless, this aspect is only rarely addressed in most support schemes for renewable electricity generation. These (current) support instruments are mostly designed to be technological neutral, and to focus mainly on economic key indicators.

The main findings from the session were as follows:

• The presented flexibility assessment showed the significant future flexibility demand in Europe
• Different technologies for short-/medium- and long-term flexibility
• Assessment of flexibility needs should consider possible changing seasonal RES-generation patterns due to climate change (e.g. run of river hydro power)
• Tenders for storage facilities: investment grants (€/kW) and annual support (€/kW/year)
• Storage capacity active in the wholesale and balancing markets

4^th Plenary Meeting, 24^th-25^th May 2023, Vienna

Session 7: Combined Session CT1/CT2: Effectiveness of support schemes

This session examined the effectiveness of support schemes for Renewable electricity in the EU Member States.

According to article 6.4 (RED II) “Member States shall, at least every five years, assess the effectiveness of their support schemes for electricity from renewable sources and their major distributive effects on different consumer groups, and on investments. That assessment shall take into account the effect of possible changes to the support schemes. The indicative long-term planning governing the decisions of the support and design of new support shall take into account the results of that assessment. Member States shall include the assessment in the relevant updates of their integrated national energy and climate plans and progress reports in accordance with Regulation (EU) 2018/1999.”[1]

The consultant that conducted the study on the performance of support for electricity from renewable sources granted by means of tendering procedures for DG ENER was invited to present the main findings. The study assessed support schemes measured against seven performance dimensions, namely: (i) achieve cost reduction; (ii) achieve technological improvement; (iii) achieve high realisation rates; (iv) provide non-discriminatory participation of small actors, where applicable local authorities; (v) limit environmental impact; (vi) ensure local acceptability; (vii) ensure security of supply and grid integration.

The report analysed how tendering procedures, as one of the forms of public support, are fostering the deployment of renewables as part of the wider transition of the energy system and how tendering procedures may evolve to address the current energy policy context, the new design of energy markets market integration of renewable energy sources.

In addition, MS were invited to present examples of their current support schemes for RES electricity and their experiences and lessons learned in the past few years. One Member State presented key areas of action: for the development of solar PV, including development of the domestic photovoltaic equipment industry (local content - increasing the share of domestic companies in the supply and value chain), development of new PV segments and PV grid integration, measures to overcome barriers limiting PV development and educational and promotional activities for the development of the PV sector.

Session 10: Effects of the Ukraine war on support schemes – part 2

This session examined the impacts of the emergency regulation and electricity price developments on the development of support schemes for renewable electricity generation in the Member States. This session is a continuation of the first session on this topic that was held during the 3rd plenary meeting in Athens.

The aim of this session was to share the knowledge gains among the MS, and to increase the understanding of the impact of the developments of the last year.

The European Commission gave a presentation on measures to mitigate the impact of high gas prices on electricity bills, protecting consumers and boosting RES investment. The objectives of the reform are as follows:

• Better protect and empower consumers
• Enhance stability and predictability of the cost of energy contributing to the competitiveness of the EU economy
• Accelerate the integration of renewables with flexibility services
• Better energy market monitoring and surveillance (REMIT)

The Commission introduced the concept of two-way contracts for difference meaning a contract signed between a power generating facility operator and a counterpart, usually a public entity, which provides both minimum remuneration protection and a limit to excess remuneration. Member States will also have to facilitate PPAs to reach NECP objectives. Credit risks for PPAs are an issue of concern. MS will also have to ensure that instruments to reduce the financial risks associated to payment default in PPA contracts are in place.

A flexibility needs assessment needs to be conducted by national regulatory authorities, considering the flexibility of non-fossil sources, demand response and storage. Based on this assessment, MS will need to adopt an indicative national objective for demand side response and storage.

Several Member States presented measures to accelerate the permitting procedures for renewable electricity plants. These measures include simplification of the planning procedures for offshore wind power plants, establishing clear criteria as to when a full Environmental Impact Assessments (EIA) is required, specifically for wind power plants and waiving of permits for small-scale installations under 100 kW.

3^rd Plenary Meeting, 09^th-10^th November 2022, Athens, Greece

Session 8: Impacts of the revenue cap on Power Purchases Agreements

The Council Regulation EU) 2022/1854 of 6 October 2022 on an emergency intervention to address high energy prices sets out an approach to recover excess revenues from generators with lower marginal costs (“inframarginal technologies”), such as renewables, waste, nuclear, lignite, petroleum products and peat. These electricity generators have made unexpectedly large financial gains over the past months, without their operational costs increasing. They are paid windfall revenues well in excess of their 'levelised cost of energy' (LCOE).

The regulation sets an ex-post cap on market revenues of 180 Euro per MWh of electricity produced. The cap on market revenues should apply to realised market revenues only, regardless of the contractual form in which the trade of electricity may take place. The revenue cap has been set such that it includes a reasonable margin compared to the current levelised cost of energy (LCOE) of most RES electricity generation technologies.

Power purchase agreements could play an important role in achieving renewable expansion objectives by 2030, potentially reducing the amount of public support needed. Thus, investment signals for PPAs need to be preserved. The proposed application of the revenue cap would in principle preserve incentives to conclude long-term power purchase agreements (PPA), given that the revenue cap does not interfere with the formation of prices. However, the announcement of the revenue cap has led to uncertainty in the PPA market due to: a) the possible differences in revenue caps across MS, b) the possible extension of the duration of the cap revenue measure beyond 30.6.2023 c) the fact that generation assets partially contracted through PPAs and partially selling on the spot market may be affected, even if the cap does not affect the PPA as such and d) the fact that Member States determine whether they apply the cap when the settlement of the exchange of electricity takes place, or thereafter.

This session examined the potential impacts of the mandatory cap on market revenues (Council Regulation (EU) 2022/1854) on renewables power purchase agreements. Several aspects were discussed. Among others:

1. Does the cap affect the closing of PPA deals?
2. Does the application of the cap affects the revenues of PPA sellers and/or buyers?
3. Does the application of the revenue cap affects investment signals for future renewable electricity projects?
4. Does the revenue cap offers sufficient margin to renewable electricity technologies such as wind power and solar PV to offer PPA prices well below the current electricity prices to off-takers?
5. How does a project developer chooses whether he/she applies to a support scheme, enters into a PPA or sells on the spot market or chooses to combine these options, if allowed?

Session 10: Impact of the Ukraine war on support schemes for renewable electricity

In this session, the impacts of the high electricity prices on the development of support schemes for renewable electricity generation in the Member States were discussed. In particular, the following questions were examined:

• Has the number of applications for support of new renewable generation capacities and the level of requested support changed?
• Are there any modifications planned to the existing support schemes to enable a faster deployment to deal with the energy price crisis?
• Have the priorities for the development of renewable electricity generation changed?

The results of the questionnaire show that MS states are experiencing some changes in the support schemes and the number of requests for support. Several MS experienced an increase in the number of requests for support while other experienced a decline in specific technologies. In particular, the requests for solar PV, offshore wind (where available) and biogas have increased substantially. In some cases, however, MS have seen a reduction in the number of requests in specific technologies such as biomass electricity generation.

The main current obstacles for RES-e project development appear to be availability of a qualified workforce, availability/delivery times of materials and components and grid connection issues. Actions being considered or already taken by MS to accelerate deployment of RES electricity projects as a response to the energy crisis include an increase in the RES-e deployment targets, increase in the volumes of tenders, process adjustments and information campaigns, as well as lifting some requirements for project developers.

During the session, DG ENER briefly introduced the Guidelines on State aid for climate, environmental protection and energy 2022 (CEEAG) and section 2.5 of the Temporary Crisis Framework (TCF). The TCF includes provisions for the rollout of renewable energy, storage, and renewable heat. Section 2.5 of the TCF, which was recently updated, allows MS to set up schemes to grant aid for RES electricity, RES heat and renewable gases.

Two Member States presented the impacts of high energy prices on their RES electricity support schemes. In one of the cases, plants are leaving the feed-in-tariff support scheme to profit from high electricity prices. The feed-in tariff system allows plant operators to leave the subsidy system temporarily. If they choose to return, they will have to stay in the support system for at least 12 months. The subsidy contract conditions when these plant operators return are the same as before they leave the system.

In the other case, the latest auctions have been undersubscribed. In particular, biomass projects have not applied for support. Apparently, this is because the feedstock is becoming more expensive or is not available.

In addition, some examples of how Member States are implementing Art. 6.3 of the RED II were presented. According to Art. 6(3), Member States have to publish a long-term schedule anticipating the expected allocation of support.

2^nd Plenary Meeting, 18^th-19^th May 2022, Online

Session 8: Power Purchase Agreements: Focus on sellers and purchasers

This session focused on power purchase agreements from the perspective of buyers and sellers as well as financial institutions. Article 15.8 of the RES directive 2018/2001 requires Member States to remove unjustified administrative or market barriers to corporate purchase agreements of renewable energy, in particular to accelerate the uptake of corporate purchase agreements of renewable energy by small and medium-sized enterprises. The REPowerEU plan has emphasised the measures foreseen by the RES directive. In the context of REPowerEU, the European Commission has issued a Guidance to Member States on good practices to accelerate permitting processes for renewable energy projects and on facilitating Power Purchase Agreements

The PPA market in Europe is growing and there is a diversification of sectors and markets is taking place. However, currently, PPAs have been signed only in about 11 EU Member States and companies face a number of barriers when trying to source renewables through PPAs. The main barriers identified in this session are policy uncertainty, lack of credit worthiness of off-takers in particular SMEs, risk aversion of off-takers, limited understanding of energy markets and contract complexity. Obstacles with project financing in connection to PPAs include partner risk and higher cost of capital compared to financing under government support scheme.

A presentation by the RE-Source platform and the WBCSD highlighted benefits of PPAs for buyers such as price stability and cost visibility. Benefits for sellers include risk mitigation through guaranteed offtake and diversified revenue streams, stable and bankable long-term income and brand recognition. The RE-Source platform buyers toolkit offers several resources for interested parties such as an introduction to corporate renewable sourcing, templates for PPA contracts and an European corporate sourcing directory.

Credit risks for PPAs are an issue of concern for the contracting parties. Risk hedging measures include contractual mechanisms, credit risk insurance, letters of credit and credit guarantees by a parent company or the state (e.g. through a management agent), among others. In the session, a presentation was held on a power purchase guarantee scheme to help large power intensive industrial companies obtain long term PPAs. The guarantee scheme covers risk related to electricity intensive power purchasers in key economic sectors In case of a power purchaser default, the power supplier can choose to invoke the guarantee. A new power purchaser is designated and the electricity is sold in the spot market. The designated power purchaser pays 80% of the difference between the PPA price and the average spot market price.

An example of a one stop-shop for SMEs, which is currently under development was also presented. The one-stop shop will have to rely on a close collaboration with the banks and standardized financial products for PPAs. Banks are a very important actor in mobilisation of investments and the closure of PPAs. The banks must have a good understanding of the risks such that they can price risks adequately and develop risk-hedging strategies. The banks typically prefer to have long term PPAs while off-takers such as SMEs may prefer to have a shorter tenor but with secured price stability. Banks may require standardised clauses in contracts and capacity building to understand the implemented approaches in order to gain confidence.

Some countries are developing support measures for PPAs such as digital platforms to facilitate the supply and demand of PPA contracts, electricity market opening, Guarantee funds for PPAs, PPA regulations, and revision of the regulatory framework for PPAs.

European markets for PPAs are dominated by large corporate off-takers and expanding PPA schemes to SMEs is still difficult. Demand aggregation mechanisms, which pool together multiple off-takers can be useful to facilitate the participation of SMEs in PPAs, since they help to distribute the risks. However, the multi-buyer PPAs also have complexities such as the fact that SMEs may not have in-house knowledge about PPAs and electricity markets. Thus, external knowledge may be needed to guide them through the process. Standardisation and template contracts can be also useful.

In some Member States there is a combination of support schemes and PPAs. In some approaches, the Member State retains the GOs for the part of the RES electricity that is subsidised by the support scheme and issues the GOs for the part that is sold in the framework of the PPA. Other MS are looking into the possibility of combining support schemes with 'proof of use of renewable electricity' through PPAs combined with GOs. This topic could be explored in future sessions.

Session 10: Administrative Barriers

The session continued the discussion on the barriers in administrative procedures and experiences that was started in November 2021.

Based upon the analysis of the existing procedures, an electronic contact point was established in Finland, that concentrates all permitting procedures for a certain project. In this contact point, the applicant can apply for permits, see the status of each permit, and cam exchange information with the competent authorities. Digital solutions can improve the permitting process, but the set-up requires time and resources, and should be designed from the costumer’s perspective

German examples show that offshore wind power benefits from preliminary site investigations. When all relevant information available in a standardized way at an early stage, delays during plan approval become more unlikely. With this information, wind farm operators are aware of site conditions at an early stage, which allows to plan on an efficient and reliable basis.

1^st Plenary Meeting, 17^th-18^th November 2021, Online

Session 3: Administrative Barriers

The session was focused on barriers in administrative procedures and experiences with the reduction of barriers and the optimisation of procedures.
The durations of administrative processes are often influenced by conflicts between the project applicants and the public (e.g. local initiatives and action groups) during the public participation processes. Public concerns are often caused by a lack of transparency and information regarding the intended projects. An early, transparent and appropriate communication process, that goes beyond basic formal requirements and that addresses existing concerns, can contribute to a settlement of conflicts and can support the acceleration of administrative procedures.

Another important basis for the reduction of administrative barriers is the appropriate staffing and funding of the authorities, which are responsible for the administrative procedures. The authorities need sufficient staff, with appropriate expertise, who can manage the processes in due time. This needs steady training and personnel development.
In general it can be noticed, that a reduction of administrative barriers does not necessarily mean a reduction of administrative procedures but more effective procedures, which can be reached in a cooperation between authorities and project applicants.

Session 12: Joint Session CT1/CT2: CEEAG: Reconciling competition and target achievement in times of higher ambition

This session discussed experiences of Member States with supporting renewable energy development through tenders and the challenges for existing systems in light of increasing target ambitions. The session included a presentation of DG COMP on the CEEAG, the Spanish auctions on RES electricity conducted in 2017 and a presentation on auction volumes for target achievement.

State Aid is considered an essential tool in reaching Green Deal goals, although other instruments are also used by the Member States. The main objective of competition rules, however, is to preserve competition and the integrity of the internal market. A proposal for Climate, Energy and Environmental Aid Guidelines (CEEAG) has been made by the Commission and it is planned that the CEEAG enters in force in 2022. The two main buildings blocks of the revision are: a) An enlargement of the scope of the guidelines to cover new areas and technologies that can deliver the Green Deal (b) a flexibilisation of the compatibility rules including the provision of higher aid amounts (100% of funding gap) and new aid instruments (e.g. CCfD). The scope of the proposed Guidelines is extended to all technologies that reduce greenhouse gases, including renewable energy sources, and improve energy efficiency. However, specific renewable schemes continue to be possible. The new guidelines will be more flexible regarding renewable-specific support schemes and technology-specific support schemes and auctions. Also, more generally, the experience gained with tenders in the renewable electricity sector is being brought into new areas.
The General Block Exemption Regulation (GBER), a key tool, is also being revised to facilitate wider and newer exempted possibilities to support renewables and other decarbonisation measures, including renewable hydrogen and storage and recognise the importance of renewable energy communities.

The Spanish experience with RES-e auctions in 2017 was also presented. In these auctions, support was granted by assigning a quota (e.g. 50 MW), not to specific facilities, which allowed project developers to choose the best locations and reduced the price. In addition, no pre-qualification requirements were imposed on the projects. The lack of prequalification requirements was effective, reducing the administrative burdens and accelerating the auction call. Generally, there was a very good response from project developers to the call for tenders. The auctions were oversubscribed and subsidies were reduced to a minimum (zero). The penalty system in place helped ensuring a high overall execution rate (over 70%).
The presentation on auction volumes and target achievement showed that the goal should be to set the auction volume high enough to reach the RES targets but still ensure competitiveness of RES auctions. In addition, other supporting measures are necessary to increase RES supply and ensure competition such as setting reliable long-term targets and auction schedules to give RES project developers sufficient certainty and time to build up a project pipeline and supply chains. Spatial planning that allows for the designation of areas for renewables is also a key element. Moreover, simplifying and speeding up permitting procedures is helpful.
Thereafter, Member States expressed their views on a variety of questions related to exceptions from the tendering requirement (e.g. for small installations and pilot projects), the use of technology-specific or technology-neutral options to support decarbonisation and monitoring RES support.