2nd Plenary Meeting, 18th-19th May 2022, Online
Session 4: Guarantees of Origin and Consumer Information
Taskforce GO had its first session and did some stocktaking regarding the status quo on GO's in Europe during the CA RES 4 PM2.
Whereas almost all countries have now implemented the GO for electricity and most by now have started implementing GO for biogas and heating and cooling, many Member States are still struggling with implementation of GO for other renewable gasses (most notably H2). Some have already started implementation by drafting law (and regulations) where applicable, but many have not in the absence of building blocks like the delegated act (DA) on RFNBO and the updated EN-standard on GO.
During our session a Q&A with the Commission had been foreseen (also related to the announced draft DA on RFNBO). Unfortunately this draft RFNBO has not been published in time for our session, however we took advantage of this fact as to discuss opportunities for a swift implementation by Member States. In short we have discussed that albeit elements like the EN standard on GO and the DA on RFNBO are important building blocks for the proper functioning of an integrated GO system for electricity, biogas and other renewable gasses (incl H2) the fact that these elements are not fully know yet need not stand in the way of starting with basic implementation of a GO system in national law. Basic elements like introducing a GO system, appointing a competent authority etc etc have to be in place and can be dealt with before all technical details have been arranged within standards or regulations on a European level (for example details of linking renewable electricity to renewable H2). We need the introduction of a GO system for other gasses and the appointment of a competent authority in all Member States for a well functioning EU-wide system (and this basic implementation of what we may call infrastructure could be decoupled from further discussions on operational rules).
Furthermore participants acknowledged during our session that there is a strong linkage not only between the different GO systems (for electricity, biogas and other renewable gasses and for renewable heating and cooling) but also between the GO and other instruments like RFNBO's and power purchase agreements. GO are meant (as per article 19 RED) to provide evidence and insights to consumers about the origin and other attributes of the energy that has been purchased and sold. Also the system should avoid any double counting or selling. For this to work in a more and more integrated renewable energy system we need to ensure that there is a proper understanding of GO and that these are taken into account in a proper way when making statement on the renewable origin whether it is e.g. by traders selling renewable electricity or heat or whether it is e.g. by producers making a statement on renewable H2 content within a RFNBO.
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3rd Plenary Meeting, 09th-10th November 2022, Athens, Greece
Session 4: Implementation of GO for other renewable gasses (incl H2)
The topic of the session was implementation of GO for renewable gasses, including Hydrogen.
Participants concluded that finalization of conversion rules and the detailed relationship between (renewable) electricity and (renewable) H2 within the legal (EU)framework as well as within the (European) GO standard is a matter of the highest priority. Next to the market demand the implementation of national policies (e.g. quota or support schemes) for H2 are important drivers to finalize this work. Furthermore the goal of having proper statistics and the obligation to avoid double counting of renewable energy, which rests upon Member States, are other important drivers to finalize this work.
Participants also exchanged information and ideas on national implementation of GO’s. Things that stood out was e.g. the idea that member states which still have to implement major elements of RED art 19 now have the opportunity to design an integrated GO system (across sectors) straight away. It was also stated that verification systems in third countries (import of energy from outside the EU / EEA) should at least be equivalent to the PPA & GO approach in the EU as to avoid for double counting renewables through cross border transfers / import into the EU.
From the EU Commission we have received a short update including a few clarifications related to implementing issues as well. Two important elements should be mentioned here:
The formal procedure to ask for recognition of GOs from a third country (Commission decision as per art 19) can only be initiated by the third country which seeks recognition of the GO. Furthermore it was stated that it is up to the Member States to decide whether to invoke rules on e.g. temporal or geographical correlation regarding renewable H2-production in the absence of further EU regulation (and even after acceptance of the DA as foreseen in art 27.3, for applications or sectors that will not be touched by this DA).
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