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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4th Plenary Meeting, 24th-25th May 2023, Vienna
Session 5: Art. 19.2 (RED II)
TF GO discussed latest policy developments on GO. Special attention was given to the clause in article 19.2 obliging Member States to ensure that every unit of renewable energy is taken into account only once.
Participants acknowledged that to prevent double counting the focus of national authorities so far has been mainly on issue, transfer, import and export of unique GO’s in one closed EU system. Additional effort of Member States however is needed regarding avoidance of potential double claims (related to usage of GO).
Options to look at on a national level are: combined (or co-operating) competent authorities for GO and disclosure, harmonised European disclosure figures (to be used and published by competent authorities) and introducing more market transparency and / or checks for consumers themselves to prevent double claims.
On a European level risks that have been identified and should be jointly addressed are:
- the current lack of a fully harmonised system for disclosure in Europe
- insufficient clarity and the need for rules related to strict coupling between GO and POS as to avoid double counting of the same unit of energy (as well as the clear separation of the two as regards to the function that they have in the system).
- how to deal with the fact that economic operators are meant to report directly to the UDB (without any national checks related to correctness of data)
- definitions and rules related to support information on a GO that should be further clarified, especially now that this information is vital in relationship to e.g. new rules on renewable H2
Session 11: Combined Session CT4/TF-GO: Biomethane and renewable gas with the focus on gas market development
The session started with a presentation of the Spanish system of guarantees of origin for renewable gas (2022), operated by ENAGAS GTS. The system has been designed to be as standard as possible to facilitate import/export of GOs (expected to be possible by the end of 2023 through the AIB hub). GOs can be issued for biogas, biomethane and renewable gas: (a) injected into the national gas grid, (b) for off grid use (rural areas), (c) injected in isolated networks and (d) include self-consumption. Regarding sustainability, Spain is currently studying the possibility to combine POS (Proof of sustainability) and GOs into a unique certificate as well as several connection options to UDB. E-control then presented the Austrian system of guarantees of origin for renewable gas (2021). E-Control issues GOs for biomethane, hydrogen and fossil gas extracted in Austria. For off grid production, specific “green certificates” are issued instead of GOs. Regarding export/import of GOs, Austria is the first issuing body connected to AIB HUB (May 2023). Austria is currently working on the possibility to integrate the sustainability information on the GOs. A green gas quota system based on GO and “green certificates” is also in preparation. The session continued with a presentation of the main results of the questionnaire sent to participants before the session. At present, at least 10 MS have an operational system for biomethane GO injected into the gas grid and 4 GO systems are already integrating the REDII POS. However, there are still pending questions about the integration of sustainability characteristics in the GOs. It also appeared that the main tendency among the participants is to accept the separate sale of GO and gas commodity (book and claim system applied to a single mass balance system, the EU interconnected gas grids) but a link between the GO and the POS seems necessary to avoid any risk of double counting. The session continued with a presentation from DG-ENER of the state of play of the Union Database for gaseous fuels value chain. As the EU Grid is considered as a single logistical facility from a Mass-Balance perspective, only the injection and the consumption points are registered (“what, where and when”). Any “between – trade” will not be registered within the UDB. In this way, the UDB doesn’t hinder the gas commodity and GO certificate trade. The UDB will ensure the link between the POS and the GO. The DG-ENER emphasized the importance of the involvement of Member States in the UDB process. Participants stressed the importance of also directly involving the relevant national GO authorities. The session concluded with a Q&A-session about the operationalization of the UDB.
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5th Plenary Meeting, 18th-19th October 2023, Lisbon
Session 12: Latest generic policy developments on GO as well as national implementation of non-electricity GO
RED 2 Article 19 (as well as RED3 by now) has extended applicability from originally electricity (only) to other energy carriers like (renewable) heating and cooling, H2 and other (bio)gasses including gaseous RFNBO’s.
During the Lisbon session Germany presented at length their progress on the implementation of a GO-scheme for heating and cooling.
The subsequent group discussion led to the acknowledgment of participants involved that the following three topics deserve extra attention in further (European) implementation of GO and need to be further developed in the near future:
1. What is the consequence of fragmented networks / transport and use of sustainable energy via means other than (connected) international networks. (This mainly applies to heat, but also, for example, to H2 and derived products e.g. if they are transported via tube trailers.
2. Conversion from one energy form or carrier to another carrier, as well as the consequences of sector integration, should be further elaborated in the EU theoretical framework, for example in relation to the possible consequences for CO2 administration in the existing market(s).
3.The connection and interaction between the existing GO market and the rules regarding energy labeling on the one hand and the UDB on the other hand must be further developed in the EU context.
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