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Reaction: deal agreed on NER300 PDF Print E-mail
Wednesday, 03 February 2010
The Member States' amendments negotiated last night have improved the NER300 text.

Increasing the maximum number of projects per Member State from two to three gives more leeway to project developers to site their installations in the places they prefer (their preferences being based on considerations like profitability, familiarity with the market and permitting procedures). It would still, however, have been far better to have ensured the maintainence of "geographic balance" through consideration of the source of components for the installations. Most of the value generated by the renewable energy industry is found in the manufacture and sale of technology, since operating and installation costs, for many technologies, are relatively low. The spoils from taxing the production and sale of manufactured equipment and the benefits of employing people in maunfacturing jobs are what the MS should have sought to share around. Also, sourcing from different locations could have been relatively easy for project developers.

We are disappointed than an idea we circulated to the Commission and Member States on aligning the definition of "transboundary" renewable energy projects with "Joint Projects" as defined in Article 7 of the Renewable Energy Directive has not been taken up. This would have provided a greater opportunity for renewable energy projects to exploit the exemption from the geographic balancing procedure that the "transboundary" categorisation allowed, and would have avoided inconsistency between the two pieces of legislation.

It is a great relief that the highly suspect "matching funding" provision of Art 2 (3) of the draft Decision has been removed. It would have required Member States to raid their budgets if they wanted to fund an NER300 project. It is better to leave the contribution of Member States undefined since this increases the chances that projects, including renewable energy projects, can go ahead.

NER300 is still a messy, political instrument of far greater complexity than the Framework Programme or the EEPR, but the Commission cannot take all the blame for this. Its room for manoeuvre was constrained by the original wording of Art 10 a (8) of the revised Emissions Trading Directive, which failed to recognise the contradiction between awarding money to renewables projects as they operated (which means the money is only available once the developer or a third party has taken on the liability of constructing his installation) and requiring them to be "innovative", i.e. take a risk.

Greg Arrowsmith, who worked on NER300 for EUREC Agency and the wider renewable energy community, has set up a website (NER300.com) offering further news, analysis and consultancy on the instrument.
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