NER300.com is an unofficial, independent portal dedicated to renewable energy and grid integration projects wishing to access this instrument, providing
DG CLIMA has launched the second public consultation in a year explicitly asking about NER300. In the table below, the questions it asks are compared with the earlier consultation, which closed on 31 July 2014. The deadline for responses is 16 March 2014.
|Latest consultation: Consultation on revision of the EU Emission Trading System (EU ETS) Directive
— closing 16/03/2015
|Earlier consultation: Consultation on Emission Trading System (ETS) post-2020 carbon leakage provisions — closed 31/07/2014|
The reponses to the earlier consultation, which were analysed by NER300.com have now been analysed by the EC. The NER300.com article has been updated with a link to the EC’s official summary of the responses.
Respondents were asked to indicate whether they would allow their replies to be made public. These replies have been posted on the homepage of the public consultation. An analysis of them is given below.
The NGO Change Partnership offered advice on how the pot of a new NER300-type scheme could be filled with allowances: “The allowances should come from a combination of a ‘haircut’ on the Market Stability Reserve (MSR) together with a dedicated fund of allowances. This should replace any ‘New Entrants Reserve’. Importantly, allowances should not be monetised but used as collateral to leverage additional funding.” The MSR is a measure that would be applied to Europe’s Emissions Trading Scheme to adjust the amount of carbon allowances that are in the market, with the expected effect (at least in the near term) of boosting the carbon price. It could begin in the next 2 to 7 years, depending on the will of the Council and European Parliament. The mandate to launch additional calls under NER300 rules, or to start NER400 early, could be linked to this dossier.
Alstom, which has been involved in a number of awarded and un-awarded NER300 proposals, fleshed out Change Partnership’s ideas:
[…] We fully support the continuation of the NER300 beyond 2015 and before 2020. To be meaningful and credible, the Fund should make available a very large amount of money.
- From the ETS: free allowances from the NER non-allocated in 2020, free allowances allocated to plants that will close before 2020 (IED regulation) and EUAs from the Market Stability Reserve could be monetised. Without being monetised, EUAs could also be used as collateral to leverage financing at an agreed carbon price.
- From the 2014-2020 EU budget: ‘Smart or Inclusive Growth’ or ‘Sustainable growth: Natural Resources’ lines, European Structural and Investment Funds, Research Fund for Coal and Steel, Horizon 2020, Connecting Europe Facility and the tax on financial transactions.[…]
The need to look beyond NER300 for stimulating innovation in energy technology was a theme in a large number of responses. Only one respondent, Holcim, mentioned “risk-sharing” in its submission, of which the EUAs-as-collateral approach could be one example.
The ‘veterans’ in this context are companies that had already applied for NER300 funding. Alstom, above, was one. Air Liquide described NER300 as Europe’s “only tool for funding large scale demonstration European projects” (supported by the European Industrial Gases Association). The utilities ENEL (responding via its Slovakian subsidiary) and RWE recognised the value of support for innovation in energy technology, but could not accept that distorting the Emissions Trading Scheme in the way NER300 has done is a price worth paying. This was a widely held view. ENEL wanted to see “analysis of [NER300’s] effectiveness and achievements”, which two other organisations, BDI and the Swedish Forest Industries Federation, also called for. Shell parted company from other oil companies and their associations by expressing its “full support” for NER300 and calling for any follow-up to be better resourced. Finally, Magnesitas Navarras, whose technological approach was confirmed ineligible by the EC in its answer to FAQ 29, looked on the bright side: “We are going to present the project in the topic LCE 15 under Horizon 2020.”
Companies that have tasted NER300 like it. That feeling is shared by their industrial associations. The two European renewable energy industry associations that responded, Ocean Energy Europe and EWEA, praised NER300. The CCS Association said NER300 had had “limited success” in promoting CCS and that a better funded future programme “should focus on delivering large-scale deployment of CCS in the EU post-2020.”
Estonia considered NER300 “an important funding programme for innovative carbon projects which helps to reduce greenhouse gas emissions and [which] should definitely continue after 2020.” The UK, whose three projects were between them awarded one sixth of the NER300 pot (more than any other Member State), would like any future pot of money for low carbon innovation not to be created by raiding allowances from the Emissions Trading Scheme. Poland shared this view, adding that if a new scheme were created the focus should move from CCS to technologies for cleaner combustion of fossil fuels. Regions also gave input. Wallonia and Flanders insisted on the principle of geographical balance. Bavaria, Thüringen and Vienna, which were the only other local government administrations to give a public reply, dismissed CCS.
The ‘newbies’ in this context are organisations from which nothing or little on NER300 has so far been heard or that have had no direct connection to the instrument. They include, above all, industrial sectors at risk of shifting production outside Europe if the EU puts too high a cost on carbon dioxide emissions. The EC intends these sectors to benefit from NER300-type funding in future.
To a great extent, however, the companies concerned and the associations that represent them reject the idea that they should give up any allowances that would otherwise be given to them for free. The taking of allowances that would otherwise have been freely allocated to new entrants was the way in which the original NER300 pot was formed. Solvay said, “The ETS is an instrument that must curb emissions at the lowest costs for participants,” echoed by Ineos, a manufacturer of oils and olefins: “The Commission should prioritise protection for industries at risk of carbon leakage to allow EU companies to remain competitive.”
One drawback noted by many of basing the pot size on a number of allowances is that the amount of money it ultimately contains will depend on an unknown quantity: the price at which the allowances are monetised. Eurometaux, repeated by 10 metal producers or their associations, pointed out that the availability of NER300 funding will be inversely proportional to the need for it: when carbon prices are high, this on its own can suffice as the driver of innovation, yet the NER300 pot will be huge. When they are low, the carbon price will not be sufficient, but the pot, if linked to it, will also be too small. USG proposed to deal with very large pots apparently by demanding more technical risk in projects: “The higher the carbon price is targeted to be, the higher the benchmark level should be.”
Support is stronger for the idea of linking the revenues from auctioned allowances to spending on low carbon innovation because this would not reduce the number of allowance available for free allocation. But can Member States be trusted to spend the revenues on ambitious technology programmes? The chemical industry lobbies CEFIC and VNCI think not. They both write, “It is seen as unlikely that Member States will free resources from auctioning revenues due to national budgetary challenges.”
A number of purists responded, opposing any use of the ETS to fund technology programmes and insisting that general taxation be the source of funding instead. This fully insulates the size (and therefore design) of the programme from the vagaries of the carbon market.
Many, from a variety of sectors, called for the future NER300 to be broader in scope:
In which direction should NER300 be broadened? The NGOs can perhaps provide a disinterested view
Swedish Steel Producers´ Association says NER300 payouts should not be reduced or cancelled if the project is built but ultimately does not perform, which is a feature of current NER300 rules that the cement industry (CEMBUREAU + 18) also considers to be a drawback.
Bellona Europa says, somewhat contradictorily, that “a higher share [should be] covered by the EC,” but also “any projects should require a substantial financial or in-kind commitment from industry”. Humberto Delgado Rosa (Director responsible for NER300 in DG CLIMA) speaking at The EU Energy Challenge said that the rules on NER400 were far from being decided and that an increase in the proportion of costs covered could be considered. He is unlikely to go as far as one respondent’s wishes: ‘Marek Kucharski Bełchatów’, writing as a citizen but using an email address of Polish electricity company PGE said grants of 100% of costs should be allowed for CCS. PGE had made the same statement at the SET Plan conference in Warsaw 2011.
The International Association of Oil & Gas Producers and its member Total made an interesting point about CPUP. CPUP was based around the wrong metric for CCS plants: “The criterion should not be the extra cost per tonne of stored CO2, but rather the extra cost per kWh of electricity.”
The paper industry (CEPI + five) said that success in energy innovation “is not so much a matter of budget allocated, but of policy uncertainty.” They were joined by three other Nordic associations/companies. The Swedish Forest Industries Federation wrote, “some of the [NER300 projects] have not been made. This is not due to the amount of allowances used for NER300 but to the low credibility of the European energy and climate policy. To increase the amount of NER300 allowances will not change this. A clear, transparent and stringent policy would mean much more.”
Eurogas: “The direct competition with renewables under NER300 should be reduced and additional funding instruments for low-carbon investments be considered.”
Many said NER300 should be made less complex, but without saying how.
The question of whether CCS is a valuable technology divided opinion as follows. The summary neglects the small number of replies declared to be personal responses.
As part of their deliberations on the EU’s Framework for Climate and Energy 2020-2030, European leaders last night mandated the creation of a successor programme to NER300, “NER400″, which would be “initially endowed with 400 million carbon allowances”. The current programme raised 2.1 bn EUR for innovative renewable energy projects and one CCS project. The next one would raise over 9 bn EUR on the assumption of a carbon price of 23 EUR/tonne. This price is a forecast made in August 2014 by Thomson Reuters for the period 2021-2030.
The European Council wants NER400 to cover “low carbon innovation in industrial sectors” as well as CCS and renewables. A reference to “small projects” has been included in the four lines devoted to the topic in the summit’s Conclusions.
EC (Kerstin) is willing to allow projects flexibility on the requirement to generate at least 75% of the energy they bid to generate in their first five (10 for CCS) years of operation in order to get 100% of their Award.
She said, “If a majority of projects find that, 2-3 years after their entry into operation, they are not on track to generate 75% of the amount they bid for technical reasons, the EC might be prepared to look again at the rule.”
EC proposes an annual NER300 conference in Brussels every autumn to showcase funded projects. Also (Andreas): EC presentations at “conference like EWEA or the biomass conference” and “this year there will be presentations at the SET Plan conference in Rome (10-11 December).”
EC confirms (Kerstin): “The MS is still liable towards the EIB to repay the money.”
If the RC are less than the ones quoted in the application, the EC may need to reduce the award. EC (Lorenzo): “We are confident that the relevant costs as identified at the time of the selection process [i.e. quoted in the application] are the ones that will apply at FID.”
EC (Kerstin): “Up to half of projects in the first call would have not been able to reach FID and therefore would have lost entitlement to their Award if we had not extended the deadlines“.
The EC is prepared to be flexible in the reporting deadlines as these are “not laid down in the Award Decision”. The questioner used the example of a national grid operator that fails, by the start of Year N+1, to report the electricity fed into the grid in year N. This info is necessary to calculate the NER300 award disbursement to the project.
Amendments to Award Decisions collected throughout the year by EC, EC bundles them into one leglislative procedure done once a year. Suggestion that a deadline might be March for the procedure completed by June.
DG CLIMA will hold a ‘Second NER300 Information Event’ on NER300 on 20 October. The invitation and programme sent to the Member States is here.
The morning session will be taken up with a series of presentations similar to those given to First Call awardees and their host Member States on 10 April 2012. One difference will be that the thinking on ‘Knowledge Sharing’ obligations is now much more advanced than it was in 2012, with DG CLIMA having published (here) the templates of Knowledge Sharing collection forms and preliminary details of the techniques it will use to obfuscate the knowledge shared. Also key deadlines have been extended.
Five representatives from associations linked to CCS, wind, ocean energy and biomass and one NGO have been invited to join in the afternoon for ‘Session II: Exchange of experiences and views on NER 300′. DG CLIMA took the position that only renewable energy associations representing particular technologies are eligible to attend, as opposed to associations having a more general view. No webstream will be available.
The renewable energy associations will push for another NER300-type programme, beginning before 2020 if possible.
***UPDATE 19 November 2014: The amendment extending the deadlines***
***UPDATE 20 October 2014: adopted unanimously***
***UPDATE 15 October 2014: Reuters reports the Climate Change Committee approved DG CLIMA’s proposal***
For a project awarded in the First Round (i.e. selected for award in Dec 2012), the deadlines applicable to
The EC says, “The extension of time-limits would apply to any project under the first and second calls,” implying that two-year extensions will be available to second call projects, too.
… comes from the Member States. A leak of draft ‘Conclusions’ for the European Council of 23-24 October 2014, which will define the main features of the EU’s climate and energy policy for the foreseeable future, suggests that maybe 5% of allowances required by the Emissions Trading Scheme to reach a 40% GHG emissions cut by 2030 be used as an ‘initial endowment’ for an ‘enlarged’ NER300-like fund that would include industry.
The EIB would manage it. The focus of the fund would be ‘new innovations’.
The EC has published the Rejection Decision (Part I: legal text, Part II: lists of projects), showing how the 32 projects sent by Member States to the EIB for Technical and Financial Due Diligence were filtered down to the 19 awarded. Five projects failed TFDD. Of the projects that passed, a further four were deemed ineligible (for example, for not being innovative enough). Thus 23 projects made it onto the long-list for funding. The rule of “maximum three projects per Member State over both NER300 awarding Rounds” meant three Member States (France, Sweden, Portugal) with four or more projects that had passed the TFDD and eligibility-check stages had to move projects to a waiting list for funding (Annex 2 of the Rejection Decision) to bring their totals down to three.
The EC is not clear about the circumstances under which these projects may be awarded, saying only it will happen “if funds become available” and if Member States confirm them as per Article 8 of the NER300 Decision. As paragraph 91 of the Call text shows, the EC has not entirely excluded the possibility of awarding more than three projects to a Member State.
The success rate (projects awarded / projects entered to the EIB for evaluation) is high both compared to the First Round…
|Round 1||Round 2|
|RES projects||23/65 = 35%||18/31 = 58%|
…and compared to early indications from the EC’s other funding instrument for energy technology development, Horizon 2020. 420 ‘stage-1’ proposals were submitted the two-stage LCE-01-2014 and LCE-02-2014 calls that closed in April 2014. Of these, 106 have been invited to submit proposals for ‘stage-2’. The grand total of the budget request of the 106 projects is still six times the budget available.
The composition of the 1.0 bn EUR funding pot for the Second Round is as follows.
First, there was left over money from the First Round:
|1st call Award Decision||1 500 000 000 EUR (monetisation proceeds) -
1 211 945 062 EUR (awarded to projects)
|SUB-TOTAL (A)||288 054 938 EUR|
The second component is the proceeds from monetisation of 100 million Second Round allowances. The sales commission charged by the EIB and its carbon market intermediaries needs to be deducted from the gross value of the sales. From the first call, it is known that gross sales of 1 609 125 460 resulted in an NER300 pot of 1 500 000 000 EUR, thus the rate of commission was roughly 6.78%. Applying that to the gross Second Round proceeds yields the following:
|Gross sales of 548 000 000 EUR||After 6.78% commission = net income to the Second Round pot of 510 836 489 EUR (B)|
|SUB-TOTAL (A+B)||798 891 427 EUR|
|Member State||1st Round project||Award /EUR|
|Ireland||Westwave||19 828 007|
|Sweden||Pyrogrot||31 404 829|
|Spain||PTC50-Alvarado||70 000 000|
|SUB-TOTAL (A+B+above)||920 124 263|
|GRAND TOTAL||1.0 bn|
Therefore the collapse of one or more additional First Round project(s) with Award(s) of at least 80 M EUR, as indicated by the row(s) of question marks in the table above, must have formally been notified to the EC since 31 Jan 2014 or it would not have been possible for the EC to award funding to the 19 projects in the Second Round Award Decision.
3 M EUR of unawarded money remains in the NER300 pot at present (statement by Kerstin Lichtenvort on June 26).
On 3 July 2013 there were 32 RES projects in the NER300 Second Round competition compared to 18 awarded today. It would be interesting to know whether a) the EIB’s Technical and Financial Due Diligence and the EC’s eligibility check coupled with the requirement for no more than three projects per Member State account for the entirety of this difference or whether b) some viable projects were not awarded because of lack of funds. The language of Recital 8 of the Award Decision, though convoluted, suggests that the answer is a).
8. […] The Commission checked, if the available funds were greater than the total funding request. As some excess funds were available, all confirmed projects by Member States could be added to the final list of projects in the CCS and RES groups.
… which should be understood as
The grand total of NER300 funding requests of the confirmed projects was less than the funds available, so all were awarded.
To know for sure, however, one would need to see the Rejection Decision, which was adopted by the Climate Change Committee on 4 June. NER300.com has requested it under freedom of information rules.