Renewable Energy
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Assessment of Renewable Energy
Action Plan Implementation and
Progress of Renewable Energy in
Energy Community
ECN et. al.
October 2015
This report was financed by the Energy Community.
Assessment of Renewable Energy Action Plan
Implementation and Progress in the Promotion and Use
of Renewable Energy in the Energy Community
Final Report
Energy Community NREAP
Final Report
Status:
final
Dissemination level:
Public
Last update:
20th July 2015
Assessment of Renewable Energy Action Plan Implementation and Progress in the Promotion
and Use of Renewable Energy in the Energy Community – Final Report
Authors:
Karina Veum, Ayla Uslu, Luuk Beurskens (ECN)
Andreas Tuerk, Dorian Frieden (JOANNEUM RESEARCH)
Mira Todorovic Symeonides, Lazaros Sidiropoulos (Rokas Law Firm)
Gustav Resch, Lukas Liebmann, Amela Ajanovic, Christoph Zehetner (TUWien)
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Assessment of Renewable Energy Action Plan Implementation and Progress in the Promotion
and Use of Renewable Energy in the Energy Community – Final Report
Table of Contents
Executive summary ............................................................................................................................... 12
Main findings/conclusions .................................................................................................................... 12
Main recommendations........................................................................................................................ 18
1
2
Introduction ................................................................................................................................. 20
1.1
Background ........................................................................................................................... 20
1.2
Study objectives, scope and output ...................................................................................... 20
Assessment of Contracting Party NREAPs .................................................................................... 22
2.1
General Chapter Introduction ............................................................................................... 22
2.2
Consistency of the national legislative measures with the NREAPs ..................................... 22
2.2.1
Introduction .................................................................................................................. 22
2.2.2
Overall assessment ....................................................................................................... 24
2.2.3
RES-E ............................................................................................................................. 27
2.2.4
RES-H&C ........................................................................................................................ 34
2.2.5
RES-T ............................................................................................................................. 36
2.3
Relevance of the national legislative measures with reference to the RES Directive .......... 38
2.3.1
Introduction .................................................................................................................. 38
2.3.2
Overall assessment ....................................................................................................... 38
2.3.3
RES-E ............................................................................................................................. 41
2.3.4
RES-H&C ........................................................................................................................ 47
2.3.5
RES-T ............................................................................................................................. 49
2.4
Assessment of Contracting Party RES policies ...................................................................... 51
2.4.1
Introduction .................................................................................................................. 51
2.4.2
Support schemes........................................................................................................... 51
2.4.3
RES-E grid integration ................................................................................................... 57
2.4.4
Guarantee of origin schemes ........................................................................................ 57
2.5
Effectiveness of national legislative measures ..................................................................... 58
2.5.1
Quantitative assessment: evaluating the effectiveness of currently implemented and
planned policy initiatives.............................................................................................................. 58
2.5.2
Qualitative assessment: bottom-up view on target achievement by CP, with a focus on
renewable electricity.................................................................................................................... 59
3
2.6
Viability of national legislative measures ............................................................................. 62
2.7
Recommendations to improve national legislative measures and policy settings............... 66
Quantitative assessment of progress in the share of RES in Contracting Parties ........................ 71
3.1
Introduction .......................................................................................................................... 71
3.2
Assessment of past progress (towards 2012/2013 interim targets for RES) ........................ 71
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Assessment of Renewable Energy Action Plan Implementation and Progress in the Promotion
and Use of Renewable Energy in the Energy Community – Final Report
3.2.1
Method of approach ..................................................................................................... 71
3.2.2
Technology and sectorial coverage (related to subtask (a) and (b)): ........................... 72
3.2.3
Results ........................................................................................................................... 72
3.2.4
Summary of key findings ............................................................................................... 88
3.3
4
Assessment of future progress (towards meeting the 2020 targets) ................................... 89
3.3.1
Method of approach ..................................................................................................... 89
3.3.2
Scenario definition ........................................................................................................ 91
3.3.3
Sensitivity analysis ........................................................................................................ 91
3.3.4
Results ........................................................................................................................... 92
Analysis of biofuels and bioliquids consumed in Contracting Parties........................................ 112
4.1
Overview of biofuel consumption, by type and origin of feedstock in Contracting Parties
112
4.2
Assessment biofuel potential of the Contracting Parties ................................................... 115
4.3
Assessment of national measures to comply with EU sustainability criterial for biofuels . 116
4.3.1
Transposition of the measures to respect sustainability criteria ............................... 117
4.3.2
Measures taken for soil, water and air protection ..................................................... 118
4.3.3
Measures taken by the EU to protect soil, water and air from the negative impacts of
from biofuel production ............................................................................................................. 120
4.4
Impacts of biofuel consumption ......................................................................................... 121
4.4.1
Assessment of land use impacts ................................................................................. 121
4.4.2
Environmental impacts ............................................................................................... 124
4.4.3
Impacts on biodiversity ............................................................................................... 125
4.4.4
Impacts on water, soil, and air .................................................................................... 126
4.4.5
Socio-economic impacts ............................................................................................. 130
5
RES perspectives in the Contracting Parties beyond 2020 ........................................................ 136
6
Conclusions and recommendations ........................................................................................... 138
REFERENCES ........................................................................................................................................ 142
ANNEX I: Summary of findings per Contracting Party ........................................................................ 146
ANNEX II: Biofuel potential assessment ............................................................................................. 147
ANNEX III: 2020 Biofuel Demand related Land use requirements ..................................................... 152
ANNEX IV: ASSESSMENT OF PLANNED (AND CURRENT) POLICY INITIATIVES (PPI (AND CPI)) ........... 153
ANNEX V: BACKGROUND DATA ON ENERGY DEMAND DEVELOPMENTS........................................... 165
ANNEX VI: Consistency of the NREAPs with other national energy strategies ................................... 170
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Assessment of Renewable Energy Action Plan Implementation and Progress in the Promotion
and Use of Renewable Energy in the Energy Community – Final Report
List of Figures
Figure 1: Expected RES share in 2020 according to distinct policy pathways (Green-X scenarios) vs.
2020 RED target (%)................................................................................................................ 59
Figure 2: Comparison of energy output from (up) and required support for (bottom) new RES
installations (2015 to 2020) by 2020. ..................................................................................... 64
Figure 3: Total remuneration for new RES-E installations on average in the period 2015 to 2020,
compared to estimated average wholesale electricity prices. ............................................... 65
Figure 4: Support expenditures for total RES-E on average in the period 2015 to 2020, expressed as
premium per unit of electricity consumed. ............................................................................ 66
Figure 5: Interplay of the six subtasks of task 2.1 (assessment of progress in renewable energy) ...... 71
Figure 6: Default and modified (corrected) data on past (2009) and planned 2020 solid biomass use
in heating & cooling (BM-H) (left) and the related impact on overall RES deployment (right),
indicating default and modified (corrected) RES shares in 2009 and in 2020 (NREAP of
Montenegro; EUROSTAT, 2015). ............................................................................................ 74
Figure 7: The Median RES shares of in 2011/2012 and 2011/2012 including the modified BM data of
the gross final energy demand for all CPs compared to the 2011/2012 indicative trajectory
in the directive. (EIA, 2015; EUROSTAT, 2015; IEA, 2015; DIRECTIVE 2009-28-EC) ............... 75
Figure 8: The deviation of the median 2011/2012 RES shares of GFEC from the renewable energy
directive (RED) minimum trajectory in percentage points. (EIA, 2015; EUROSTAT, 2015; IEA,
2015; DIRECTIVE 2009-28-EC) ................................................................................................ 76
Figure 9: The RES shares calculated for 2012 and 2012 including the modified solid biomass data of
the gross final energy demand for all CPs compared to the reported shares of all available
CPs Progress Reports and the non-binding 2012 and 2013 shares of the CPs NREAP
trajectories. (EIA, 2015; EUROSTAT, 2015; IEA, 2015; CPs NREAPs, draft NEAPs and Progress
Reports) .................................................................................................................................. 77
Figure 10: The deviation of RES shares of GFEC from the NREAP planned trajectory by 2012 and 2013
in percentage points. (EIA, 2015; EUROSTAT, 2015; IEA, 2015; CPs NREAPs, draft NEAPs and
Progress Reports) ................................................................................................................... 77
Figure 11: Absolute RES deployment in 2012 compared to RES deployment of 2012 and 2013 as of
Progress Reports and NREAP trajectories. (EIA, 2015; EUROSTAT, 2015; IEA, 2015; CPs
NREAPs, draft NEAPs and Progress Reports).......................................................................... 78
Figure 12: The percentage deviation of the absolute RES deployment in 2012 and 2013 from the
absolute RES targets set in the CPs NREAPs. (EIA, 2015; EUROSTAT, 2015; IEA, 2015; CPs
NREAPs, draft NEAPs and Progress Reports).......................................................................... 78
Figure 13: RES-E share in 2012 and 2013 of the gross electricity demand for all Contraction Parties
compared to the not binding NREAP targets. (EIA, 2015; EUROSTAT, 2015; IEA, 2015; CPs
NREAPs, draft NEAPs and Progress Reports).......................................................................... 79
Figure 14: The deviation of the RES-E share in 2012 and 2013 from the RES-E target shares set in the
CPs NREAPs in percentage points. (EIA, 2015; EUROSTAT, 2015; IEA, 2015; CPs NREAPs,
draft NEAPs and Progress Reports) ........................................................................................ 79
Figure 15: Absolute RES-E deployment in 2012 and 2013 for all CPs compared to the indicative
NREAP targets. (EIA, 2015; EUROSTAT, 2015; IEA, 2015; CPs NREAPs, draft NEAPs and
Progress Reports) ................................................................................................................... 80
Figure 16: The percentage deviation of the absolute RES-E deployment in 2012 and 2013 from the
absolute RES-E targets set in the CPs NREAPs. (EIA, 2015; EUROSTAT, 2015; IEA, 2015; CPs
NREAPs, draft NEAPs and Progress Reports).......................................................................... 80
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Assessment of Renewable Energy Action Plan Implementation and Progress in the Promotion
and Use of Renewable Energy in the Energy Community – Final Report
Figure 17: Biomass deployment in the electricity sector in 2012 and 2013 for all CPs compared to the
indicative NREAP targets. (EUROSTAT, 2015; IEA, 2015; CPs NREAPs, draft NREAPs and
Progress Reports) ................................................................................................................... 81
Figure 18: Biogas deployment in the electricity sector in 2012 and 2013 for all CPs compared to the
indicative NREAP targets. (EUROSTAT, 2015; IEA, 2015; CPs NREAPs, draft NEAPs and
Progress Reports) ................................................................................................................... 81
Figure 19: Electricity generated by Hydropower in 2012 and 2013 for all CPs compared to the
indicative NREAP targets. (EIA, 2015; EUROSTAT, 2015; IEA, 2015; CPs NREAPs, draft NEAPs
and Progress Reports) ............................................................................................................ 82
Figure 20: The percent deviation of hydropower generation in 2012 and 2013 from the targets set in
the CPs NREAPs. (EIA, 2015; EUROSTAT, 2015; IEA, 2015; CPs NREAPs, draft NEAPs and
Progress Reports) ................................................................................................................... 82
Figure 21: PV deployment in 2012 and 2013 for all CPs compared to the indicative NREAP targets.
(EUROSTAT, 2015; IEA, 2015; DIRECTIVE 2009-28-EC) ........................................................... 83
Figure 22: Wind onshore deployment in 2012 and 2013 for all CPs compared to the indicative NREAP
targets. (IEA, 2015; EUROSTAT, 2015; CPs NREAPs, draft NEAPs and Progress Reports) ...... 83
Figure 23: RES-H share in 2012 and 2013 of the gross heating and cooling demand for all Contraction
Parties compared to the indicative NREAP targets. (EUROSTAT, 2015; IEA, 2015; CPs
NREAPs, draft NEAPs and Progress Reports).......................................................................... 84
Figure 24: The deviation in percentage points of the RES-H shares in 2012 and 2013 from the RES-H
target shares set in the CPs NREAPs. (EIA, 2015; EUROSTAT, 2015; IEA, 2015; CPs NREAPs,
draft NEAPs and Progress Reports) ........................................................................................ 84
Figure 25: The absolute RES-H deployment in 2012 and 2013 of the gross heating and cooling
demand for all Contraction Parties compared to the indicative NREAP targets. (EUROSTAT,
2015; IEA, 2015; CPs NREAPs, draft NEAPs and Progress Reports) ........................................ 85
Figure 26: The biomass deployment in the heating and cooling sector for the years 2012 and 2013
compared to the NREAP trajectory. (EUROSTAT, 2015; IEA, 2015; CPs NREAPs, draft NEAPs
and Progress Reports) ............................................................................................................ 85
Figure 27: The percentage deviation of biomass deployment in 2012 and 2013 from the indicative
NREAP targets. (EIA, 2015; EUROSTAT, 2015; IEA, 2015; CPs NREAPs, draft NEAPs and
Progress Reports) ................................................................................................................... 86
Figure 28: Geothermal deployment in the heating and cooling sector in 2012 and 2013 compared to
the indicative NREAP targets. (EUROSTAT, 2015; IEA, 2015; CPs NREAPs, draft NEAPs and
Progress Reports) ................................................................................................................... 86
Figure 29: Solar thermal deployment in the heating and cooling sector in 2012 and 2013 compared
to the indicative NREAP targets. (EUROSTAT, 2015; IEA, 2015; CPs NREAPs, draft NEAPs and
Progress Reports) ................................................................................................................... 87
Figure 30: Heat pump deployment in the heating and cooling sector in 2012 and 2013 compared to
the indicative NREAP targets. (EUROSTAT, 2015; IEA, 2015; CPs NREAPs, draft NEAPs and
Progress Reports) ................................................................................................................... 87
Figure 31: Biofuel deployment in 2012 and 2013 for all Contraction Parties compared to the NREAP
trajectory. (EUROSTAT, 2015; IEA, 2015; CPs NREAPs, draft NEAPs and Progress Reports).. 88
Figure 32: Expected RES share in 2020 vs. 2020 RED minimum trajectory and 2020 indicative (NREAP)
target (%). ............................................................................................................................... 93
Figure 33: Deviation of expected RES shares (Green-X scenarios) from indicative (NREAP) target by
2020. ....................................................................................................................................... 94
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Assessment of Renewable Energy Action Plan Implementation and Progress in the Promotion
and Use of Renewable Energy in the Energy Community – Final Report
Figure 34: Actual (2012) and expected RES deployment (in absolute terms) in 2020 vs. 2020
indicative (NREAP) target. ...................................................................................................... 95
Figure 35: Expected RES-E share in 2020 vs. 2020 indicative (NREAP) target (%). ................................ 95
Figure 36: Deviation of expected RES-E shares (Green-X scenarios) from indicative (NREAP) target by
2020. ....................................................................................................................................... 96
Figure 37: Expected RES-E deployment (in absolute terms) in 2020 vs. 2020 indicative (NREAP)
target. ..................................................................................................................................... 96
Figure 38: Deviation from indicative target - Biomass .......................................................................... 97
Figure 39: Deviation from indicative target - Biogas ............................................................................. 98
Figure 40: Deviation from indicative target - Geothermal .................................................................... 99
Figure 41: Deviation from indicative target – Hydro ........................................................................... 100
Figure 42: Deviation from indicative target – Photovoltaics ............................................................... 101
Figure 43: Deviation from indicative target - Wind onshore ............................................................... 102
Figure 44: Expected RES-H share in 2020 vs. 2020 indicative (NREAP) target (%). ............................. 103
Figure 45: Deviation of expected RES-H shares (Green-X scenarios) from indicative (NREAP) target by
2020. ..................................................................................................................................... 103
Figure 46: Expected RES-H deployment (in absolute terms) in 2020 vs. 2020 indicative (NREAP)
target. ................................................................................................................................... 104
Figure 47: Deviation from indicative target - Biogas (Heat) ................................................................ 105
Figure 48: Deviation from indicative target - Biomass (Heat) ............................................................. 106
Figure 49: Deviation from indicative target - Geothermal (Heat) ....................................................... 107
Figure 50: Deviation from indicative target - Solar thermal (Heat) ..................................................... 108
Figure 51: Deviation from indicative target - Heat pumps (Heat) ....................................................... 109
Figure 52: Expected biofuel share in 2020 (%). ................................................................................... 110
Figure 53: Expected biofuel deployment (in absolute terms) in 2020 vs. 2020 indicative (NREAP)
target. ................................................................................................................................... 111
Figure 54: Deviation of expected biofuel deployment (Green-X scenarios) from indicative (NREAP)
target by 2020. ..................................................................................................................... 111
Figure 55: Biofuel potentials of the CPs in 2020 in comparison to the NREAP demand (ktoe)........... 116
Figure 56: Average Land required to produce the 2020 biofuel demand (Ha).................................... 123
Figure 57 Biofuel potential (on the left side) and the amount of required feedstock (on the right) to
produce biofuels in Albania up to 2030 ............................................................................... 148
Figure 58 Biofuel potential (on the left) and the amount of required feedstock (on the right) to
produce biofuels in Bosnia and Herzegovina up to 2030 ..................................................... 148
Figure 59 Biofuel potential (on the left) and the amount of required feedstock (on the right) to
produce biofuels in FYR of Macedonia up to 2030 .............................................................. 149
Figure 60 Biofuel potential (on the left) and the amount of required feedstock (on the right) to
produce biofuels in Kosovo* up to 2030 .............................................................................. 149
Figure 61 Biofuel potential (on the left) and the amount of required feedstock (on the right) to
produce biofuels in Moldova up to 2030 ............................................................................. 150
Figure 62 Biofuel potential (on the left) and the amount of required feedstock (on the right) to
produce biofuels in Montenegro up to 2030 ....................................................................... 150
Figure 63 Biofuel potential (on the left) and the amount of required feedstock (on the right) to
produce biofuels in Serbia up to 2030 ................................................................................. 151
Figure 64 Biofuel potential (on the left) and the amount of required feedstock (on the right) to
produce biofuels in Ukraine up to 2030 ............................................................................... 151
Figure 65. S-curve: Market penetration of new technologies (Resch, 2005). ..................................... 153
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Assessment of Renewable Energy Action Plan Implementation and Progress in the Promotion
and Use of Renewable Energy in the Energy Community – Final Report
Figure 66: Gross final energy consumption according to the NREAP scenarios of Albania compared to
the historic development up to 2012 and the Progress Report (2012 and 2013, if available).
(EUROSTAT, 2015) ................................................................................................................ 165
Figure 67: Gross final energy consumption according to the NREAP scenarios of Bosnia and
Herzegovina compared to the historic development up to 2012 and the Progress Report
(2012 and 2013, if available). (IEA, 2015) ............................................................................. 166
Figure 68: Gross final energy consumption according to the NREAP scenarios of Kosovo* compared
to the historic development up to 2012 and the Progress Report (2012 and 2013, if
available). (IEA, 2015) ........................................................................................................... 166
Figure 69: Gross final energy consumption according to the NREAP scenarios of FYR of Macedonia
compared to the historic development up to 2012 and the Progress Report (2012 and
2013, if available). (EUROSTAT, 2015) .................................................................................. 167
Figure 70: Gross final energy consumption according to the NREAP scenarios of Moldova compared
to the historic development up to 2012 and the Progress Report (2012 and 2013, if
available). (IEA, 2015) ........................................................................................................... 168
Figure 71: Gross final energy consumption according to the NREAP scenarios of Montenegro
compared to the historic development up to 2012 and the Progress Report (2012 and
2013, if available). (IEA, 2015; EIA, 2015) ............................................................................. 168
Figure 72: Gross final energy consumption according to the NREAP scenarios Serbia compared to the
historic development up to 2012 and the Progress Report (2012 and 2013, if available).
(IEA, 2015; EIA, 2015) ........................................................................................................... 169
Figure 73: Gross final energy consumption according to the NREAP scenarios of Ukraine compared to
the historic development up to 2012 and the Progress Report (2012 and 2013, if available).
(IEA, 2015; EIA, 2015) ........................................................................................................... 169
Figure 74: GFEC/ GFEC Electricity projections for Albania................................................................... 171
Figure 75: GFEC/ GFEC Electricity projections for Kosovo* ................................................................. 172
Figure 76: RES Detail projections for Kosovo* ..................................................................................... 173
Figure 77: GFEC/ GFEC Transport projections for Serbia ..................................................................... 174
Figure 78: RES Detail projections for Serbia ........................................................................................ 174
Figure 79: GFEC projections for Montenegro ...................................................................................... 175
Figure 80: KAP sensitivity analysis – GFEC projections for Montenegro ............................................. 176
Figure 81: RES Detail projections for Montenegro .............................................................................. 177
Figure 82: GFEC/ % RES in GFEC projections for FYR of Macedonia .................................................... 178
Figure 83: RES Detail projections for FYR of Macedonia ..................................................................... 179
Figure 84: GFEC/ GFEC Electricity projections for Moldova ................................................................ 180
Figure 85: GFEC/ GFEC Electricity projections for Ukraine .................................................................. 181
Figure 86: RES Detail projections for Ukraine ...................................................................................... 182
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Assessment of Renewable Energy Action Plan Implementation and Progress in the Promotion
and Use of Renewable Energy in the Energy Community – Final Report
List of Tables
Table 1: Adoption of NREAPs and Progress Reports in Contracting Parties .......................................... 24
Table 2: Assessment of relevance of the national legislative measures with RES DIRECTIVE (RES-E) .. 41
Table 3: Assessment of relevance of the national legislative measures with NREAPs (RES-H&C) ........ 47
Table 4: Assessment of relevance of the national legislative measures with NREAPs (RES-T) ............. 49
Table 5: Overview of caps on supported amounts (quotas) in the Contracting Parties........................ 52
Table 6: Assessment of administrative procedures in Contracting Parties ........................................... 55
Table 7: Technology and sectorial split within the quantitative assessment ........................................ 72
Table 8: Default and modified (corrected) data on past (2009) and planned 2020 solid biomass use
for heating & cooling (BM-H) (NREAP of Montenegro; EUROSTAT, 2015). ........................... 74
Table 9: The median RES share in gross final energy demand by 2011/2012 compared to the RED
minimum trajectory. (EIA, 2015; EUROSTAT, 2015; IEA, 2015; DIRECTIVE 2009-28-EC) ....... 75
Table 10: The RES share in gross final energy demand by 2012 and 2013 compared to the NREAP
planned trajectory. (EIA, 2015; EUROSTAT, 2015; IEA, 2015; CPs NREAPs, draft NREAPs and
Progress Reports) ................................................................................................................... 76
Table 11: Expected, planned and required RES shares in 2020. ............................................................ 94
Table 12: Comparison of planned and expected deployment - Biomass .............................................. 97
Table 13: Comparison of planned and expected deployment - Biogas ................................................. 98
Table 14: Comparison of planned and expected deployment - Geothermal ........................................ 99
Table 15: Comparison of planned and expected deployment - Hydro ................................................ 100
Table 16: Comparison of planned and expected deployment - Photovoltaics .................................... 101
Table 17: Comparison of planned and expected deployment - Wind onshore ................................... 102
Table 18: Comparison of planned and expected deployment - Biogas (Heat) .................................... 105
Table 19: Comparison of planned and expected deployment - Biomass (Heat) ................................. 106
Table 20: Comparison of planned and expected deployment - Geothermal (Heat) ........................... 107
Table 21: Comparison of planned and expected deployment - Solar thermal (Heat) ......................... 108
Table 22: Comparison of planned and expected deployment - Heat pumps (Heat) ........................... 109
Table 23: CP Biodiesel & bioethanol production and consumption in transport sector in 2009-2012
expressed as absolute volumes (tons) (rounded up to nearest whole figure) .................... 113
Table 24: Names and the capacities of existing biodiesel and bioethanol factories ........................... 114
Table 25: Estimated GHG emission reductions of RES in transport sector (in ton CO2equivalents)(based on the Progress Reports) ...................................................................... 124
Table 26: Potential Water Impacts within Biofuel Supply Chains (Hamelinck et al., 2012) ................ 127
Table 27: Water requirements of different types of biofuel feedstock per unit of energy produced
(de Fraiture and Berndes, 2009)........................................................................................... 128
Table 28 Average land needed to produce the necessary feedstock for biofuels in each CP in 2020
(Ha) ....................................................................................................................................... 152
Table 29: Overview of respected measurements for the mitigation of non-cost barriers .................. 155
Table 30: Summary of planned measures as of CP’s NREAPs and Progress Reports for the mitigation
of non-cost barriers per energy sector. The numbers in the table signify percentages to
what extent non-cost barriers are removed. For a more detailed description see paragraph
above this table. ................................................................................................................... 160
Table 31: Existing and planned financial measures as of the CP’s NREAPs and Progress Reports. ..... 161
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Assessment of Renewable Energy Action Plan Implementation and Progress in the Promotion
and Use of Renewable Energy in the Energy Community – Final Report
List of abbreviations
AL
Albania
ANRE
Regulatory Authority for Energy in Moldova
BiH
Bosnia and Herzegovina
CAP
Common Agricultural Policy
CEFIC
European Chemical Industry Council
CEPI
The Confederation of European Paper Industries
CITES
Convention on International Trade in Endangered Species of Wild Fauna and
Flora
CP
Contracting Party
DSO
Distribution system operator
EEA
European Economic Area
EIA
Environmental Impact Assessment
ECS
Energy Community Secretariat
ET
Evapotranspiration
EU
European Union
FAO
Food and Agriculture Organisation of the United Nations
FIT
Feed-in Tariff
FIP
Feed-in Premium
BIH(FBiH)
Federation of Bosnia and Herzegovina
BIH(RS)
Republika Srpska
FYR of Macedonia
Former Yugoslav Republic of Macedonia
GEF
Global Environment Facility
GDP
Gross Domestic Product
GoO
Guarantees of Origin
ILC
International Land Coalition
iLUC
Indirect land use change
KEPA
Kosovo* Environmental Protection Agency
KO*
Kosovo*
ME
Montenegro
MO
Moldova
MS
Member States
NRA
National Regulatory Authority in Energy
NREAP
National Renewable Energy Action Plan
OECD
Organisation for Economic Co-operation and Development
PM10
Particulate matter with a diameter of 10 micrometres or less
PPA
Power Purchase Agreement
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Assessment of Renewable Energy Action Plan Implementation and Progress in the Promotion
and Use of Renewable Energy in the Energy Community – Final Report
PR
Progress Report
RA
Regulatory Authority for Energy at entity level in BiH
REAP
Renewable Energy Action Plan
RES
Renewable Energy Source
RES-E
Renewable Electricity
RES-H&C
Renewable Heating & Cooling
RES-T
Renewable Energy in Transport
SAEE
State Agency on energy Efficiency and Energy Savings of Ukraine
RS
Serbia
TSO
Transmission system operator
UA
Ukraine
UCO
Used Cooking Oil
UN CSD
The United Nations Commission on Sustainable Development
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Assessment of Renewable Energy Action Plan Implementation and Progress in the Promotion
and Use of Renewable Energy in the Energy Community – Final Report
Executive summary
Main findings/conclusions
National legislative measures to promote RES deployment
•
•
•
•
•
•
•
•
•
In general, efforts for improvement of the legislative and regulatory framework have been
made, including amendment of existing (or introducing of new) major primary legislation,
such as RES laws, energy or electricity laws, laws on biofuels etc. However, adoption and
implementation of RES-related primary and secondary legislation is generally rather slow
and often very delayed.
It should also be highlighted that three of the eight Contracting Parties have yet to adopt
NREAPs, a key planning document both in terms of defining trajectories towards national
2020 RES targets as well as defining and describing the measures that will be implemented
to reach the 2020 RES target.
In the last 2-3 years, undoubtedly the most significant progress by most Contracting Parties
in adopting legislative measures in compliance with the RES Directive has been made in the
RES-E sector. Some efforts to improve the legislative framework for RES deployment have
been made with regard to the RES-H&C sector, while the RES-T sector seems to have been
left behind in all Contracting Parties.
Several important compliance gaps with respect to the RES Directive remain. In many of the
Contracting Parties compliance gaps can be seen with regard to improved administrative
procedures in all three sectors (RES-E, RES-H&C and RES-T): simplification of authorisation
and licensing rules and improvement of coordination of different bodies are issues which
are still not properly addressed in most cases.
Apart from introducing attractive support measures, legislation is still not very investorfriendly, which is reflected among others in the insufficient regulations on the adoption and
proper formulation of Power Purchase Agreements. CPs rarely initiate promotion of RES
without financed programmes.
Assistance to applicants and dissemination of information to interested parties in general is
also an issue which needs to be improved in all CPs. Compliance with information
requirements mostly consist in uploading most of the relevant legislation and regulation on
the internet pages of the respective authorities and most often only in local language.
While rules aiming to ensure access of RES producers to the networks are in most CPs
developed, network development for the purpose of integration of new RES capacities is
very important in this respect and is generally not on a satisfactory level.
Most CPs failed so far to regulate the minimum use of RES in the building sector as well as
the exemplary role of public sector in development of RES-H&C which would be the
necessary.
There is no compliance in any CP regarding RES-T. Only in some CPs introduction of
minimum biofuel obligations, regulation of sustainability criteria and establishment of
verification schemes are currently included in draft legal acts.
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Assessment of Renewable Energy Action Plan Implementation and Progress in the Promotion
and Use of Renewable Energy in the Energy Community – Final Report
Quantitative assessment of past RES progress (2012/2013):
•
•
•
•
•
We start with assessing compliance with required minimum trajectory targets (according to
the RES Directive). It can be seen that only Montenegro achieved its RED target for
2011/2012 whereas all other CPs fall short in complying. For the case of Montenegro it has
to be taken into account that national energy balances have been corrected retrospectively
for a final consumption of solid biomass in the heating and cooling sector. Therefore its
share of RES in GFEC increased anyways without any additional deployment (see Box 2 on
page 73 for a detailed description). Of interest, the RES Directive minimum trajectory for
2011/2012 sets a relatively strict interim target. This can be seen when comparing these
with interim targets defined by CPs in their NREAPs: all interim targets of the NREAPs for
2012 show a lower percentage target than the RED Minimum Trajectory for 2011/2012.
A comparison of actual and planned RES shares in GFEC (in accordance with CP’s NREAPs)
shows that almost all of the CPs have managed to meet their planned overall RES shares for
the years 2012 and 2013. The CP who missed its targets was Moldova by 2.2 percentage
points in 2012 and 0.4 percentage points in 2013. The strongest positive deviations of actual
to planned RES shares in GFEC in 2012 occur for Albania (3.2 percentage points (p.p.)),
Montenegro (13.5 p.p.), FYR of Macedonia (4.9 p.p.) and Serbia (2.3 p.p.). In 2013
Montenegro overachieved its target by 10.8 (see Box 2 for further explanations on the
special case of Montenegro) and FYR of Macedonia by 3.1 percentage points, respectively. If
the absolute RES deployment is considered, six CPs met their absolute NREAP targets in
2012, but only two did so in 2013. The negative deviations in 2013 range from minus 1.1%
for Kosovo* to minus 5% of planned vs. actual deployment for FYR of Macedonia. In this
case positive examples are Ukraine who surpassed its absolute NREAP RES targets by 37.5%
in 2012 and 23.5% in 2013, and Montenegro who surpassed its absolute target in 2012 by
43.4% and 32.2% in 2013, respectively.
With respect to the deployment of renewable electricity it can be seen that most CPs are
well on track. When statistics are compared to NREAPs Albania surpassed its planned RES-E
share by 3.5 in 2012 and 0.8 percentage points in 2013. Kosovo*, Moldova and Ukraine met
their planned RES-E shares in 2012 and 2013 by +-0.6 percentage points. Also Montenegro
did so in 2012 but fell short in 2013 with a deficit of 6.2 percentage points. FYR of
Macedonia missed its RES-E target by 4.7 and 2.5 percentage points in 2012 and 2013.
Serbia had a surplus of 2.4 and deficit of 1.9 percentage points in 2012 and 2013.
The status of renewable energies in the heating and cooling sector depends very much on
the statistical records of solid biomass use for every CP. As such, the picture for the absolute
RES-H deployment and NREAP trajectory fulfilment in this report depends significantly on
the (necessary) correction of national biomass data. The assessment of these corrections
dates back to the RES target setting process of the ECS in 2012. If these corrections are
applied Kosovo*, Montenegro, FYR of Macedonia, Serbia and Ukraine managed to meet
their RES-H target shares in 2012 and 2013. Moldova showed a deficit in 2012 but met its
target in 2013. Finally, Albania is the only CP that missed its RES-H target in both years.
Only Albania, Ukraine and to a very small amount the FYR of Macedonia report some
biofuel deployment in the transport sector for the year 2013 in their Progress Reports. The
planned deployment of Montenegro as reported in its NREAP for 2012 and 2013 were not
fulfilled at all and in the case of FYR of Macedonia only to a very small amount. Available
energy balances for 2012 and 2013 could only verify a small production of biofuels in the
FYR of Macedonia and a more respectable volume in Ukraine in 2013.
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Quantitative assessment of future RES progress (to 2020):
•
•
•
•
•
•
Modelling results on expected future progress by 2020 (i.e. against binding 2020 RES target)
indicate by CP the likeliness of delivering as required under the RES Directive. The basket of
assessed cases includes four distinct scenarios: two policy scenarios (i.e. CPI and CPI + PPI)
combined with two distinct demand developments (i.e. reference and efficiency trend,
originally based on CPs NREAPs but corrected in accordance with actual demand
developments).
Results suggest that only one CP, i.e. Montenegro, is expected to reach the given 2020
target with currently implemented and planned policy measures. Another CP, namely
Moldova may be added to that list where expected 2020 RES deployment is slightly below
the given target. All other CPs appear to fail in complying with their binding 2020 RES target
whereby a comparatively small gap is expected for Serbia. Despite the expected increase in
absolute terms, BiH and Ukraine would for example fail to achieve their 2020 RES targets. At
the aggregated level (i.e. all CPs in total), a comparison of the expected and targeted 2020
RES share points out that a gap in size of about 4 to 6 percentage points would occur if no
additional policy revisions (to the ones implemented or planned) are undertaken.
Next a closer look is taken on the expected progress in meeting planned (i.e. according to
NREAPs) RES deployment by 2020: Only a few CPs have established a higher RES
deployment target than their required one, namely Albania, Moldova and Montenegro.
Thus, the number of CPs that are expected to meet their planned trajectory is diminishing
compared to above – i.e. none of the CPs is expected to meet its indicative NREAP target.
This does not change even if optimistic framework conditions like a low demand growth (in
accordance with the energy efficiency demand scenario) are assumed and planned RES
policy initiatives in addition to currently implemented ones are taken into consideration.
Deviations are modest in Moldova, Montenegro and Serbia and highest in Ukraine.
None of the CPs is expected to comply with own deployment plans for RES-E. Thus, in all CPs
expected deployment lacks behind the planned one. The gap appears comparatively low in
CPs like Moldova, Montenegro or Serbia, whereas high deviations are apparent for Kosovo*,
FYR of Macedonia, Albania and Ukraine. Thus, in those CPs a strengthening and fine tuning
of policy initiatives offering adequate support for all available RES-E technologies and a
rapid removal of non-cost barriers that hinder a rapid take-off of RES-E appear
indispensable for achieving 2020 deployment plans and for meeting overall binding RES
targets.
Compared to other sectors, the RES-H&C sector offers comparatively promising RES
potentials due to suitable framework conditions like high solar incoming radiation in
Western Balkans or a high potential of biomass feedstock in almost all CPs. Thus, RES-H&C
can be classified as “low hanging fruits”. Biomass heat used in households or industry is
here the key RES both in terms of planned and according to modelling expected deployment
whereas other promising RES options like solar thermal collectors, the use of heat pumps or
of geothermal resources are generally underrepresented in policy making and in market
establishments. A combination of tailored financial incentives and campaigns to increase
public awareness may consequently serve well to increase demand for renewable sources in
heating and cooling which, in turn, would significantly contribute towards overall RES target
achievement.
With respect to biofuels in transport it can be concluded that the establishment of a real
market for biofuel is key for almost all of the CPs. Blending obligations, partly combined
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with tax exemptions for the use of biofuels, are simple and straightforward policy measures
that allow for that. This would increase overall renewables deployment significantly in all
CPs that have failed to do so in prior, and, consequently, increase overall progress in terms
of achieving binding 2020 RES targets.
Support schemes
•
•
•
•
•
•
FIT systems are implemented in almost all CPs (except for Moldova, while the BiH (entity RS)
has a combination of FIT and FIP), however, these are subject to changes and uncertainties.
There is a clear in need in all CPs to provide more investor confidence, particularly through
long term stable and predictable FIT schemes, for example FITs in Ukraine.
The support schemes for RES-E show mixed success in CPs, e.g. only in a few CPs could an
expansion of non-hydro RES-E be observed so far. In most CPs, for example, are there no or
only the first wind parks being implement even though FITs have been in place for several
years.
Often, one can see that it’s not necessarily the FITs that are a major bottleneck but the
administrative barriers, which increase the country risk, and a lack of investors due to
unattractive framework (high country risks in general). In a few CPs, FIT levels were either
lowered after their introduction or are calculated on an annual basis leading to increased
uncertain among investors.
Non-hydro technologies which can be more cost-effective often have strict budgetary limits
restricting diversity of the RES technology mix.
For the RES-H&C sector, only a few CPs have support schemes in place and in most cases on
a limited scale.
For RES-T, several CPs have included legal provisions covering blending obligation in draft
legal acts, which have not been adopted yet, for example Kosovo*. There are other CPs with
older legal acts in place providing for blending obligation which have never been applied in
practice, Albania, BIH entities (FBIH; RS) and UA. Support mechanisms are in place in
Moldova, which applies the same remuneration scheme for biofuels producers as for RES
electricity producers or tax exemption in Albania and Ukraine.
Administrative procedures
•
•
•
•
Overall progress made by the CPs to improve administrative procedures since the adoption
of the NREAPs has been limited. Lengthy procedures remain a key barrier for RES
deployment in all three sectors.
The has been progress made regarding a simplification of administrative procedures
however in most CPs far beyond what would be required to enable fast implementation of
RES needed for target achievement.
A lack of coordination between different administrative levels and agencies is a major
problem in most CPs. Often numerous state and local level authorities are involved in the
licensing and administrative procedures.
Information is not coordinated and in some cases still neither transparent nor even
comprehensive. Serbia is a notable exception and provides a good model for other CPs, for
example in 2013 four guides for investors, updating the ones of 2010, and a new one were
produced. In most CPs at least some attempts to simplify administrative procedures can be
observed.
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•
•
•
Very little progress can be seen in the CPs on the practical implementation of a one-stop
shop. A one-stop shop was implemented only in Serbia for construction licenses and in
Albania for all licenses and permits required for a project, though some specific licenses and
permits are not integrated in the one-stop shop.
The requirement that administrative charges to be paid are transparent and cost related
show a very mixed picture among the CPs. Only in few CPs they are both, transparent and
cost related. In several Contracting Parties there are some simplifications for smaller/
decentralized projects but further simplifications are needed in most Contracting Parties.
For the RES-T sector, there is little to report as close to zero efforts have been made to
improve the licensing procedures, largely linked to the fact that there is no biofuels
production and consumption taking place in most CPs.
RES-E integration
•
•
Overall progress made by CPs to facilitate and improve the integration of RES-E into the grid
has generally been slow. While the NREAPs provide a fairly positive picture of measures that
will be undertaken, in many cases these measures are still pending.
As for priority connection for RES-E producers, the picture is quite dim. Although some
Contracting Parties have in place provisions for priority connection, e.g. Albania, FYR of
Macedonia, Kosovo* and BiH (at the level of one entity –), in reality it is not the case.
Biofuels production and consumption
•
•
•
•
•
Among the Contracting Parties, Albania, FYR of Macedonia and Ukraine report some biofuel
deployment in the transport sector in their Progress Reports. Additionally, stakeholders from
Montenegro and Serbia have reported biofuel production and/or consumption. In the other
CPs the production and consumption are either null or only limited to self-consumption,
mainly at the farmers level, and therefore regarded as null.
While the very limited amount of current production and consumption relate to biodiesels,
Ukraine is the only CP with known bioethanol production.
The technical potential of biofuels in each CP is much higher when compared with the 2020
set targets. There is significantly more potential for using ethanol-producing feedstock (such
as wheat and corn) than oil seeds (such as soy and oilseed rape).
According to the results, overall, domestic oilseed production would not be sufficient to
satisfy the 2020 biodiesel targets set by the CPs. It should, however, be noted that the
biofuel potential assessment considers agricultural crops, grass, manure, waste fat and
organic waste and doesn’t include for instance used cooking oils (UCO).
While imports of oilseed crops or biodiesel will be crucial to meeting the target, the role of
domestic crops such as wheat, sugar beet and maize in producing ethanol and contributing
to the target should be considered.
Biofuels sustainability
•
•
Currently, the legislative framework to comply with the EU sustainability criteria is not in
place in the CPs. However, these will be essential in order to establish the conditions for
their introduction and subsequent contribution towards the renewable energy targets
established in the Renewable Energy Directive.
The CP progress reports provide no evidence about the impact of biofuel production on the
national land use patterns as there have been very little or no biofuel production in the CPs.
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•
•
•
•
•
•
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•
According to the existing NREAPs (Kosovo*, Moldova, Montenegro, Serbia and Ukraine) the
biofuel demand in the 5 CPs for 2020 are approximately 727 ktoe. When compared with the
EU27 it is only 7.5% of the EU’s 2010 biofuel consumption. As such, any possible future land
use impacts of the CPs biofuel demand will be well below the EU’s current/recent land use
impacts.
The results indicate land use requirements in average would corresponds to approximately
453 thousand Ha, representing only 1% of total arable and fallow land of the respective CPs
(Kosovo*, Moldova, Montenegro, Serbia and Ukraine). For comparison, the worldwide total
land use to produce the feedstock for EU-consumed biofuels in 2010 was estimated to be
about 5.7 Mha. Of this, 3.2 Mha (57%) is within the EU and 2.4 Mha (43%) resides outside
the EU (Hamelinck et al., 2012).
The current deployment impacts of biofuels on biodiversity, water, air and soil are negligible
in the CPs (as the production figures are very small or null). It is, however, important to
highlight that the sustainability criteria focusing on these aspects of the 2009 RED shall be
adopted to avoid any possible negative impacts of increased biofuel production and
consumption to environment in the future.
When looked at the recent progress reports of the EU Commission that are prepared
regularly to the Council and Parliament on the progress made by the CPs of the Western
Balkans region towards European integration, the environment regulations related to air,
water, soil and biodiversity are not yet aligned with the EU legislations. While solutions are
available for mitigating the environmental impacts which result from biofuel plants, but may
not be installed in regions with lax environmental regulations or limited law enforcement
capacity.
The future water demand of biofuels and the likely impacts will depend on the location
where the energy crop will be grown; the scope of increase in water productivity of main
feedstock crops and the water stress level of the region. The Western Balkans have relatively
abundant freshwater resources but in many parts of the region water is scarce, particularly
in summer months. According to the study conducted by WRI (2013) most of the CPs water
stress level are indicated as low stress (<10%). Albania and Moldova are classified as low to
medium stress (10-20%), whereas FYR of Macedonia and Ukraine highlighted as medium to
high stress (20-40%).
There is a concern that increased demand for biofuel feedstock may increase the pressure
on agriculture and encourage expansion of cropping area, shift from diversity to
monoculture, increase use of inputs that in return result in negative impact on soil. There
are some indications towards soil degradation due to increased biofuel demand (mainly
from the EU); however, no definitive conclusions can be drawn.
While the exact impact of biofuel policies on food prices is not clear, several studies
acknowledge that biofuel policies and targets put further pressure on the demand for the
oily crops and grains.
There have been concerns related to the likely negative impacts of increased demand for
biofuels in land use rights. Land grabbing may become an issue in the CPs if/when foreign
investors consider West Balkans as potential area to produce biofuels.
The advantage of biofuels over technologies such as wind energy or solar PV is that it is
more labour intensive where the feedstock is grown and refined into a biofuel (IRENA,
2011). As such, biofuel production can create employment opportunities in the CPs.
Increasing demand of biofuels may affect other sectors that also use biomass as raw
material for their production of goods, such as the pulp and paper industry, the chemical
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industry, the oleo-chemical industry and food processing industry. The sector organisations,
such as the chemical industry CEFIC and the pulp and paper industry CEPI have been
claiming that the increasing demand for bioenergy and biofuels, supported by the policies,
may have undesired and adverse impacts on these sectors.
Main recommendations
General recommendations
•
•
•
•
Three of the Contracting Parties (Albania, Bosnia and Herzegovina, and FYR of Macedonia)
should give immediate priority to the adoption of their NREAP, as this is a key tool for
identifying concretely the RES trajectories and accompanying measures required to achieve
their 2020 RES targets.
Furthermore, Contracting Parties should proceed without delay to the pending amendments
to existing main legislative instruments (RES laws, energy laws, electricity laws etc.) or to
adoption of new such acts currently in draft form. Adoption of such acts should be
immediately succeeded by the issuance of respective implementing regulations.
Regarding RES Directive compliance with information requirements, appointing an
information desk with properly trained staff is recommended in all Contracting Parties. Such
a desk could be combined with or even act as an important starting point for the
implementation of a one-stop-shop for permitting procedures.
On the non-legal aspect, a strengthening and fine-tuning of policy initiatives offering
adequate support for RES-E technologies and a rapid removal of non-cost barriers that
hinder a rapid take-off of RES-E appear indispensable for achieving 2020 deployment plans
and for meeting the binding RES targets.
RES-E recommendations
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•
•
•
For the majority of CPs a strengthening and fine-tuning of policy initiatives offering adequate
and cost-efficient support for RES-E technologies and a rapid removal of non-cost barriers
that hinder a rapid take-off of RES-E appear indispensable for achieving 2020 deployment
plans and for meeting overall binding RES targets.
Investor security is crucial; CPs should address country- and project-specific risks with a view
to reducing these.
CPs should improve the stability of support schemes, and related to this improve the
understanding of cost efficiency of different RES-E technologies
CPs should anticipate and prepare for the introduction of more market-based support
schemes, such as Feed-in Premiums and tendering, in order to lower the impact on end-user
electricity prices. As pointed out in various EU guidance on public intervention and on design
of support schemes, more market-based support schemes will essentially allow for increased
competition in the electricity market and for lowering the support expenditure burden on
end-user consumer prices.
RES-H&C recommendations
•
CPs should speed up efforts to establish appropriate instruments to promote RES-H. A
combination of tailored financial incentives and campaigns to increase public awareness
may consequently serve well to increase demand for renewable sources in heating and
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•
•
cooling which, in turn, would significantly contribute towards overall RES target
achievement.
CPs should diversify their options for RES-H. CPs could learn from best practice examples in
neighbouring CPs, for example the solar thermal pilot project carried out in Albania. This is a
project which could be replicated in other CPs.
The energy demand is lower than projected in most CPs, however mainly caused by lower
economic growth and too high demand projections, but not caused by structural
improvements to the inefficient use of energy. This however poses additional opportunities
to meet the 2020 RES targets in particular for those CPs that are not on trajectory to meet
the targets. All the same, CPs should improve and/or strengthen the energy efficiency
requirements of RES-H technologies.
RES-T recommendations
•
•
•
•
•
•
Establishing a legislative framework, covering all aspects of the RES Directive related to
biofuels. This could be achieved through amendments to the existing RES and/or biofuelsspecific laws, or through a dedicated piece of secondary legislation.
For each CP a detailed feasibility study looking at the domestic biofuel potentials and the
economics of converting them to biofuels would be highly recommendable. This could be
accompanied by a cost benefit analysis taking into account all socio-economic and
environmental aspects.
Policy support measures shall enable the right framework so that the investments in biofuel
technologies become attractive and the existing biodiesel and bioethanol plants in the CPs
produce biofuels for transport sector.
The most relevant policy support measures in Europe are tax exemptions, blending
obligations and/or the combination of the two. For the CPs it is advisable to consider a
combination until the sector matures and after that move to obligations to decrease the
revenue losses due to tax exemption schemes.
The blending requirements need to be enforced, for instance through imposing sanctions on
suppliers who fail to adhere to their obligations.
A close monitoring of the sustainability impacts of biofuel production is necessary to avoid
any possible negative impacts to biodiversity, water, sold and air in the future. Additionally
socio-economic impacts shall be monitored when and if biofuel industry grows in the CPs.
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1 Introduction
1.1 Background
In 2012, the Ministerial Council of the Energy Community adopted Decision 2012/04/MC-EnC on the
implementation of the Renewable Energy Directive 2009/28/EC and amending Article 20. Article 20
of the Treaty includes an obligation for the Contracting Parties to implement the Renewable Energy
Directive.
The Contracting Parties agreed to binding renewable energy targets by 2020 modelled on the same
methodology as for the European Union Member States (EU MS). Following the Ministerial Council
Decision, the Contracting Parties were obliged to submit their NREAPs to the Energy Community
Secretariat (ECS) by 30 June 2013. It was a prerequisite that their plans were to be prepared in
accordance with a template published by the European Commission. All in all, the plans map down
each Contracting Party's expected steps to reach the legally binding renewable energy target by
2020.
In the NREAPs, the Contracting Parties are to lay down the sector targets, including the technology
mix they expect to use. They also must determine the trajectory they intend to follow in the years to
come. The plans are to comprise detailed descriptions on the measures and reforms the Parties
intend to undertake to overcome the barriers in developing renewable energy.
Ministerial Council Decision 2012/04/MC-EnC also requires the Contracting Parties to report to the
Secretariat on the progress in the promotion and use of the energy from renewable sources for the
first time by 31 December 2014 and every two years afterwards. These reports shall detail the points
of Article 22 of Directive 2009/28/EC.
Against this background, the Energy Community Secretariat (ECS) has requested a study on the
extent (draft) NREAPs and national energy legislations in Energy Community Contracting Parties are
suited to enable an interim and 2020 RES target achievement, and where adjustments need to be
made. Further details are presented in the next section.
1.2 Study objectives, scope and output
This assignment aimed to give technical support to the Energy Community Secretariat in evaluating,
monitoring and reporting. The main output of this assignment is an assessment of to what extent
(draft) NREAPs and national energy legislations in Energy Community Contracting Parties are suited
to enable an interim and 2020 RES target achievement, and where adjustments need to me made.
Adjustment may include the choices of the technologies, the policy settings or administrative and
institutional conditions. More specifically the assignment includes:
•
•
•
Assess the consistency, relevance, effectiveness and viability of national policy measures in
the Energy Community Contracting Parties, i.e. NREAPs and transposition of national
legislation, to meet the provisions of the RES Directive.
Undertake a detailed assessment of progress in renewable energy at CP and at aggregated
level, at present (2011-2013) and in future (by 2020).
Provide recommendations, where necessary, on measures and actions to be taken to
improve the national legal and regulatory framework.
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•
Analyse the biofuels and bio-liquids consumed in the Contracting Parties, with respect to
quantities, types and origin, with respect to progress on availability made from various
sources and sustainability criteria, and with respect to their impacts.
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2 Assessment of Contracting Party NREAPs
2.1 General Chapter Introduction
The consortium has conducted an assessment of the conformity of national policy measures with the
provisions of the NREAPs and of the RES Directive as adapted by the Ministerial Council decision
2012/04/MC-EnC, covering four aspects:
•
•
•
•
Consistency of the national legislative measures with the provisions of the NREAP and the
forecast documents;
Effectiveness of the national legislative measures implementing the RES Directive in terms of
delivering the results (e.g. the indicative trajectory) provided by the NREAP.
Relevance of the national legislative measures with reference to the objectives and
provisions of the RES Directive;
Viability of the national legislative measures in terms of reaching the 2020 mandatory
national renewable energy targets, also from the perspective of the NREAPs provisions.
These four aspects are covered in more detail in the following sections.
2.2 Consistency of the national legislative measures with the NREAPs
2.2.1 Introduction
Concerning the consistency of national legislative measures with NREAPs, the following question is
addressed: Are the national legislative measures in line with the provisions of the NREAPs and
forecast documents?
In order to answer this question we have cross-checked the commitments which have been made by
the CPs in their NREAPs with respect to policies and measures they planned to adopt in order to
support the deployment of RES with national legislative measures. We have also compared the
policies and measures the MS reported in the NREAP and in the progress report to identify measure
by measure if the planned measures have been adopted or if existing measures planned to be
revised have been revised. The assessment is based on the list of measures reported as well as an
expert judgement of recent progress in the CP. The expert judgement is based on literature review
and interviews with key stakeholders in each of the CPs.
In conducting this assessment, we have taken into account the most recent & ongoing efforts in the
CPs, such as a new Energy Law adopted in Serbia and to be adopted in Montenegro soon and the
RES energy law under revision in Albania, draft RES Law in Moldova, renewable energy laws and bylaws in entities of Bosnia and Herzegovina.
The qualitative assessment is presented separately for RES-E, RES-H&C and RES-T policies and
measures, while in each of these sectors several different subcategories are also separately assessed
in correspondence to the categorisations provided in the RES Directive and the NREAP template.
Detailed results per country are presented in the CP-specific reports presented in Annex I. In this
section 2.2 of the main report a basic outline of the key findings is presented, starting with a general
overall assessment (2.2.2), followed by a presentation of the findings for each particular sector and
subcategory (2.2.3, 2.2.4 and 2.2.5).
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Before entering into details, as a starting point we present a brief update on the most important
legal measures so far taken in 2015, so as to give an idea of the current pace of legislative and
regulatory progress in the CPs of the Energy Community:
Albania: On 11 February 2015, DCM no. 125 “Enacting the methodology for the fixed tariff for
electricity purchased by small hydro power producers for the year 2015” was adopted. On 12
February 2015, Law No.6/2015 introduced some amendments to Law no. 10081, of 23 February
2009, “On licenses, authorisations and permits in the Republic of Albania”. On 30 April 2015 the new
power sector law was finally adopted.
Bosnia and Herzegovina: There was no regulatory activity finalised in 2015 although several
regulations were issued after the adoption of the RES Law (FBiH) in 2014 and REAP (RS) in 2014 such
as: a) in FBiH three rulebooks: on promotion of RES production and effective cogeneration, on
acquiring of the status of qualified producer of electricity and on compulsory participation and
undertaking of electricity produced from RES as well as the Decision on guaranteed purchase prices
for RES plants and b) in RS: the Rulebook on amendments and supplementing of the Rulebook on
support of production of electricity from RES and in effective cogeneration, and the Decision on the
amount of guaranteed FIT and Premiums as of 30 July 2014.
Kosovo*: Although in 2015 no remarkable legal acts in the RES sector could be identified, there was
a lot of activity at the end of 2014: On 23 December 2014, the Rule on support of generation of
electricity from RES was adopted and on the same day ERO adopted Decision V_673_2014 on
determination of FIT for generation of electricity from RES. On 11 November 2014, the Rule on
Authorisation Procedure for Construction of New Generating Capacities was adopted, replacing the
corresponding rule of 29 August 2011 for the purpose of simplification of procedures.
FYR of Macedonia: As this was the case also in the previous years, in 2015 further amendments to
the Energy law were introduced by the Law on changes of the Energy Law issued on 5 March 2015.
Also, amendments to the Law on Construction were introduced in March 2015 towards
simplification of administrative procedures. For the same purpose, a new Law on spatial and urban
planning was issued on 30 December 2014. A new transmission grid code has also been approved at
the end of 2014, aiming to simplify and shorten the procedures for connection of electricity
producers to the grid.
Moldova: While Moldova demonstrated significant legislative activity in 2014, respective progress
could not be verified for 2015 so far.
Montenegro: Although in 2015 no remarkable legal acts in the RES sector could be identified, there
was a lot of activity at the end of 2014 such the adoption of the Energy Efficiency law and submitting
of the new Energy Law to the Parliament for voting. Some amendments to the Energy Law were
passed in the Parliament in February 2015. However, the main amendments are expected with the
new Energy Law.
Serbia: Several regulations were passed in 2015, such as the Rulebook on energy permits (OJ RS no.
15/2015); the Rulebook on opening available capacities increased for the value of the installed
power of the facilities for which the temporary status of privileged producers has been expired (OJ
RS no. 24/2015); and two Rulebooks regulating the training of energy managers and certified energy
consultants (OJ RS no. 12/2015).
Ukraine: Several legal acts were adopted in 2015, such as Law No. 222-VIII on Licensing of Types of
Business Activity, of 2 March 2015, which shall become effective on 28 June 2015; Law No. 284-VIII
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Assessment of Renewable Energy Action Plan Implementation and Progress in the Promotion
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on Amending the Law on Electric Power Industry, in effect since 26 April 2015; resolutions of the
NERC that establish/amend tariffs (including FIT), orders of the Government on emergency measures
at the electricity market as well as plans on implementation of EU legislation.
2.2.2 Overall assessment
Examination of consistency of current national legislative measures with the national measures
listed as “existing” or “planned” in the NREAPs submitted by the CPs was formally possible only with
respect to 5 CPs (Kosovo*, Moldova, Montenegro, Serbia and Ukraine). For Bosnia and Herzegovina,
REAPs have been prepared at entity level (FBiH and RS) but no NREAP at the national level. Despite
some minor discrepancies and occasional problems in translation, most of the NREAPs which were
officially submitted were in general quite comprehensive and most of the questions have been
replied. This has not been the case only for Ukraine, which submitted a very short and incomplete
NREAP failing to provide information and answers regarding the existing measures and provide
remarks on the planned measures in the Implementation act of the NREAP, as well as for one of the
BiH entities, FBiH, whose REAP was insufficient, not only because no version in English translation
was submitted, but also with regard to the quality of the replies given, which mostly consisted in
simple references to relevant legal acts without providing any clarifying explanations within the text
of the REAP. There is no English version of the REAP adopted also by the other BiH entity, RS. All CPs,
with the exception of Bosnia and Herzegovina, have adopted Progress Reports. Table 1 below
provides an overview of the CPs that have adopted NREAPs and/or Progress Reports.
Table 1: Adoption of NREAPs and Progress Reports in Contracting Parties
Contracting Party
Albania
Bosnia and Herzegovina
Kosovo*
FYR of Macedonia
Moldova
Montenegro
Serbia
Ukraine
Adopted NREAP
✘
✘
(√ at entity level for FBiH and RS)
√
✘
√
√
√
√
Adopted Progress Report
√
✘
√
√
√
√
√
√
Some general remarks which apply more or less to all CPs are as follows: Firstly, a positive finding
was that the validity of measures listed in the NREAP as “existing” was to a great extent confirmed,
some discrepancies mainly being attributed to problems of translation. Further, as regards the
measures listed as “planned” in the NREAPs, it was observed that CPs in general have focused their
legislative and regulatory practise on realising the planned measures, these being proved to a large
extent to constitute not mere promises but realistic plans. However, in the vast majority significant
delays are observed in meeting the timetables provided in the NREAPs for adoption of the measures.
In most cases the main legislative and regulatory measures announced in the NREAPs are currently
still in draft form. On the other hand, there have been also cases where CPs have made some
significant progress in the time following the submission of the NREAPs, having adopted a series of
measures within a relatively short time period. In a few cases, measures have been adopted which
were not even mentioned in the NREAPs as planned.
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Undoubtedly the most significant progress in adopting legislative measures in compliance with the
RES Directive has been made by most CPs in the RES-E sector. Not insignificant, but also not always
sufficient, efforts have been made in some cases in the RES-H&C sector, while the RES-T sector
seems to have been left behind in all CPs, although this could be changed soon in some of the CPs, in
which relevant legal acts already exist in draft form.
Before presenting the detailed key findings on the progress of the national legislations for each
particular subcategory (in the next section as well as in the Annex I), an introductory general
summary for each CP would be useful to outline demonstratively the level of consistency of each CP
in relation to the measures listed in the NREAPs (an introductory summary is also provided for the
three CPs which have not yet adopted NREAPs):
In Albania the RES law was adopted in May 2013, but until now it has still not been implemented.
The reason for this was the need for harmonisation with the new Power Sector Law which was
finally adopted on 30 April 2015. It should be expected that adoption of this latter law would also
lead to amendment of the RES law, since this law does not fully transpose the RES Directive in
national legislation, among others, because other technologies other than hydro are not properly
taken into consideration, which is also the case for the RES-H&C sector. For the latter sector a draft
law on energy efficiency, initially drafted in 2011, is still in preparation so as to transpose recent
acquis in that field. As regards the RES-T sector the law on biofuels of 2008, introduced some
measures required under the RES Directive but was also never implemented and it is about to be
revised with a view to transpose the requirements of Directive 2009/28/EC with regard to
sustainability criteria and to introduce more adequate incentive measures
In Bosnia and Herzegovina (hereafter BiH) RES is not regulated on the level of BiH but on the levels
of the two entities. The two BiH entities are Federation of Bosnia and Herzegovina (FBiH) and
Republika Srpska (RS). In principle, the prime focus in this report is on the State level BiH, however,
in order to provide a complete and accurate picture of the legal systems in place in BiH as a whole,
where appropriate we include a presentation/assessment at entity levels. When referring to the
state level, the abbreviation BiH is used, and when referring to entity levels, the abbreviations BiH
entity (FBiH) and BiH entity (RS) are used. The issues of transmission grid and the TSO are regulated
by the State Regulatory Commission at BiH level and they are presented in the Annex of BiH. At
entity level, in FBiH a significant part of RES legislation was introduced in 2013 and some important
NREAP planned measures were implemented in 2014: by-laws for implementation or improvement
or regulation were enacted (particularly NRA regulations on acquiring the status of qualified
producer, on compulsory participation and undertaking of electricity producer form RES); an
independent authority for RES support scheme and purchase of electricity from RES i.e. the RES
Operator was established and became operational. There was no recent regulatory activity in the
RES-H&C sector as well as in RES transport although the REAP planned measures for 2015 include
regulation of support to RES-H&C, cogeneration and compulsory blending of biofuels. In the BiH
entity (RS) also the major RES regulations currently in force were enacted in. In 2014 mostly by-laws
were amended or issued (such as an important improvement of the Rulebook on support of RES).
There was significant legislative activity planned in the REAP for RES-H&C and RES-T (including two
rulebooks regarding biofuels in 2014, information and educational campaigns) which were not
implemented.
In FYR of Macedonia, although not specifically announced in the draft NREAP, continuous
amendments have been made in the last years to the existing Energy Law, the Law on Construction
and relevant by-laws, and a new Law on Spatial and Urban Planning was issued, for the purpose of
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accelerating progress, particularly with regard to simplification of administrative procedures. Also a
draft new Law on Energy has been prepared aiming to transpose the provisions of the RES Directive.
Further, in consistency with the respective plans in the draft NREAP, both network codes have been
revised so as to facilitate RES integration to the networks. As regards RES-H&C a set of legal acts
from the field of energy performance of buildings were adopted, including provisions applicable to
the use of RES in buildings. The establishment of the Energy Efficiency Fund that could finance also
renewable energy projects, contrary to what is planned in the draft NREAP, is still pending. In the
RES-T sector, although the draft NREAP lists no planned measures for introduction of sustainability
criteria, a draft law on biofuels has been drafted and should be adopted in the second half of 2015.
In Kosovo* amendments to the Law on Electricity, although planned for 2014 according to the
NREAP, have not been passed yet. However, consistent with relevant plans included in the NREAP, a
set of regulatory acts were issued in 2013 and 2014 for the RES-E sector expanding the scope of the
support scheme as well as simplifying the administrative procedures. Despite planned measures for
2013 and 2014, no substantive progress has been made so far in the RES-H&C sector but a set of
legislative and regulatory acts are currently in draft form. In the RES-T sector a draft law on
petroleum market and a draft regulatory act on biofuels are still in the process of adoption,
demonstrating thus a delay in relation to the timetables provided in the NREAP (2013 and 2014
respectively).
In Moldova a draft new RES law has been submitted to the Parliament and passed the first reading
in July 2014. Until this law is voted and implementing by-laws are issued thereafter, Moldova will
have not observed most of the measures included in the NREAP regarding promotion of RES-E,
despite planned implementation for 2013-2014. In relation to RES-H&C a heating law, including
provisions on the promotion of renewable energy used for heating, and a law on energy
performance of buildings were adopted in 2014, in consistency with the NREAP. Also as regards REST there was no practical progress until now, although in the NREAP this should have started being
the case by 2014; extensive provisions in this regard are included in the draft RES law but also
additional regulatory acts will be necessary to deliver the results planned in the NREAP.
Montenegro has recently implemented some legislative measures envisaged in the NREAP. In
December 2014 it passed the Law on Energy Efficiency while the Draft Law on Energy which should
replace the existing one and provide for harmonisation with the Third Energy Package is currently in
the parliamentary procedure. The NREAP provided for its adoption in 2015. The energy efficiency
sector and particularly the building sector were significantly developed during the last years. The
next steps are adjusting the respective by-laws to the new energy efficiency law. The NREAP
provides introduction of support measures for H&C and biofuels in 2015.
Serbia had extensive regulatory activity in 2014, not always in implementation of the NREAP. A onestop-shop was organised for the construction related procedures, which were the most burdening,
the new Energy Law was passed to be in compliance with EU directives while the law regulating
constructions issues was significantly improved. Measures for RES H&C were partly addressed by
passing of the energy efficiency law although not sufficiently as the regulation was transferred to
local self-government without deadlines or instructions for implementation. The transport measures
were not implemented at all (NREAP predicts passing of decree on sustainable criteria for biofuels in
2012, amendments for technical requirements for biofuels planned for 2013, fuel quality monitoring
2013).
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As regards Ukraine, given that this CP adopted its NREAP late in 2014 there was not much time for
implementation of measures. Concrete measures were not predicted in the NREAP but in its
implementation act, as a separate piece of regulation attached to the NREAP. The deadlines for
implementation start from July 2015 and on, thus Ukraine is still in consistency with the NREAP. RESE support schemes already exist and, apart from a FIT, include various tax exemptions and
incentives. Some of the tax incentives for both electricity and heating were recently abolished and
FIT amounts temporarily reduced. Blending obligation for biofuels was introduced earlier but never
implemented in practice. The measures planned in the NREAP implementation act are few and
deadlines are long. For example, introducing a technical regulation for RES and biofuels is planned
for the end of 2018, a regulation regarding RES connections to the grid for June 2016 and for RES in
buildings for the end of 2016. Considering a possible delay in passing of the measures, necessary bylaws, clarifications, implementation and effects of implementation it seems, that the time schedule
did not take into account the 2020 goals.
2.2.3 RES-E
Support schemes
BiH (in FBiH), FYR of Macedonia, Montenegro and Serbia have one support measure (FIT) and it is
operational. RS has a combination of two support measures (FIT and FIP) and both are operational.
In Albania financial support to RES power producers is provided through two schemes (FIT and tax
exemptions). Also Ukraine has introduced, apart from FIT, certain tax and customs exemptions for
RES (such as tax reductions and exemptions for profit tax, VAT, tax on trade with electricity, and
import duty exemptions for equipment and materials for RES). The system is operational although
there have been some temporary reductions of tariffs in 2014 and 2015. In Moldova, the support
scheme, which is currently in force, differs from the usually applicable support schemes: a generally
applicable tariff calculation methodology is in place, based on which producers calculate annually
their own tariffs and submit them to the energy regulator ANRE for approval. The draft new RES law
will introduce a new system of remuneration of RES generated electricity, based on auctions
organised by the Government.
In Albania a FIT is applied only for small hydro power plants (SHPP) with installed capacity up to 15
MW. In BiH (in FBiH) the measure applies to HPP up to 10 MW, PV up to 1 MW, wind, geothermal,
biomass, biogas, sea, waste and efficient cogeneration without limit, although the FIT is currently
not provided for geothermal, sea and waste. In BiH (in RS) the measure applies to HPP, wind,
geothermal and biomass up to 10 MW, PV and biogas up to 1 MW and effective cogeneration up to
10 MW. In FYR of Macedonia tariffs are currently in effect for small hydro, wind, solar PV, biomass,
and biogas. In Kosovo* a very recent decision has set out FIT also for PV, apart from previously
existing FIT for hydro, wind, biogas and biomass energy. Maximum allowed size of SHPP to benefit
from support schemes is set at 10MW. In Montenegro limits support for HPP, biomass, biogas, solid
waste, landfill gas and cogeneration plants to 10 MW, while for PV to 1 MW. In Serbia the capacity
limit for acquiring the status to qualify for FIT for HPP is 30 MW, for effective cogeneration 10 MW
while for biomass, biogas, waste, geothermal and PV there is no limitation per plant, however the
quota for solar PV until 2020 is 10 MW which indirectly limits the capacity of individual plants. There
is a limit for wind of 500 MW to 2020. Ukraine limits support to HPP up to 10 MW, but for other
technologies there is no capacity limit introduced and no quotas of grid connection.
In BiH (FBiH), Montenegro and Serbia the duration of the measure is for 12 years while in Albania
for 15 years. In BiH entity (RS) the duration is also for 15 years, after that it is possible to conclude
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an agreement for compulsory purchase of all produced electricity for the reference price. In FYR of
Macedonia the duration is 20 years for hydro and wind, and 15 years for solar PV, biomass and
biogas. Kosovo* offers longer duration of support for PV (12 years) instead of 10 years for the other
technologies. In Moldova, in the new auction system, the successful bidder will obtain the status of
eligible producer, entitling it to sell the whole volume of electricity produced at the price obtained
through the tender for a period of 15 years. In Ukraine there is no legal provision on the duration of
the agreement while in practice the MO Energorinok concludes first an annual agreement which is
after that renewed on a yearly or a six-month basis with a fixed FIT provided in the law
corresponding to the year in which the plant becomes operational. The law provides descending FITs
up to year 2030. There is a general obligation of Energorinok to purchase all electricity from RES
plants up to the year 2030 at the FIT of the year the plant started its operations.
Power Purchase Agreement (PPA)
In Albania a template PPA has been approved by the regulator (ERE) containing the minimum terms
provided in the RES law. Also in FYR of Macedonia contracts are based on a template PPA which has
been approved by the regulator (ERC).
In BiH, in FBiH there are two model agreements: a) preliminary PPA and b) PPA; in the preliminary
PPA an operator does not clearly assume an obligation to conclude the PPA, if all conditions are met,
although such obligation would be necessary for the security of financing. The preliminary PPA
guarantees the FIT effective at the time of its conclusion. In BiH, in RS there are three model
agreements: preliminary PPA, PPA for FIT and agreement for FIP. There is an obligation of the RES
operators to conclude the agreement on support. The model agreements in both entities should be
improved to provide necessary security fort the investors.
In Kosovo* recent amendments made it possible for investors to sign the PPA at the moment of
reception of Preliminary Authorisation, the applicable FIT being thus guaranteed. Aim of the
amendments was to provide a higher regulatory security enabling potential investors to ensure the
necessary funding sources for the construction of new RES projects. A sample PPA is not yet
available.
In Montenegro there is a model Agreement on Defining the Conditions for Conclusion of a PPA,
which provides the obligation that after finalisation of the construction and obtaining of the
operation license the PPA will be concluded. The TSO is obliged to conclude the PPA if all conditions
are fulfilled. The sample PPA is an integral part of the Agreement on Defining the Conditions for
Conclusion of a PPA and may be amended only upon written consent of the parties.
In Moldova the energy regulator (ANRE) is designated as the competent authority to develop
mandatory clauses for the PPA for electricity. A template PPA is not in place yet.
In Serbia, according to the newly passed energy law, there will be only one PPA and it will be
concluded before beginning of construction (the model agreement harmonised with the new energy
law is not yet prepared).
In Ukraine there is only a PPA, no preliminary agreements. The PPA is concluded after finalisation of
construction and obtaining of all licenses. The only legal obligation of the Market Operator is to
purchase all electricity from RES.
In BiH (FBiH, RS) the investor, when concluding the preliminary PPA, should pay deposit or submit a
guarantee in the amount of 1% and 2 %, respectively, of the amount to be invested. The guarantee
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paid on a deposit account is refunded after beginning of operations. In Montenegro and Ukraine no
guarantee is paid by the investor. In Serbia there are currently models of one preliminary PPA and
several types of PPAs depending on the capacity. A guarantee is paid for obtaining the energy
permit. It remains to be seen if there will be some changes when a new model PPA is provided.
In BiH (FBiH, RS), Montenegro and Ukraine there are no guarantees for payment of obligations from
the PPAs. The new Law on Energy in Serbia provides for the obligation that an instrument for
securing payments of the RES off taker is agreed in the PPA. This has already been regulated in the
currently applicable PPAs models drafted in accordance with the previous law.
Some CPs BiH (RS), Montenegro, Ukraine and Serbia provide (or will provide, in case of Serbia) in
PPAs that in case of delay in payment of support measures the defaulting party should pay the legal
interest. In BiH entity (FBiH), the PPA does not contain such a provision.
In regard to balancing costs, in Albania the wholesale public supplier is the one to assume any
balancing costs. In BiH (FBiH) payment of balancing is not regulated in the agreement. The law
provides that RES producers with a capacity below 50 kW do not pay balancing and above 50 kW
pay, although at the moment no RES producers pay for balancing costs. In BiH (RS) beneficiaries of
the FIT support schemes pay 25% of the balancing costs while beneficiaries of the FIP pay 100% of
the balancing costs. In FYR of Macedonia preferential RES producers are not charged for their
imbalance. A balancing group created by the market operator takes balance responsibility for all
preferential producers. Starting 2015, large preferential producers (with capacities above 10 MW)
are obliged to take balance responsibility. In Montenegro and Serbia RES producers do not pay
balancing costs while Ukraine fails to regulate this issue in the PPA.
Compulsory jurisdiction of domestic courts is provided in BiH (FBiH and RS), Montenegro and
Ukraine. Montenegro provides the possibility to resolve dispute in arbitration, while if it is not
agreed, the local courts will have jurisdiction. In Serbia, the current PPA model for the installed
capacity of up to 50 MW provides for arbitration before the Serbian Chamber of Commerce or the
International Chamber of Commerce (ICC). The place of arbitration would be chosen by the party
which initiates the procedure. The PPA model for the installed capacity of above 50 MW provides for
the Serbian court resolution of disputes with the possibility that the parties agree on arbitration.
However, ICC arbitration may be agreed only if the majority shareholder of the investor is a foreign
legal entity, otherwise only arbitration before the Serbian Chamber of Commerce may be agreed.
Streamlined administrative procedures
BiH (FBiH) has very complex procedures including numerous authorities on the level of FBiH, cantons
and municipalities, no training for employees, with frequent issues of unclear competence of
authorities and generally long and not well coordinated procedures. In BiH (RS) the procedures are
not so complex but may take long in cases that concession is required. In Moldova several
authorities are involved, each permit/license is regulated by a separate law and there is no outline of
allocation of responsibilities among the various authorities. Also in Kosovo* several authorities are
involved in the licensing and authorisation procedures. Montenegro and Serbia have reduced the
number of procedures and have clear distinctions between authorities. In Montenegro particularly
there is an issue of understaffing in some authorities.
BiH (FBiH) had significant regulatory activity regarding RES in 2013 and 2014 when the RES and
electricity laws were introduced, a RES Operator established and several by-laws passed. BiH (RS)
plans to introduce a separate entity for supporting of RES (Support System Operator) but it has not
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been established yet and RAE fulfils its role until the establishment. In Kosovo* an act was adopted
recently to improve procedures for the authorisation of new RES plants. Also, in FYR of Macedonia,
in the past two years, amendments have significantly shortened deadlines and simplified
procedures, while further simplification is expected. In Moldova the draft new RES law assigns EEA
to propose improvement of procedures.
In Albania a one-stop shop was created for all licenses and permits required for a project, though
some specific licenses and permits are not integrated in the one-stop shop. In BiH (FBiH and RS),
Montenegro, Moldova a one-stop shop does not exist and none is planned. In Serbia there was a
significant simplification of procedures in 2014 through introduction of one-stop-shop for the
procedures of acquiring of the construction permits, which was the longest and most complicated in
the energy licensing procedures. As this is a new measure the results are still to be seen.
Montenegro performed a similar reform in the period 2008-2011 when the procedures for the
construction related permits were reduced to two.
In BiH (FBiH), Kosovo* and FYR of Macedonia simplified procedures are provided for smaller
projects, while in Albania, BiH entity (RS), Moldova, Montenegro and Serbia not.
Information & assistance to applicants
BiH (FBiH and RS) and Serbia have well informed web pages that contain most of the relevant
legislation but mostly only in local languages. In Albania, Kosovo* and FYR of Macedonia support to
applicants is provided by several authorities, also through the web pages, but no clear legal
information obligation is laid down to a certain body. In Moldova the Energy Efficiency Authority is
assigned with the competency of operating as a single information center responsible to assist,
consult and inform investors and consumers. In Montenegro there are significant differences in the
level of information provided on web pages of different authorities and almost all RES related
information is provided only in local language. In BiH, Serbia, Montenegro and Ukraine legislation
imposes mostly general information obligations but also addresses such obligations to some specific
authorities.
BiH (FBiH and RS), Kosovo*, Montenegro and Ukraine do not have guidelines for investors and/or
collected RES relevant information on one place. Serbia has guidelines for investors updated in 2013
and FYR of Macedonia has recently prepared such.
Except for Moldova, no other CP has an information centre to provide comprehensive information
on the whole procedure, although the energy regulators in general, even if not designated as “single
information center”, normally provide more general information.
Transparent & cost-related administrative charges
While in Albania and Moldova transparency is mainly ensured through the fact that the charges are
officially published, in Kosovo* and FYR of Macedonia charges are explicitly correlated to the
administration costs through the legal acts imposing these charges. In BiH (FBiH and RS) charges are
transparent but information is not collected in one place, extensive research is needed in order to
collect information. Charges are often calculated depending on the capacity and not cost-related. In
Montenegro RES producers are so far exempted from paying any administrative charges for issuing
energy permits. Administrative charges are paid for issuing the energy operation license. Charges are
often calculated based on the capacity of the plant. In Ukraine they are not sufficiently transparent.
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BiH, Serbia, Montenegro and Ukraine are generally logical and within a range that one would
assume for cost-related charges.
Electricity infrastructure development
In Albania concrete obligations are laid down to the network operators to take into consideration
RES integration when planning network development. BiH prepares and executes development
plans for the transmission grid and the entities in BiH (FBiH and RS) for the distribution grids. A tenyear transmission grid development plan is prepared by the TSO and approved by the State regulator
NRA. It does not have specific provisions on RES. In BiH (FBiH and RS) DSOs prepare development
plans which should include RES integration and which are approved by FBiH / RS RA. In Kosovo*
detailed rules on network development are in place, taking into consideration integration of RES in
the network. In FYR of Macedonia the grid infrastructure authorisation procedures and the rules
governing connections are published in the network codes, but no clear rules are in place ensuring
that the relevant operators take due consideration of RES integration when planning network
development; on the other hand a detailed study on RES integration strategy has been made. In
Moldova, apart from general rules obliging operators to take into consideration future electricity
production and demand, no concrete rules exist on planning integration of new capacities of RES. In
Montenegro ten-year transmission and distribution system development plans are approved by NRA
and should be in accordance with the Energy Development Strategy, which among others promotes
RES development. In Serbia the energy strategy should include the strategy for development of the
grids and the strategy for development of RES but there is no formal requirement for the ten-year
development plans to be in accordance with the Strategy. In Ukraine the DSO prepares and NRA
approves annual plans which should be in accordance with local area development plans while the
TSO prepares ten-year development plans to be approved by the Cabinet of Ministers.
In Albania the promotion of use of smart grids and storage facilities is addressed in the RES law. In
FYR of Macedonia, Kosovo* and Moldova, no measures for smart grids and storage facilities are in
place or planned. In Montenegro there are no measures for smart grids and storage facilities in
place but the measures for smart grids are planned in the NREAP and the Energy Development
Strategy up to 2030. In Ukraine the existing regulation envisages the development of transmission
and distribution grid infrastructure and intelligent networks.
Objective rules on connection requirements (incl. costs) made public
In Albania the connection procedures are stipulated by the network codes, but a specific regulation
regarding the connection of RES producers, although required by law, has not been adopted yet. In
BiH (state legislation and in FBiH and RS) the rules and the methodologies for calculation are made
public by the TSO and the DSOs, but mostly not in English; there is no guidance for investors with
costs and timetables. In BiH entity (RS) these rules are regulated in numerous overlapping legal acts
which may be contradictory in some parts and are difficult for handling. In Kosovo* there are rules
on objective and non-discriminatory connection of electricity producers in general to the grid and
networks. In FYR of Macedonia, connection of RES producers to the transmission grid and
distribution network has been facilitated in the recent years, because connection rules have been
simplified through amendments to both network codes. In Moldova, the electricity law assigns the
regulator to set up conditions for grid connection in an objective and transparent way; technical
norms have been issued in this respect only by the TSO. In Montenegro most of the information on
web pages is in the local language only, while some regulations are missing. In Serbia and Ukraine
the TSO pages contain sufficient information in English as well, but not the ones of the DSO.
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In BiH (State legislation), BiH (RS), Montenegro, Serbia and Ukraine RES producers do not have
priority connection to the grid, contrary to Albania, Kosovo*, FYR of Macedonia and BiH entity
(FBiH) in which priority connection is provided for RES producers, while for Moldova such provision
is included in the draft RES law.
In Albania connection costs are borne by the producer, while some concrete exceptions are
provided in which case the connection costs are borne by the grid operator or through private
investments. BiH (state legislation and in FBiH and RS), Kosovo* and Ukraine have provisions on
connection cost bearing and sharing. In BiH RES producers are exempted from paying part of the
connection costs to the transmission grid (they pay 50% of the fixed, not cost-related, part). In FYR
of Macedonia, producers are responsible for all connection and technical adaptation costs, but the
regulator is entitled to oblige the competent operator to cover the grid connection costs when
needed to provide incentives to promote RES or to reach the relevant targets. As regards cost
sharing between subsequently connected producers, clear rules exist regarding connection to the
distribution network, this not being the case for connections to the transmission grid. In Moldova,
there is no legal obligation for publication of general rules on cost sharing and bearing; obligation is
laid down only for individual offering of grid connection conditions. In practice construction of
connection points to the grid is fully paid by the producers, while TSOs and DSOs fully assume the
costs for general grid development, these costs being covered through the transmission and
distribution tariffs. In Montenegro all connection costs are paid by the users without exceptions for
RES while in Ukraine 50% of the connection construction costs are paid by the investors and 50% by
funds financed from the tariffs for electricity transmission and distribution. Serbia has no sharing
provisions.
In BiH (FBiH and RS) and Serbia, the new applicants are comprehensively informed by the TSO and
the DSO on connection cost estimates and timetables upon application and receiving the preliminary
approval from the System Operator. In BiH (RS) the complete information is in the connection
agreement. In Kosovo* and FYR of Macedonia RES producers are legally entitled to receive the
necessary information on grid connection requirements, timetables and costs. In Moldova, a related
provision is included in the draft new RES law. So far in practice grid connection costs are
determined on a case-by-case basis. Same is the practice in Albania, although the RES law lays down
extensive information obligations to operators. In Montenegro costs for small production units up to
10 MW are provided in the Distribution Grid Code while for the plants exceeding this capacity the
conditions are determined after analyses and calculations. In Ukraine the development and
adaptation of the grid for RES connection is mainly decided on a case-by-case basis. This issue should
be addressed in the development plan and grid codes that are not issued yet.
Guaranteed and/or priority access to the grid
In Albania the applicable legislation provides guaranteed transmission and distribution and priority
dispatch of RES generated electricity. Also, the new power sector law provides for priority and
guaranteed access of RES producers to the electricity networks. In BiH (transmission grid) and in
Ukraine there are no provisions on priority access to the grid or guaranteed transmission and
distribution. BiH (FBiH and RS), Montenegro, and Serbia provide priority access to the grid. In
Kosovo* transmission and distribution of RES generated electricity is also guaranteed and priority
dispatch is in place as well. In FYR of Macedonia transmission and distribution of electricity
generated by RES producers is guaranteed. Also guaranteed is purchase of produced electricity by
the Market Operator. In Moldova, provisions on non-discriminatory access to the grid, priority
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dispatch of RES generated electricity, guaranteed purchase for eligible producers (selected through
auctioning) and minimisation of curtailment are included in the draft new RES law.
Non-discriminatory transmission and distribution tariffs
In Albania, transmission and distribution tariffs are correlated in the legislation with the cost
incurred by the operators for the purpose of integration of RES to the network. BiH (FBiH and RS),
Montenegro and Serbia, have transparent provisions necessary for securing that there is no
discrimination of RES producers. In Kosovo* there are rules both in legislation as well as in
implementing regulations that transmission and distribution charges for RES producers are designed
in a non-discriminatory manner. In FYR of Macedonia RES producers are not subject to network
charges; these are paid by consumers. In Moldova, provisions on non-discrimination of RES through
the tariffs charged for transmission and distribution of RES generated electricity are included in the
draft new RES law. Montenegro recently introduced transmission charges. In Ukraine there is no
transparency of calculation of tariffs but no legal discrimination among RES producers and between
RES or other electricity producers either.
Information and training on RES support measures, benefits and use
In Albania the RES law lays down concrete information obligations. However, so far the organisation
of provision of information and training on RES support measures, benefits and use has not been
developed so much in practice. At the time, there is not sufficient information provided to the public
covering all RES technologies. There is also no official guidance available to local administrative
bodies.
BiH (FBiH and RS) has not developed specific promotion activity except for well organised web pages
of all the authorities, but in local language. There is no guidance or sufficient information for
different stakeholders, no trainings and awareness raising campaigns. In Kosovo* a regulatory act of
2013 addresses issues relating to information on types of RES to be used, support schemes available,
certification requirements for installers of RES etc. No official guidance is currently provided to local
and regional administrative bodies involved in the licensing procedures, apart from some meetings
which are occasionally held with the local administrative officials in this regard. In FYR of Macedonia
awareness raising campaigns and/or other measures are adopted to inform relevant actors on RES
support measures, on the benefits, costs and the optimal use of RES technologies that are promoted
with support schemes. There is no official guidance for local and regional administrative bodies and
no trainings are planned for authorities in charge of authorisation procedures. In Moldova
comprehensive information obligations towards investors, consumers etc. are imposed by the draft
new RES law. Awareness raising campaigns and/or other measures adopted to inform relevant
actors on RES support measures, on the benefits, costs and the optimal use of RES technologies are
organised mainly in the course of certain projects.
Montenegro lacks RES awareness raising measures except as part of energy efficiency awareness
raising, which is well developed. Serbia has developed guidelines for investors while for other
stakeholders there are no specific instructions, only regulatory acts presented on the respective web
pages, mostly in the local language, not in English. There are no trainings and awareness raising
campaigns. Ukraine has a well-informed web page of the SAEE on RES support measures, benefits
and use, guidelines on FIT, biomass and biogas projects, information on technologies and
equipment, list of producers, international investment business forums, exhibitions, but mostly in
the local language.
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Guarantees of origin
In Albania the necessary legislative framework for GoO has been established by the RES law, but
implementing regulation is pending. In BiH (FBiH and RS), Serbia and Ukraine GoO are regulated but
still not functioning in practice. In FYR of Macedonia and Kosovo* both the legislative framework as
well as the necessary regulatory acts are available, but there is no practical implementation, i.e.
there is no market of GoO. In Moldova, a regulatory act of 2009 regulates GoO; the new draft RES
law includes a detailed regulation transposing the RES Directive, so that after its adoption, an
amendment of the existing regulatory act will be necessary. In Montenegro the first GoO was
reported to have been issued recently. In Ukraine the authority in charge for issuing GoO (SAEE) is
not sufficiently equipped so it is discussed that issuing of GoO would be transferred to the TSO.
There are significant differences regarding the issuance of GoO and receiving of financial or other
support: in Albania GoO are issued to each producer who has been granted a permission or
authorisation to build a RES power plant. In BiH (FBiH) GoO are issued only to qualified producers, in
BiH entity RS and FYR of Macedonia they are not issued for producers under a support scheme (FIT
or Premium). In Moldova GoO are issued to RES producers with plants having capacity equal or
above 10kW. In Montenegro they are issued to privileged producers while in Serbia and Ukraine
they may be issued to any RES producer regardless of the support scheme.
In Albania ERE is the authority both to issue and supervise GoO. In BiH (FBiH and RS) the RES
Operator or NRA issue the GoO while inspectors may control data and books of RES producers. In
BiH (FBiH and RS) and Ukraine there is no independent supervision (by an authority other than the
one who is issuing GoO) over issuing of the GoO. In Kosovo* the NRA (ERO) is the one to issue and
keep the electronic registry, while in FYR of Macedonia the Energy Agency is the authority in charge
for GoO. In Moldova, according to the draft RES law, GoO are issued by the network operator, while
supervision competences are not regulated. In Montenegro GoO are issued by RAE and supervised
by the Market Operator. In Serbia, the TSO issues GoO while NRA and the Ministry for energy
supervise (through inspectors as well) their issuing, transfer and cancellation.
Albania and Moldova recognise GoO issued by other CPs or EU member states without the
condition of reciprocity. BiH (FBiH and RS) Montenegro and Serbia recognise GoO issued by other
CPs only under the condition of reciprocity. In addition, in Serbia the GoO issued by other members
of the European Association for issuing of GoO will apply once Serbia becomes the member itself. In
Ukraine recognition is not regulated.
2.2.4 RES-H&C
Support schemes
In Albania and Montenegro there is no support scheme. However, in Albania a new draft law on
energy efficiency is currently under preparation, among others envisaging the establishment of an
Energy Efficiency Fund. Moreover, the RES law provides for the possibility of granting tax exemptions
(custom duties and VAT) to producers or installers of solar water heating systems, but such
measures could not be verified to have been adopted in practice. In BiH (FBiH and RS) there are also
no support schemes for RES-H&C, apart from a provision in the RES Law that the Government may
impose subventions and other benefits for production and supply of equipment, and impose
obligations to industrial and city heating plants on production heating quota from RES. In Kosovo*
an act generally provides for the possibility of providing FITs to RES thermal energy generating plants
connected to the thermal energy grid but the competent regulator has not set out any such FITs yet.
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In FYR of Macedonia subsidies have been granted and a reduced VAT is applied since 2007 for the
installation of solar thermal collectors in households. In Moldova no generally applicable support
scheme for RES-H&C exists; financing of RES-H&C is made on a project-basis through the support of
several funds and programmes.
Serbia did not introduce any support scheme so far and has regulated that such schemes would be
developed by the local governments. In Ukraine, some support schemes applicable to all RES have
been cancelled in 2015 (land tax reduction, profit tax exemptions for production of heat by biofuels).
Exemption from VAT and import duty for import of equipment for operations and production from
renewable sources (if such equipment is not produced in Ukraine) are still in place. There are no
specific schemes for RES-H&C.
In BiH (FBiH) the draft entity Law on Energy Efficiency and in Serbia the energy efficiency law
provide that the use of RES for production of electricity or heating is considered to be an energy
efficiency measure if used in the building in which it is partly or wholly produced. The BiH (FBiH)
draft entity law provides that if no other support measure is used for this production, an energy
efficiency measure may be used. In BiH (RS), the only support measure is that these producers are
exempted from the concession procedure. Serbia provides in the second national plan for energy
efficiency that credit lines for energy efficiency and RES usage in the building sector will be
established but this measure is not implemented yet.
Building sector
Albania applies a Law on Energy Efficiency of 2005 which has never been properly implemented. A
new Law on Energy Efficiency has been drafted in order to transpose energy efficiency Directives. In
BiH (FBiH) a draft entity Law on Energy Efficiency is in the parliamentary procedure while the
construction regulation is on cantonal level. Thus the use of RES in the building sector remains
unregulated for now. Kosovo* has drafted a separate law on energy performance of buildings which
is already in adoption procedure. In FYR of Macedonia, amendments were introduced in 2013 to the
Energy Law also regarding the chapter on energy efficiency. In the same year, several legal acts from
the field of energy performance of buildings were adopted, including provisions applicable to the use
of RES in buildings. In Moldova a new Law on Energy Performance of Buildings was adopted in July
2014. Technical norms for execution of this law which were planned for 2014 (according to the
NREAP) have not been adopted yet. Further, the draft new RES law requires from central as well as
local authorities to promote the use of RES in buildings and to introduce relevant changes in building
codes. Montenegro passed the new law on Energy Efficiency in December 2014 while the respective
by-laws should be passed in 2015. Ukraine also still does not have respective measures, which are
planned to be introduced by December 2016.
In Albania the RES law requires for regulatory measures to set minimum requirements, but still no
such measures are in place. Both BiH entities (FBiH and RS), Montenegro and Serbia did not
introduce obligations to use minimum levels of RES in new or reconstructed buildings so far. In
Montenegro the new energy efficiency law provides that the Ministry will issue the minimum
requirements for energy efficiency of new buildings but it is still not clear whether these
requirements will address the obligatory minimum for RES in buildings. In Kosovo* there are
currently no minimum levels for the use of renewable energy in building regulations and codes;
these were expected to be formulated in the Administrative Instruction on the Use of RES in
Buildings planned to be adopted at the end of 2013, but is not yet in place. In FYR of Macedonia
minimum levels are extensively regulated in the new legislative and regulatory measures. In
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Moldova the new Law on Energy Performance of Buildings sets minimum requirements for old,
existing and new buildings as well as requirements for the use of RES in private and public buildings,
but implementing regulation is still pending.
Energy efficiency certificates should be submitted for obtaining a license to use a newly constructed
or reconstructed building in BiH entity (FBiH) (still draft law), in BiH entity (RS) and Montenegro. In
BiH entity (FBiH) (Draft law), BiH entity (RS) and Montenegro (from January 2016), these energy
efficiency certificates should be provided to buyers/ lessees when selling or leasing of buildings. Also
in FYR of Macedonia the relevant regulatory act on energy performance of buildings stipulates the
issuance of energy performance certificates, which, among others, should indicate the share of RES
in the total energy consumption. In Moldova the recent Law on Energy Performance of Buildings
regulates certification of buildings and provides the establishment of an electronic information
system to register energy performance certificates. In Serbia it would be the study on energy
efficiency characteristics of buildings. Since RES is recognised as contributing to the energy efficiency
of buildings these certificates take into consideration RES electricity and heating production in
buildings.
2.2.5 RES-T
Support schemes (other than blending obligations)
Apart from blending obligations, Albania also provides for tax exemptions in its law on biofuels of
2008, but the necessary implementing regulations have never been adopted. This law is currently
under review with the aim, among others, to introduce more adequate incentive measures. In BiH
(FBiH and RS) there are no support schemes other than a blending obligation, which is not applied in
practice. In Kosovo* no support scheme for RES-T is currently available, although the draft Law on
Petroleum and Petroleum Product Market assigns the competent Ministry to propose to the
Government possible support schemes for the production of biofuels other than the establishment
of a blending obligation. In FYR of Macedonia there are currently no support schemes in place to
encourage the use of biofuels; however a draft law on biofuels should be adopted in the second half
of 2015 which is expected to introduce schemes for the promotion of the production and use of
biofuels in the transport sector, among others, through payment of monetary incentives to eligible
biofuel producers. In Moldova the same remuneration scheme for biofuels producers as for RES
generated electricity producers applies, i.e. biofuels producers calculate their tariffs annually based
on an ANRE methodology and subject to approval of their calculations by the same authority. In
Serbia the law provides that support for placing of biofuels on the market will be financed from the
State budget with participation of the producers of petrol derivatives and traders with petrol, petrol
derivatives, biofuels and CNG. It is still not adopted. Ukraine has, apart from blending obligations,
also general tax and customs exemptions for RES which may apply for biofuel production as well,
under the condition that such equipment or material is not produced in Ukraine.
Blending obligation
In Albania, BiH entities (FBiH and RS) and Ukraine there are regulations imposing blending
obligations which have not been implemented so far. In BiH entity (FBiH) quotas are calculated up to
2010 while in BiH entity (RS) the quotas are calculated until 2013. In Kosovo*, the draft legislation to
be adopted soon (Law on Trade and Petroleum, Petroleum Product and Renewable Fuels and
Regulatory act on Biofuels and Bioliquids Use) shall establish mandatory blending obligations. Also in
FYR of Macedonia the draft law on biofuels is expected to include provisions also on an obligatory
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biofuel quota to suppliers or to end users. In Moldova, while general reference to blending
obligations is made in the RES law of 2007, the draft new RES law introduces much more detailed
rules and obligations in this regard. In Montenegro and Serbia there are no support schemes and no
blending obligations.
Streamlined administrative procedures
Albania regulates administrative procedures in its law on biofuels of 2008, but this law has never
been implemented, and is currently under review. In Moldova the draft RES law sets out only the
general principles in relation to administrative procedures for RES-T. BiH (RS), Ukraine, Montenegro
and Serbia have regulation on licensing procedures for some biofuels energy activities. More
precisely, an operation license is in BiH entity (RS) required for production and storage of biofuels
but not for trade, in Montenegro for retail and wholesale trade with biofuels, in Ukraine for
production and for sale and in Serbia for production of biofuels. In addition, in Serbia energy permit
is required for construction of biofuel production plants exceeding 10t annually. The other CPs do
not regulate these procedures.
Sustainability criteria incl. verification for biofuels and bioliquids
In Albania’s law on biofuels of 2008 no sustainability criteria and verification schemes are
introduced, but this issue will be regulated in amendments to this law currently in preparation. The
RES law does not include any provisions regarding sustainability criteria for biofuels. In both BiH
entities (FBiH and RS), Montenegro, Serbia and Ukraine there are no sustainability criteria provided
or verification schemes for biofuels and bioliquids regarding the sustainability criteria. In Kosovo*
sustainability criteria and verification schemes for biofuels are expected to be introduced by the
draft Administrative Instruction (AI) on the use of biofuels and bioliquids. FYR of Macedonia has
drafted a law on biofuels which shall introduce sustainability criteria and establish a verification
system. The law shall be adopted in the second half of 2015 and secondary legislation shall follow
immediately thereafter. In Moldova provisions regarding sustainability criteria for biofuels will be
introduced for the first time by the new RES law, currently in draft form. However, the draft makes
only basic reference to this matter and detailed regulation is provided to take place through
regulatory acts of the Government. In Ukraine, the Action Plan for the implementation of the RES
Directive provides that the measures on sustainability criteria for biofuels and bioliquids were
foreseen to be developed by the end of 2014.
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2.3 Relevance of the national legislative measures with reference to the RES Directive
2.3.1 Introduction
Concerning the issue of relevance of national legislative measures with NREAPs, the following
question is addressed: Are the provisions of the RES Directive properly transposed into national
legislation?
In order to answer this question we have reviewed the existing laws, by-laws, draft agreements,
network codes, discussed the application of the adopted measures and immediate plans with the
authorities, when available, and discussed the barriers in implementation with the industry
representatives. The results have then been compared between the CPs in order to give an objective
assessment. We took into consideration, when possible, the immediate planned steps and how
ambitious the authorities are in reality regard to implementation of the measures.
In this section we have limited our research and findings only to assessing compliance with the
compulsory measures provided in the RES Directive, while recommendations based on these
findings are included in the relevant section of this report.
As the case was also in the “consistency” section of this report, the qualitative assessment is
presented separately for RES-E, RES-H&C and RES-T policies and measures, while in each of these
sectors several different subcategories are also separately assessed in correspondence to the
categorisations provided in the RES Directive and the NREAP template. Detailed results per country
are presented in the CP-specific reports presented in Annexes. In this section 2.3 of the main report
a basic outline of the key findings is presented, starting with a general overall assessment (2.3.2),
followed by a presentation of the findings for each particular sector and subcategory (2.3.3, 2.3.4
and 2.3.5). Moreover, in each of the three sectors, evaluation of compliance is also demonstratively
presented in relevant tables for purposes of clarity.
2.3.2 Overall assessment
Although it is difficult to categorise such diversity of measures and regulatory developments as they
depend on numerous and different circumstances of each CP, our conclusion is that most of the CPs
have demonstrated a moderate level of compliance as regards RES-E and relatively low level as
regards RES-H&C and RES-T. It should be acknowledged that most CPs undertake constant efforts to
increasing compliance. Good examples for RES-E compliance are Serbia and FYR of Macedonia
(although both should improve some aspects of compliance as described below) while Ukraine and
Moldova need more time and efforts, which is understandable given that they were last CPs to join
the Energy Community and had less time than the others to achieve compliance. All CPs
demonstrate a higher level of compliance in RES-H&C than in RES-T. Regarding H&C, FYR of
Macedonia and Moldova are the CPs with more advanced compliance as they have introduced
minimum levels for the use of renewable energy in buildings. They are followed by Montenegro and
RS which have already addressed some issues although significant improvement is needed. There is
no compliance of any CP regarding RES-T. Albania, Ukraine and BiH (RS and FBiH) have old laws with
blending obligation which are not applied in practice.
In Albania a moderate level of compliance as regards RES-E could be attested in general, although
higher level of compliance is demonstrated in certain aspects. The reason for still falling short of
satisfactory compliance is that some important primary legislation has been already adopted (RES
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law) but implementation is absent. Moreover, this legislation as such is not fully transposing the RES
Directive and needs to be amended. Nevertheless, progress should be expected soon because
harmonisation should be promoted also with the new Power Sector Law which is currently in draft
form and the adoption of which should also pave the way for respective improvement and
implementation of the RES law, for which no by-laws are being issued until the new Power Sector
Law is adopted. A relatively low level of compliance is demonstrated in the RES-H&C sector, because
the RES law does not properly take into consideration RES-H&C, while some progress in this field
should be expected by the adoption of the new law on energy efficiency, which is still in draft form.
A relatively low level of compliance is shown also in the RES-T sector, in which the Albanian
legislation is currently not compliant with the RES Directive but this may change through adoption of
the amendments to the law on biofuels and secondary legislation to follow.
BiH (FBiH and RS) have a moderate level of compliance in all three sectors. In the RES-E sector both
entities need to improve administrative procedures, although in FBiH there is an additional issue of
mixed competences due to the complex organisational structure of the entity and splitting of RES
related authorisations between 4 levels of administration (federal/cantonal/municipality/local
community). The information is still inadequate although the efforts to provide updated laws and
regulations on various web pages of authorities should be taken into consideration. There is,
however, no functional direct provision of information (comprehensive and reliable). RES-H&C
legislation is partly in compliance. Efforts have been made, further efforts should follow. RS has
more advanced regulation as it has passed the energy efficiency law which is in the BiH entity (FBiH)
still in the parliamentary procedure. In regard to RES-T both entities have adopted some time ago
rulebooks regulating a blending obligation but have failed to implement them.
In FYR of Macedonia a moderate and in some cases an advanced level of compliance is reached as
regards promotion of RES-E. Through a series of amendments and the adoption of new legislation in
the past few years FYR of Macedonia has improved significantly its level of compliance, particularly
with regard to simplification of administrative procedures and facilitation of RES integration, while
plans for further improvement in the near future allow for expectations for reaching fully
satisfactory levels of compliance. As regards RES-H&C, FYR of Macedonia has also recently
demonstrated significant progress in adopting primary and secondary legislation, in some aspects
reaching also an advanced level of compliance, although in some parts necessary measures are still
pending. In the RES-T sector the level of compliance is still low, but should be gradually improved if
the draft law on biofuels and implementing regulations are adopted until the end of 2015.
Kosovo* has also reached so far a rather moderate, and in some cases an advanced, level of
compliance as regards RES-E. While a set of several different regulatory acts in the past few years
has brought forward substantive improvements in relation to financial support and simplification of
administrative procedures, there is still progress to be made in several regards, mostly in relation to
practical implementation. Further, a relatively low level of compliance exists both in the RES-H&C
and the RES-T sector, but this could be changed soon, because in both cases a set of legislative and
regulatory acts is currently in the process of adoption.
In Moldova, the level of compliance in the RES-E sector ranges between low and moderate
depending on the specific aspect of compliance. In general, compliance may only reach satisfactory
levels when the draft RES law is finally voted and implementing by-laws are issued, although even
then further improvements may still be needed, especially towards simplification of procedures. As
regards RES-H&C a moderate level of compliance is generally attested due to the adoption of a
series of legislative acts within 2014, but further adoption of by-laws will be necessary for practical
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implementation. A rather low level of compliance is demonstrated in the RES-T sector, which would
still require time to be improved after adoption of the new RES law, since relevant issues are only
generally regulated there and adoption of detailed implementing regulations will be necessary
thereafter.
In Montenegro, the level of compliance is moderate with certain aspects of low compliance. In
regard to RES-E, procedures and information are not at the same level of compliance with all
authorities, because some authorities are understaffed. On the other hand efforts have been made
and numerous procedures have been already improved. The Law on Energy which is currently in the
parliamentary procedure should significantly contribute to improvement. There is partial compliance
in the RES-H&C sector as the new energy efficiency law was passed in December 2014 but the
respective by-laws are still to be issued. However, even this new law is not in full compliance with
the RES Directive. For example there is no obligation to use the minimum level of energy from RES.
There is no compliance in RES-T sector. Relevant legislation is planned to be introduced through
other acts.
In Serbia, the level of compliance is advanced for RES-E, moderate for H/C and low for RES-T. In
regard to RES-E, regulatory compliance may be considered advanced. The advanced level of
compliance is reached as regards promotion of RES-E, except from some particular aspects of
compliance with information obligations in which case compliance is not complete. Through a series
of amendments and the adoption of new legislation in 2014 Serbia has improved significantly its
level of compliance, particularly with regard to simplification of administrative procedures and
facilitation of RES integration, while plans for further improvement in the near future allow for
expectations for reaching fully satisfactory levels of compliance. As regards RES-H&C, compliance is
moderate particularly since the competence of adoption of H&C support measures has been
transferred to the local authorities without specific instructions and timeframe for implementation.
In the RES-T sector the level of compliance is still low as there is no compliance (there is no blending
obligation and no other support schemes regulated).
In Ukraine the level of compliance in RES-E is moderate. Although RES-E support measures function
in practice for some time, several incentives have been recently withdrawn or suspended. No clear
and immediate plan for further development seems to exist as the NREAP Implementation Plan is
not very ambitious. Streamlined administrative procedures and transparent cost-related charges are
yet to be achieved. Compliance with regard to RES-H&C as well as RES-T is on low level. It will be
improved when the envisaged measures on building and housing are passed and the legislation on
biofuels is either amended or implemented.
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2.3.3 RES-E
Table 2: Assessment of relevance of the national legislative measures with RES DIRECTIVE (RES-E)
Contracting
Party
AL
BIH
(State)
(FBIH/RS)
KO*
FYR of
Macedonia
MO
ME
SE
UA
Support schemes
Streamlined
administrative
procedures
Transparent
and cost-related
administrative
charges
Electricity
infrastructure
development
Objective rules
on connection
requirements (incl.
costs) made public
Guaranteed
and/or priority
access to the grid
Non-discriminatory
transmission and
distribution tariffs
Guarantees of
origin
Table legend:
The red light indicates a zero level of compliance whereby the CPs have not adopted any legal act
transposing the relevant provisions of the RES-D neither has such act been prepared and included in a
relevant decision making procedure.
The orange light indicates a low level of compliance whereby the CPs have drafted some legal acts within a
relevant decision making procedure, but these have not been adopted yet.
The yellow light indicates a moderate level of compliance whereby the CPs have adopted some major legal
acts, but they are not implemented in practice and/or substantive supporting regulation is needed for the
implementation.
The green light indicates an advanced level of compliance whereby the CPs have successfully transposed and
implemented all or most of the provisions of the RES-D.
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Support schemes and power purchase agreements (PPA)
Article 3 of the RES Directive provides that CPs in order to achieve their mandatory national overall targets shall
introduce measures effectively designed to ensure that the share of energy from renewable sources equals or
exceeds that shown in the indicative trajectory, including support schemes.
Considering the fact that the relevant provision of the RES Directive (article 3) is very flexible in
regard to support schemes, as it does not set specific requirements for the features and procedures
relating to the support schemes applicable in each CP, compliance - in a strictly legal sense - is
satisfied when relevant support schemes do exist in a CP. This is the case for almost all CPs
(including Kosovo* now that also PV are eligible for FITs) except for Albania in which FITs are
applicable only to small hydro.
As regards evaluation of status of PPAs in particular, as the model PPA is not regulated by the RES
Directive, our comments refer, not to compliance in a strict sense, but to legal effectiveness of the
PPA provisions and schemes.
Security of investors and their financiers is an important issue for promotion of RES in CPs. They
normally require to be contractually secured before they begin construction and invest large
amounts of money in a CP. BiH (both entities) have preliminary and main agreements. In case of
(FBiH), there is no strict contractual obligation to conclude the main agreement if the investor fulfils
its obligations, while in BiH (RS), there is a provision for the obligation to conclude but does not
provide security that the main agreement will contain the provisions known to the investor at the
time when the preliminary agreement is concluded. In Kosovo* a recent amendment gave to
producers the right to enter into a PPA at the moment of being granted with preliminary
authorisation, so that the applicable FITs are guaranteed. In Montenegro there is a first agreement
on the main conditions for conclusion of the main agreement which contains the obligation of the
supplier to conclude the main agreement. The content of the first agreement should be improved
particularly regarding the conclusion of the main agreement before finalisation of the construction
and the need for clarification of the provisions regulating amendments to the agreement. Serbia has
resolved this issue by introducing one single agreement to be signed before beginning of the
construction. Ukraine does not fulfil this requirement as the PPA is concluded only after conclusion
of construction. Out of all CPs, although legally provided, no standard PPA has been developed yet
in Kosovo* and Moldova.
Streamlined administrative procedures
Article 13(1) (a), (c), (d) and (f) of the RES Directive includes the following requirements: a) clearly coordinated
and defined responsibilities of bodies assigned with authorisation, certification and licensing, including spatial
planning; b) streamlined and expedient administration procedures; c) objective, transparent, proportionate and
non-discriminative rules on authorization, certification and licensing; d) consideration of particularities of
individual RES technologies; and e) simplified procedures for smaller projects.
In Albania the establishment of a one-stop shop signifies to a large extent compliance with the RES
Directive requirements for coordinated administrative procedures. Legislation applicable to RES
licensing is older than the RES Directive and thus not fully compliant. This should be changed by the
recently adopted new power sector law and the relevant implementation regulation to follow. BiH
(FBiH) has the most complex licensing procedures with confusing jurisdiction and authorisation
issues. It has made an attempt of simplification by introducing the RES Operator but the authorities’
coordination issues are yet to be fully addressed. BiH (RS), Montenegro and Serbia have numerous
authorities involved on different levels but their authorisations are clear and undoubted. There is no
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sufficient coordination between them. In Kosovo* better coordination between institutions of
different levels responsible for RES projects should be achieved. Compliance is not fully achieved.
The recent regulatory decision of ERO determining the special procedures for the authorisation of
new RES plants constitutes though a significant step towards achievement of compliance.
In FYR of Macedonia, continuous improvements of the legislative and regulatory framework in the
past few years have substantially simplified and shortened the administrative procedures. Further
simplification is possible and is expected to come by the new energy law. Compliance is so far
satisfactory and is expected to be improved more soon. In Moldova a low level of compliance is
attested; the whole licensing procedure comprises several steps to which different legal acts apply,
so that the need for simplification, especially for smaller plants, is clear. Planned adoption of draft
RES law shall only set a very basic framework for simplification. Montenegro and Serbia have made
significant improvements during the last years in direction of reducing duration and complexity of
construction permits procedures which was the main barrier and lasted long. Ukraine also has
numerous authorities involved in authorisation procedures. The law regulating the authorisations of
NRA is currently in parliamentary procedures; thus improvements are expected.
Information & assistance to applicants
Article 13 1 (b) of the RES Directive regulates the obligation of CPs to provide comprehensive information on
the processing of authorisations, certification and licensing applications as well as on available assistance to
applicants.
In Albania, BiH (FBiH and RS), Kosovo*, FYR of Macedonia, Montenegro, Serbia and Ukraine
although in practice several authorities provide information to applicants to a certain extent,
dissemination of information to applicants is not clearly regulated in the relevant legislation as a
legal obligation of a certain body; thus, compliance on a legal level is not sufficient. In Albania, the
RES law designates a certain body to develop guidelines, but this does not include a clear obligation
for assistance to applicants. In Moldova, the establishment of a single information centre (within the
Energy Efficiency Authority) is a very positive measure, although practical implementation could be
improved.
In general, the CPs present a significant number of updated legislation and regulations on the web
pages of their authorities, although mostly in local language. All CPs should improve the level of
information provided in English language.
Transparent & cost-related administrative charges
Article 13.1 (e) of the RES Directive lays down the obligation of transparent and cost-related administrative
charges paid by consumers, planners, architects, builders and equipment and system installers/ suppliers.
In Kosovo* and FYR of Macedonia compliance is achieved by the fact that the relevant acts
establishing the fees payable by the applicants explicitly correlate these fees to the administrative
expenses of the licensing body. In Albania, BiH (FBiH and RS), Moldova, Montenegro and Serbia,
this is not always the case; nevertheless, transparency is ensured through the fact that
administrative charges are officially published. In Ukraine the transparency of charges should be
improved. All CPs should try to collect and provide all information on charges on one place.
Electricity infrastructure development
Article 16 (1) of the RES Directive regulates the obligation of the CPs to enable integration of RES into the
electricity grid through development of transmission and distribution grid infrastructure, intelligent networks
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and storage facilities as well as accelerated and coordinated authorisation procedures for grid infrastructure
development.
In Albania, primary compliance is satisfactory from a legal point of view considering that the RES law
lays down obligations to the network operators for network development for the purpose of RES
integration, while intelligent networks are also addressed as an issue. BiH (FBiH and RS),
Montenegro and Serbia are in regulatory compliance with the planning of RES integration. In
Kosovo* RES integration seems to be sufficiently taken into consideration in the relevant legislative
and regulatory framework for network development, but this should be implemented also in
practice. This does not appear to be the case in FYR of Macedonia, but on the other hand general
RES integration planning is satisfied by means of a comprehensive study on RES integration strategy.
In Moldova, although general rules on network development exist, it is not clear whether
integration of RES is sufficiently taken into consideration. In Ukraine the proposal for the ten-year
network development plan is published but it has not been adopted yet. The Ministry of Energy
Order on the Procedure for Preparation by the TSO of the Ten-Year Network Development Plan for
the Unified Energy System of Ukraine requires inclusion of the developed and future RES facilities in
the plan.
In BiH, Kosovo*, FYR of Macedonia, Moldova and Montenegro no compliance is attested so far as
regards intelligent networks, information technology tools and storage facilities.
Objective rules on connection requirements (incl. costs) made public
Article 16 (3) and (5) of the RES Directive provides that standard rules on costs for technical grid adaptations,
grid operation improvement and non-discriminatory implementation of the grid codes are made public by the
TSOs and DSOs and that new applicants are comprehensively informed by the TSOs and DSOs on connection
cost estimates and on timetables for processing requests and for grid connection.
Article 16 (3) ad (4) of the RES Directive provides that the rules relating to the bearing and sharing of costs for
grid adaptations necessary for RES integration are based on objective, transparent and non-discriminatory
criteria, through establishment of a respective mechanism taking into account costs and benefits of RES
integration. Such costs are eventually, partly of full, borne by TSOs and DSOs.
In Albania, compliance is sufficient only on a primary level, considering the substantive information
obligations as well as obligations to set up and make public non-discriminatory standard rules on
bearing and sharing of the costs which are laid down to the operators by the RES law. However, in
terms of practical implementation, the implementing regulations are still pending. Although the RES
law includes stipulations in compliance with the RES Directive in this regard, no such rules have been
published yet. In BiH (FBiH and RS) the rules for all grids connections are made public and objective.
Kosovo* is also generally compliant, having introduced rules on providing the applicants with
necessary information on grid connection requirements, timetables and costs as well as on bearing
and/or sharing of the costs. In FYR of Macedonia simplification of connection procedures is a
significant step towards compliance. More transparency was introduced with the recent
amendments to the network codes. Bearing and sharing of connection costs is sufficiently regulated,
except for cost sharing in cases of connection to the transmission system. In Moldova the current
practice of the network operator to provide information only on a case-by-case basis is not
compliant with the requirements of the RES Directive; this should be changed when the new RES law
is finally adopted. There is also no clear and publicly available methodology of connection costs
allocation between network operators and RES producers and no rules setting up conditions for grid
connection in an objective and transparent way. Compliance in this regard is thus unsatisfactory. In
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Montenegro, transmission costs were introduced only last year. In Serbia compliance is achieved in
regard to objectiveness, transparency and publicity of rules. Producers bear part of the costs but
there is no sharing between old and new connections. Ukraine does not have sufficient transparency
regarding the non-standard connections which are decided on a case-by-case basis without clear
methodology. There are rules on sharing of costs between a RES fund and investors which are often
not applied in practice. There are no rules on sharing of costs between producers connected to the
connection point of the network.
Guaranteed and/or priority access to the grid
Article 16 (2) of the RES Directive provides that CP should ensure either guaranteed transmission and
distribution or priority or guaranteed access to the grid and the priority of dispatch.
In Albania, Kosovo* and FYR of Macedonia a high level of legal compliance is attested, since the
national legislation provides for guaranteed transmission and distribution of RES generated
electricity through the grid as well as guaranteed purchase or priority dispatch. In Moldova
compliance should only be achieved after the draft RES law is adopted. BiH (state level) and
Ukrainian rules are not in compliance as there is no priority access and dispatch or guaranteed
transmission and distribution. BiH (FBiH and RS), Montenegro and Serbia, are in compliance as
priority access is granted to the RES producers that are part of the support scheme.
Non-discriminatory transmission and distribution tariffs
Article 16 (7) of the RES Directive provides that CPs shall ensure that transmission and distribution tariffs do not
discriminate RES generated electricity and reflect realisable cost benefits.
In Albania, compliance is from a legal point of view achieved through the legal provision explicitly
correlating the transmission and distribution tariffs with the cost suffered by the operators for the
purpose of integration of RES to the network. In Kosovo* compliance is achieved considering that
non-discrimination of RES producers through the tariffs for grid access is a general legal requirement
and it is also concretely regulated in the relevant regulatory act. In FYR of Macedonia, because RES
producers are not subject to network charges, discrimination is not an issue. In Moldova, this issue is
regulated in the draft new RES law, which should ensure compliance when the law is voted. There is
no discrimination of RES generated electricity in BiH (state level) and BiH (FBiH and RS),
Montenegro, Serbia and Ukraine.
Information and training on RES support measures, benefits and use
Article 14 (1), (2), (5) and (6) of the RES Directive provides that CPs shall ensure that information and guidance
is made available to all relevant actors (also through awareness-raising, guidance and training programmers)
on RES support measures, on the benefits, costs and energy efficiency of equipment and on the optimal use of
RES technologies.
In Albania compliance is quite satisfactory from a legal point of view, considering that information
obligations are relatively comprehensively regulated in law. Practical implementation is still
unsatisfactory. The same should also be the case for Moldova when the draft RES law is adopted.
BiH (FBiH and RS), Montenegro, Serbia and Ukraine have a similar level of information, except that
in Montenegro for some issues and by some authorities less information is provided. Most relevant
regulation is provided in their web pages in local language. Only Serbia has developed guidelines for
foreign investors updated in 2013 which should be again updated. There is no full compliance. In FYR
of Macedonia, although in practice information campaigns and training programs on the benefits
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and use of RES take place from time to time, there are no information requirements according to
article 14 of the RES Directive stipulated in any national legal act. Also in Kosovo* no such clear legal
provision imposing information obligations seems to exist.
In Albania, FYR of Macedonia and Moldova not sufficient official guidance and trainings are
provided to local and regional administrative bodies.
Guarantees of origin
Article 15 of the RES Directive provides that GoO issued in accordance with objective, transparent and nondiscriminatory criteria at the request of electricity RES producers (possibly also of heat and cooling RES
producers), for the purpose of proving the share or quantity of RES in it the supplier's mix in accordance with
article 3 (6) of Directive 2003/54/EC. GoO have a standard size of 1 MWh, are valid for 12 months and have the
minimum content of article 15 (6).
Except for Montenegro, no CP has a functional system of GoO. In Albania and FYR of Macedonia the
procedures for issuance, transfer and cancellation, the form of the GoO and the information which is
required to be contained in it, as stipulated in the relevant legislative and/or regulatory measure,
generally meet the requirements of the RES Directive. This is also generally the case in Kosovo* with
the exception that the relevant regulatory act provides for a longer period of usage of the GoO
(specifically 18 months from the moment of production of the energy unit). In Moldova, the so far
applicable framework on GoO is not in compliance with the RES Directive. However, this should be
changed after the adoption of the new RES law, which includes stipulations mostly in line with the
Directive: the provisions of the draft RES law on electronic issuance, transfer and cancellation of GoO
as well as on recognition of foreign GoO are mostly in compliance with the RES Directive. Not
properly regulated is the supervision of the procedures as well as the fact that all network operators
and not a single entity is assigned with the issuance of the GoO.
In some CPs the content of the GoO is not in accordance with RES-D, as in the case of BiH (FBiH and
RS) and Ukraine. In Montenegro and Serbia the content is in compliance with RES-D. The following
CPs do not have supervision of GoO issuing, transfer and cancellation by other authority than the
one which issued them or the supervision issue is not addressed at all: Albania, BiH (FBiH and RS),
Kosovo* and Ukraine. With some exceptions (e.g. Albania, Moldova) most CPs are also not
compliant in regard to recognition of the GoO issued by other CPs.
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2.3.4 RES-H&C
Table 3: Assessment of relevance of the national legislative measures with NREAPs (RES-H&C)
Contracting
Party
AL
BIH
(FBIH/RS)
KO*
FYR of
Macedonia
MO
ME
SE
UA
Support schemes
Building sector
Table legend:
The red light indicates a zero level of compliance whereby the CPs have not adopted any legal act
transposing the relevant provisions of the RES-D neither has such act been prepared and included in a
relevant decision making procedure.
The orange light indicates a low level of compliance whereby the CPs have drafted some legal acts within a
relevant decision making procedure, but these have not been adopted yet.
The yellow light indicates a moderate level of compliance whereby the CPs have adopted some major legal
acts, but they are not implemented in practice and/or substantive supporting regulation is needed for the
implementation.
The green light indicates an advanced level of compliance whereby the CPs have successfully transposed
and implemented all or most of the provisions of the RES-D.
Support schemes
Article 3 of the RES Directive provides that CPs in order to achieve their mandatory national overall targets shall
introduce measures effectively designed to ensure that the share of energy from renewable sources equals or
exceeds that shown in the indicative trajectory, including support schemes.
In Albania, the RES Directive is not sufficiently transposed in the national legislation, because the
RES law does not properly take into consideration RES for H&C purposes, while generally envisaged
measures for tax exemptions for solar water heating have not been adopted yet. In Kosovo*
compliance is not satisfactory; although legislation includes general provisions on the support of
RES-H&C, it appears that necessary implementing regulatory measures are not in place. In FYR of
Macedonia a significant level of compliance has been achieved, since several specific measures have
already been adopted, although financial mechanisms of more general character are missing. In
Moldova due to the lack of any support schemes applicable for RES-H&C, the national legislation is
not in compliance with the RES-Directive; no improvement is expected in this regard through the
pending adoption of the new RES law. In BiH (FBiH and RS), Montenegro and Serbia there are no
support schemes. In Ukraine there are support schemes consisting of tax and customs exemptions.
Building sector
Article 13 (4), (5) and (6) of the RES Directive regulates that the use of RES for electricity and heating & cooling
should be ensured by local and regional bodies, when planning and building industrial and residential
infrastructure; measures to promote the use of RES in the building sector and minimum requirements for new
and renovated buildings (by 31 December 2014) should be introduced in the building regulations and codes,
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inter alia, through district heating and cooling; CPs should ensure that new and reconstructed public buildings
have from 1 January 2012 onwards an exemplary role in regard to RES .
In Albania there are currently no minimum levels for the use of renewable energy in buildings. Draft
legislation on energy efficiency, which should include provisions also with regard to the use of RES in
buildings, has still not been adopted. Compliance remains so far unsatisfactory. In BiH (FBiH) there is
no compliance as the draft law on Energy Efficiency which should regulate this issue is still in the
parliamentary procedure. Even if it is adopted in the proposed form it would not be in full
compliance (no minimum requirements for RES, no exemplary role of public buildings etc). BiH RS is
generally not in compliance (no requirement for minimum levels of energy from RES in new or
reconstructed buildings; no obligation for exemplary role of public buildings; no promotion of H&C
systems and other requirements regarding biomass, heat pumps, solar thermal energy). In Kosovo*
as long as the expected legislative and regulatory acts on energy performance of buildings is not
been adopted, compliance remains unsatisfactory. Since 2013 FYR of Macedonia has demonstrated
significant progress in adopting primary and secondary legislation on energy efficiency, also
specifically with regard to the use of RES on buildings, including setting minimum levels. Compliance
has been achieved to a great extent.
In Moldova adoption of primary legislation including provisions on the use of RES in buildings
signifies a positive step towards compliance, but adoption of implementing regulations is still
pending. Montenegro is also generally not in compliance (no requirement for minimum level of
energy from RES in new or reconstructed buildings, no obligation for exemplary role of public
buildings). Serbia also does not have satisfactory compliance although several by-laws are currently
being prepared (no compulsory use and minimum level or RES, no exemplary role of public buildings,
no special promotion measures). There are few provisions on the use of RES in building sector. In
Ukraine there is no compliance and the measures are planned for 2016.
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2.3.5 RES-T
Table 4: Assessment of relevance of the national legislative measures with NREAPs (RES-T)
Contracting
Party
AL
BIH
(FBIH/RS)
KO*
FYR of
Macedonia
MO
ME
SE
UA
Support schemes
(other than
blending
obligation)
Blending
obligation
Streamlined
administrative
procedures
Sustainability
criteria incl.
verification for
biofuels and
bioliquids
Table legend:
The red light indicates a zero level of compliance whereby the CPs have not adopted any legal act
transposing the relevant provisions of the RES-D neither has such act been prepared and included in a
relevant decision making procedure.
The orange light indicates a low level of compliance whereby the CPs have drafted some legal acts within a
relevant decision making procedure, but these have not been adopted yet.
The yellow light indicates a moderate level of compliance whereby the CPs have adopted some major legal
acts, but they are not implemented in practice and/or substantive supporting regulation is needed for the
implementation.
The green light indicates an advanced level of compliance whereby the CPs have successfully transposed and
implemented all or most of the provisions of the RES-D.
Support schemes (other than blending obligation)
Article 3 (4) of the RES Directive provides that CPs shall introduce measures to ensure that the share of energy
from renewable sources in all forms of transport in 2020 is at least 10% of the final consumption of energy in
transport in the CPs, including support schemes.
Despite adoption of relevant primary legislation introducing certain tax exemptions a long time ago,
Albania’s law on biofuels of 2008 has never been applied in practice and the RES law has contributed
very little as regards RES-T. Thus, Albanian legislation is practically not compliant with the RES
Directive but this may change through adoption of the amendments to the law on biofuels and
secondary legislation to follow. In Kosovo*, although the draft legal acts which will become
applicable in the RES-T sector mainly provide for the introduction of blending obligation, adoption of
other support schemes is also provided as a possibility. Also in FYR of Macedonia compliance is
expected to be reached only after the adoption of the law on biofuels and the implementation
regulations, providing among others for payment of monetary incentives to eligible biofuel
producers. In Moldova compliance is achieved as regards support of biofuels production because
the RES law of 2007 and a relevant act of the regulator introduce a support scheme for
remuneration of biofuels production. In BiH (FBiH and RS), Montenegro and Serbia there is no
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compliance as there is no support scheme. In Ukraine there are tax support schemes applicable to
all RES including RES-T.
Blending obligation
Article 3 (4) of the RES Directive provides that CPs shall introduce measures to ensure that the share of energy
from renewable sources in all forms of transport in 2020 is at least 10% of the final consumption of energy in
transport in the CPs, including support schemes.
In Albania, Kosovo* and FYR of Macedonia blending obligations are expected to be imposed and
implemented only after the adoption of the respective laws on biofuels (in Albania, revision of the
existing law which provides for blending obligation) and the implementation regulations. BiH (FBiH
and RS) has passed the relevant regulation many years ago but it was never applied in practice. In
Moldova blending obligations are only generally addressed in the currently applicable RES law of
2007. Detailed regulation is included in the draft new RES law. Thus, compliance will be satisfied only
after voting of the RES law and adoption of further implementing regulations are accomplished. In
Montenegro and Serbia there is no compliance as no regulation on blending obligation exists.
Ukraine has regulation on blending obligation which is not applied in practice.
Streamlined administrative procedures
Article 13(1) (a), (c), (d) and (f) of the RES Directive includes the following requirements: a) clearly coordinated
and defined responsibilities of bodies assigned with authorisation, certification and licensing, including spatial
planning; b) streamlined and expedient administration procedures; c) objective, transparent, proportionate and
non-discriminative rules on authorization, certification and licensing; d) consideration of particularities of
individual RES technologies; and e) simplified procedures for smaller projects.
In Albania compliance is unsatisfactory because the law on biofuels of 2008 has never been applied
in practice and the RES law has contributed very little as regards RES-T. This may change through
adoption of the amendments to the law on biofuels and secondary legislation to follow. No
compliance is respectively attested in BiH (FBiH), Kosovo* and FYR of Macedonia. Not sufficiently
compliant is also Moldova in which the current legal framework does not regulate administrative
procedures in relation to RES-T and the draft RES law only sets out the general principles. BiH (RS),
Montenegro, Ukraine and Serbia have regulation on licensing procedures for certain biofuels energy
activities which are the same as for the other energy activities.
Sustainability criteria incl. verification for biofuels and bioliquids
Articles 17 and 18 of the RES Directive provide that energy from biofuels and bioliquids, which is taken into
account for the purposes of compliance with RES Directive's obligations and targets, fulfils certain sustainability
criteria: Greenhouse gas emissions savings are at least 35%, 50% from 2017 and 60% from 2018; biofuels and
bioliquids are not obtained from certain land categories (with high biodiversity value, with high carbon stock,
peat land); biofuels and bioliquids are obtained in accordance with the standards of Annex II to Regulation (EC)
No 73/2009. Economic operators use a mass balance system, submit reliable information and undergo
independent auditing. CPs submit to EC Secretariat this information.
Albanian legislation is not compliant with the RES Directive as long as planned amendments to the
law on biofuels and secondary legislation, which are expected to include provisions regarding
sustainability criteria for biofuels, are not adopted. The same goes for Kosovo* as regards the
regulatory act on the use of biofuels and bioliquids, FYR of Macedonia as regards the planned law on
biofuels and secondary legislation, and Moldova as regards the planned RES law and secondary
legislation. There is no compliance in BiH (FBiH and RS), Montenegro, Serbia and Ukraine.
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2.4 Assessment of Contracting Party RES policies
2.4.1 Introduction
This chapter assesses Contracting Parties’ RES policies from the perspective on how they worked in
practice. In all Contracting Parties’ support systems and legal frameworks (as assessed in chapter 2)
are present, but didn’t always lead to a (significant ) RES expansion. The assessment was made
based on literature and most importantly on interview with energy experts, business and other
relevant stakeholder in all Contracting Parties over the last months. It should help to illustrate
strengths weaknesses in the Contracting Parties’ support schemes and will contribute also to the
effectiveness and viability assessment in chapter 2.
2.4.2 Support schemes
All Contracting Parties have introduced RES support schemes in the last years, mainly for RES-E.
Most of the Contracting Parities have feed-in systems (referred to as feed-in-tariffs (FIT)) for RES-E,
however capped at low levels for non-hydro technologies. Albania and Ukraine have in addition tax
exemptions for power producers. While next to hydro also wind is incentivized in some of the
Contracting Parties, most have only marginal support for PV or biomass electricity.
2.4.2.1 RES-E
Technologies
Most of the Contracting Parties have feed-in tariff systems for RES-E in place. In BiH (RS), a
combination of two support measures (FIT and premiums). In Moldova there is a general tariff
calculation methodology, based on which producers calculate annually their own tariffs and submit
them to the regulator for approval. Moldova has plans to introduce a tendering procedure as the
current system is not considered to provide long-term security and reliability for investors.
While Albania has a FIT only for small hydro power plants all other Contracting Parties have FITs
also for wind and PV. In Montenegro the support for solar plants is restricted to a maximum
capacity of 1 MW limited only to roof tops or building structure.
Support durations
The support duration varies strongly among Contracting Parties ranging from only 10 years for all
technologies in Kosovo* (except PV where it is 12 years) to 20 for hydro in FYR of Macedonia. In BiH
entity level (FBiH), Montenegro and Serbia the duration of the tariff is 12 years while in Albania 15
years. In BiH entity level (RS) the duration is also 15 years. In Ukraine there is no provision on the
duration of the agreement, the FIT lasts until 2030 while there is a general obligation to purchase all
electricity from RES.
Cap on support amounts
In several Contracting Parties the supported amount is capped mainly for non-hydro technologies.
The cap is sometimes very low for technologies such as PV.
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Table 5: Overview of caps on supported amounts (quotas) in the Contracting Parties
Contracting
Party
Large hydro
Small hydro
Wind
PV
Biomass
Biogas
-
-
-
-
-
436.5 GWh
No cap
302.22 GWh
20.56 GWh
105 GWh
-
FYR of
Macedonia
No cap
No cap
100 MW
18 MW
10 MW
7 MW
Moldova
No cap
No cap
No cap
No cap
-
-
Montenegro
No strict limits, but Government may limit support schemes or withhold support in the
event it is deemed to have a negative impact on the economy or on the price of electricity
Serbia
No cap
Ukraine
No info
Albania
No cap
Bosnia and
Herzegovina
No info
Kosovo*
No cap
500 MW
10 MW
No cap
No cap
Not in all Contracting Parties the cap on support matches the expansion plans. In FYR of Macedonia
the cap for wind and PV is below the expansion plans in the NREAP, while in Kosovo* it is above. In
Serbia the cap for PV already has been exhausted.
Levels of FITs over time
The levels of FITs in the Contracting Parties are comparable with levels in many EU countries, only
Bosnia and Herzegovina and in particular the Federation has lower FIT levels than the other
Contracting Parties. While the cost of capital for RES-E investments in Contracting Parties is generally
higher than in the EU, the investment costs for particular hydro power is generally lower than in EU
Member States due to lower labour and environmental cost and (Tuerk et al. 2014). For non-hydro
technologies especially wind, IFIs provide favourable financing conditions. In some Contracting
Parties the level of support is not fixed over the support period, but set annually. In a few others
Contracting Parties it has been cut over time.
•
•
•
•
In Albania the PPA tariff is updated on a yearly basis reflecting the average import price of
the previous year and the average retail tariff for tariff customers.
In Ukraine according to Business associations the support schemes (tax benefits and FIT) are
considered sufficient for the development of the RES sector and stimulated development of
solar and wind electricity generation but legislative inconsistency regarding (, unexpected
reduction of FIT, cancellation of tax exemptions/reductions) and the local content
requirement of 50% may endanger the fulfilment of obligations under the NREAP.
Also Serbia saw a reduction of FIT levels for wind in 2012. According to the Serbian
Association for Wind Energy (SEWEA) and other market actors however the current FIT level
is still satisfactory but there is concern that it may be again changed. For biomass electricity
the FIT seems too low for investors.
In Montenegro the level of support seems to be sufficient but the duration of the support
may be reduced by the new RES law.
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2.4.2.2 RES-H&C
Measures for RES-H are in a planning phase in some of the Contracting Parties. With a few
exceptions no support mechanism are in place, even though most of the Contracting Parties aim to
significantly expand RES-H up to 2020. In particular Albania, Montenegro or Ukraine plan a
significant increase of RES-H.
Some of the Contracting Parties have (limited) support mechanisms for RE-H in place:
•
•
•
•
•
In Kosovo* the government promotes the use of RES-H (investment grants / capacity
payment).
Montenegro that also has first pilot programmes for solar-thermal heating.
In FYR of Macedonia, in order to stimulate the use of solar energy in the country, the
Ministry of Economy in several of the last year conducted activities for the implementation
of subsidies through reimbursement of part of the cost for purchased and installed solar
thermal collector systems in about 500-600 households per years. In addition in FYR of
Macedonia the VAT rate for solar collector systems is lowered from 18% to 5%.
In Ukraine some support schemes applicable to all RES have been in place but partly been
cancelled in 2015 (land tax reduction, profit tax exemptions for production of heat by
biofuels). Exemption from VAT and import duty for import of equipment for operations and
production from renewable sources (if such equipment is not produced in Ukraine) are still
in place.
In Moldova no generally applicable support scheme for RES heating and cooling exists but
financing of RES for heating and cooling is partly made on a project-basis through the
support of several funds and programmes.
Interest free credit lines are available for RES-H in several Contracting Parties.
Several of the Contracting Parties plan support schemes for RES-H in the upcoming years:
• Albania is planning policies and measures to implement solar heating in buildings following a
successful pilot programme supported by the GEF und implement by UNDP.
• In Serbia according to the Law on Energy support measures for RES-heat should be
developed by local self-government.
• In Kosovo* an act generally provides for the possibility of providing FITs to RES thermal
energy generating plants connected to the thermal energy grid but the competent regulator
has not set out any such FITs yet.
• In Montenegro policy and support schemes for promoting use of renewable energy sources
in heating and cooling are planned for 2015.
2.4.2.3 RES-T
In the transport sector only Albania, both entities in ΒiH and Ukraine have implemented legal
provisions for blending obligation in place, but were in the case for BiH and Ukraine never applied.
Serbia and FYR of Macedonia are in the process of implementing corresponding regulations or laws
for blending obligations. In Albania and Ukraine there are some existing support measures aimed to
encourage development of alternative fuels, such as tax benefits. In Moldova support of biofuels is
provided both through a support scheme for biofuels production as well as with blending obligations
for importers and suppliers.
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2.4.2.4 Overall Assessment
The support schemes for RES-E show mixed success in the Contracting Parties. Only in few
Contracting Parties, such as Montenegro or FYR of Macedonia an expansion of non-hydro RES-E
could be observed so far. In most Contracting Parties for example there are no or only the first wind
parks being implement even if FITs exist since several years. In Montenegro for example the FIT
could sufficiently incentivize wind electricity expansion and is likely to meet its 2020 expansion
plans. In Kosovo* where the support level is lower and the support period shorter, no wind farm has
been built so far and in general nor RES-E support has been paid at all as there are no investors. In
Serbia the support levels seem to be high enough according to market actors, rather administrative
barriers slow down RES expansion, only for biomass electricity the FIT seems to be too low. In the
BiH entity BIH(FBIH) the feed-in tariffs are lower for wind and PV than in the BiH entity BIH(RS), RS
and in the other Contracting Parties, the country has so far only one wind park in place, however
several planned ones. Albania does not incentivize non-hydro technologies. In several Contracting
Parties, such as Ukraine or in Serbia, for wind the FIT levels were lowered after their introduction
while FIT levels have to capture the country risks (that are higher than in the EU) leading to
increased uncertain among investors.
For RES-H only a few Contracting Parties have support schemes in place and in most cases on a
limited scale. For RES-H that most Contracting Parties aim to significantly expand almost no support
is available, and for RES-T countries are only at the beginning of introducing relevant legislation. For
RES-T a few Contracting Parties have provisions or laws, mostly blending obligation in place or under
implementation, other Contracting Parties plan legal provisions or support or mechanisms for the
next years.
Administrative procedures
Licensing procedures are generally considered to be a key barrier to the development of RES.
Therefore, the RES Directive includes several provisions to ensure improvements in the procedures
for authorisation, certification and licensing. In particular, Article 13 of the RES Directive addresses
among others:
•
•
•
•
•
coordination between different administrative levels and agencies and asks for concrete
time limits for decisions;
comprehensive information shall be made available and assistance provided at appropriate
level;
streamlining at adequate administrative levels and requirements shall be objective,
transparent and proportionate;
administrative charges to be paid are transparent and cost related; and
simplified and less burdensome procedures for smaller projects or decentralized projects.
Furthermore, article 22(3) specifies the general reporting obligation, including a report on plans to
have a so-called “one stop shop”, i.e. a single agency for all authorisation, certification and licensing
procedures (art. 22(3) a)), automatic permission in case of no response from the respective authority
within a certain time frame (art. 22(3) b)) and measures to clearly identify geographical sites for the
use of renewables and district heating and cooling. (Hamelinck et al., 2012)
This chapter assesses the practical functioning of administrative procedures complementary to the
legal assessment in chapter 2.3.
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Table 6: Assessment of administrative procedures in Contracting Parties
Contracting
Party
AL
BiH
(RS/FBiH)
KO*
FYR of
Macedonia
MO
ME
RS
UA
Coordination
between different
administrative
levels
Admin
procedures/One
stop shop
Transparent cost
related charging
Transparent and
comprehensive
information on
procedures
Simplified
procedure for
small projects
Table legend:
The red light indicates a level of implementation whereby the CPs have not envisaged action or
not have implemented envisaged actions.
The amber light indicates an advanced level of implementation whereby actions have been
initiated but nevertheless require additional effort.
The green light indicates a mature level of implementation whereby the CPs have successfully
implement all or most of the provisions
Coordination between administrative levels and agencies/ concrete time limits for
decisions
A lack of coordination between different administrative levels and agencies is a major problem in
most Contracting Parties. Often numerous state and local level authorities are involved in the
licensing and administrative procedures. Only a few Contracting Parties were able to improve this
situation. In Albania the establishment of the National Licensing Centre was a very positive
development since it assumed the largest part of the licensing procedures and helped reduce the
time period necessary. Authorisation and licensing procedures in Ukraine are carried out by many
bodies of different levels. However a draft law of Ukraine on State Regulation of Energy Sector has
been developed and is undergoing approval procedures that shall secure the legal status of the
National Commission for State Regulation of Energy and Public Utilities Sector, including its
responsibilities. The indicative time of adoption is the second quarter of 2015 and may be a step in
the right direction. In FBiH there are numerous authorities involved in the licensing procedures and
insufficient number of legal acts regulating the particular licensing steps which in practice lead to
overlapping and bottlenecks. In Serbia the coordination between different administrative levels and
agencies needs to be improved, long duration of the procedure are among the main barriers for
implementation of RES projects. In Montenegro there is not sufficient communication between the
numerous authorized bodies. It is the same for FBiH, where this leads to major overlapping and
bottlenecks. Also in FYR of Macedonia too many authorities are involved on local and central level,
leading to long licencing procedures of up to two years. In Kosovo* there are no clear mechanisms
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for coordination of the different authorities. Problems are reported in relation to the efficiency of
local authorities issuing construction permits. Nevertheless, in both aforementioned CPs
authorization procedures have been recently simplified and shortened.
Transparent and comprehensive information on procedures
Not in all Contracting Parties information on procedures is transparent and comprehensive. Serbia
however is a good example: In 2012 four guides for Investors updating the 2010 and one new were
produced. In Kosovo* the regulator ERO provides sufficient information and assistance to the
applicants. Except for general information, it also provides individual assistance and information is
also provided on the web page. In Ukraine the information is well provided by the legislation and is
available at web-sites of respective bodies, but in Ukrainian only; overviews on project
implementation stages of the construction of RES facilities in general and wind power plants in
particular are being developed and planned to be available on-line in Ukrainian and English in 2015.
In FYR of Macedonia information is provided by several authorities, but is not considered sufficient.
In Albania while the legal framework is in place the practical implementation is still insufficient as for
example no to guidelines on the administrative procedures for RES authorization have been
developed as mandated by law. In Montenegro the level of information for the investors is
unbalanced. While some state authorities are easily reached and sufficient information provided,
other required additional efforts for establishing collecting information on conditions, procedures
and costs. In Moldova there are no guidelines on the licensing procedures publicly available for the
investors. Information on the website of EEA is not updated and the list of related laws and
regulations is not complete.
Simplification of administrative procedures/One stop shop
In most Contracting Parties attempts to simplify administrative procedures were observed in the last
years. A one-stop shop was implemented only in Serbia for construction licenses and in Albania for
all licenses and permits required for a project, though some specific licenses and permits are not
integrated in the one-stop shop. In FBiH, RS, Montenegro, Moldova, Ukraine Kosovo*no one-stop
shop exists and none is planned. Montenegro however reduced the number of procedures related
to the construction permits. In Ukraine the government managed to simplify the administrative
procedures, but there is a need for further reduction of timeframes and to introduce a one-stopshop. Also in Kosovo*authorisation procedures have recently been simplified. The only remaining
issue is the necessity for harmonisation of the time limits for others licenses (building, working,
water permits etc.). In Moldova the planned amendment of law on electricity for the purpose of
simplification has not taken place. In RS after passing of the new set of regulations in 2013 and 2014
the administrative procedures have been simplified. In FYR of Macedonia finally there have been
simplifications in the administrative procedures, but there is a need for further reduction of
timeframes. Especially joining competencies where central and local governments are deciding on
the same issue, such as transformation of the land from agricultural (central level) or forest (local
level) into construction land.
Transparent cost related charging
The requirement that administrative charges to be paid are transparent and cost related show a very
mixed picture among the Contracting Parties. In FBiH and RS costs are transparent but information is
not collected in one place, extensive research is needed in order to collect information. They are
often calculated depending on the capacity and not cost related. In Montenegro RES producers are
so far exempted from paying of some administrative charges. Charges are often calculated based on
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the capacity of the plant. Fees in Serbia and Ukraine are transparent but mostly not cost related,
sometimes they are depending on the capacity. In Kosovo* fees are explicitly correlated to the
administration costs through the legal acts imposing these fees. In Albania taking into consideration
that the charges for the several permits are published in the relevant regulatory instruments and/or
websites of the competent bodies, transparency is generally attested, allowing one to assess on
whether these are cost-related. In FYR of Macedonia the fees with applications for authorization/
licenses/ permits for new installations are published on websites of relevant ministries, relevant laws
or sub-laws that govern procedures. The fees are correlated to the administrative costs as the
relevant legal act explicitly states that these are meant to “cover the costs arising from the licensing
procedure”. In Moldova not sufficient transparency could be identified with regard to administrative
fees so as to be able to assess them on their cost-related character.
Simplification for smaller/decentralised projects
In several Contracting Parties there are simplifications for smaller/ decentralized projects. This is
particular the case for FYR of Macedonia, Kosovo* and BIH (FBiH). In some of the other Contracting
Parties are there are some simplifications, for example in Serbia certain small power plants are
exempted from the obligation to obtain energy permit (below 1 MW), some solar collectors on the
existing structures are exempted from obligation to obtain construction permit and certain power
plants are exempted from obligation to obtain energy license. In Montenegro there are simplified
procedures only when certain permits or licenses are not required for some plants, for example
when no authorization is required e.g. with installed capacity up to 20 kW.
2.4.3 RES-E grid integration
CPs are required to implement a number of important measures to facilitate the integration RES-E
into the transmission and distribution grids. These include taking into account RES in the preparation
and execution of development plans for the transmission and distribution grid; rules granting either
priority access or guaranteed access to the grid-system of electricity produced from RES, and also
ensure that transmission system operators (TSOs) give priority to generating installations using RES
when dispatching electricity. The RES Directive also encourages Member States to accelerate
authorisation procedures for grid infrastructure and to provide transparent and non-discriminatory
information and conditions for grid connection and use.
Implementation of grid integration measures are described in sections 2.2.3 and 2.3.3 (legal
transposition of the specific provisions of the RES Directive) and therefore not elaborated further in
this section. All in all, the picture is quite varied with respect to transposition. In practice, the picture
is quite grim, and examples where even though legal provisions are in place these are not being
taken into account in practice. Alongside slow and lengthy administrative procedures, difficulties in
acquiring grid connection, especially when new RES-E plants are located further away from existing
grid infrastructure, together non-transparent grid costs are creating a serious barrier for further
deployment of RES-E.
2.4.4 Guarantee of origin schemes
As described in section 2.3.3, whilst the legal provisions governing the issuance, transfer and
redemption of GoO is partially in place in the CPs, actual implementation is still largely pending in
most CPs. In Montenegro the first GoO was reported to have been issued recently. This section does
not provide further details on GoO implementation given that section 2.3.3 already provides a good
overview of the current status of GoO is CPs.
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2.5 Effectiveness of national legislative measures
This subtask focuses on analysing how effective RES policies in place in the Contracting Parties are in
order to stipulate targeted RES volumes, at present (2013/2014) and in future (2020).
The work within this subtask is closely linked to (and builds on) the assessment of RES progress
conducted in section 3 of this report. It contains two elements: a quantitative and a qualitative
assessment of effectiveness of national legislative measures.
2.5.1 Quantitative assessment: evaluating the effectiveness of currently implemented and
planned policy initiatives
This subtask builds on the quantitative analysis within the assessment of past and future progress,
including a modelling of future RES deployment up to 2020 for each assessed CP that is done by
application of the Green-X model. Thus, for details on assumptions and approach we refer to section
3.3 of this report.
Complementary to the scenarios reflecting currently implemented and planned policy initiatives
(CPI+PPI) an alternative policy scenario is derived, aiming for 2020 RES target achievement across
the whole region and identifying the need for RES cooperation. The difference between these two
conceptually different approaches - i.e. one reflecting currently implemented/planned policies while
the other characterises an ideal policy framework that assures target achievement by 2020 – helps
to identify the necessary steps for achieving given policy targets. Moreover, the impact of prevailing
non-cost barriers 1 is indicated, showing the feasible progress that could be achieved with planned
and implemented policy initiatives, assuming a rapid mitigation of these hurdles. Figure 1 shows the
projected future progress by 2020 (i.e. against the binding 2020 RES target) according to the
assessed Green-X scenarios, indicating by CP the likeliness of delivering as required under the RES
directive. More precisely, this graph illustrates the expected RES deployment in relative terms,
expressing the RES share in gross final energy demand in 2020 by CP.
Of highlight are the following outcomes:
•
•
1
Results indicate that only one CP, namely Montenegro, is expected to reach the given 2020
target with currently implemented and in particular with planned policy measures (new
tendering scheme), considering a prevailing (or more precisely modest mitigation) of noncost barriers (i.e. administrative barriers, deficits related to grid access, etc.) (cf. Green-X
scenario “CPI+PPI max”).
Two other CP, namely Moldova and Serbia, can be added to that list of CPs succeeding in
meeting their 2020 RES targets if measures are taken to remove these barriers in time (cf.
Green-X scenario “CPI+PPI, non-cost barriers mitigated”). The majority of CPs would
however fail in meeting their 2020 RES targets if no additional policy initiatives are
implemented in forthcoming years.
In several countries within Europe and worldwide financial support appears sufficiently high to stimulate deployment of a RES
technology, in practice actual deployment lacks however far behind expectations. This is a consequence of several deficits not directly
linked to the financial support offered which in literature are frequently named “non-economic /non-cost barriers”. These barriers refer to
administrative deficiencies (e.g. a high level of bureaucracy), diminishing spatial planning, problems associated with grid access, possibly
missing local acceptance, or even the non-existence of proper market structures.
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•
•
In an ideal policy world as assumed in the alternative policy case, significant improvements
appear feasible and several other CPs are then well on track in delivering as required: In
addition to Moldova, Montenegro and Serbia, also Albania and Kosovo* would then achieve
and even succeed their given 2020 RES target. Strong progress is also applicable in Bosnia
and Herzegovina, FYR of Macedonia and Ukraine. RES cooperation would then assure target
achievement for these CPs where domestic action appears insufficient.
At first glance surprising appears the decrease of the expected 2020 RES share in
Montenegro and Moldova under alternative policy initiatives. The reason for that is the
increased policy ambition, and consequently rising demand for biomass in other CPs: Still
both CPs, Moldova and Montenegro, remain well on track for RES target achievement but
the increased demand for biomass feedstock from other CPs reduces the availability and use
of biomass feedstock in these countries and, consequently, biomass deployment is also
reduced compared to the CPI+PPI scenario in both Moldova and Montenegro.
CPI+PPI max
CPI+PPI, non-cost barriers mitigated
RES Share vs. RED Target 2020 [%]
Alternative policy initiatives, non-cost barriers mitigated
RED Target
50%
40%
30%
20%
10%
0%
Albania
Bosnia and
Herzegovina
Kosovo*
Moldova
Montenegro
FYR of
Macedonia
Serbia
Ukraine
Figure 1: Expected RES share in 2020 according to distinct policy pathways (Green-X scenarios) vs. 2020 RED target (%).
2.5.2 Qualitative assessment: bottom-up view on target achievement by CP, with a focus on
renewable electricity
The qualitative analysis is based on the quantitative work described above as well as on the
qualitative RES policy assessment (cf. section 3), in particular the assessment of (RES) policies, of grid
integration and of administrative barriers. It aims for identifying by CP the policy needs in terms of
improving the legislative framework and/or removing non-economic barriers. Thus, by country a list
of recommended steps is derived, reflecting the outcomes of an intense stakeholder dialogue.
Albania
Albania plans to meet its 2020 target mainly by hydro power. It seems that, with the exception of
Devolli HP that is being built by the Norwegian Statkraft, the others are in a doubt to be financed by
2020 due to a lack of investors. This means that far less than the about 800 MW of planned large
hydro would be built by 2020. Albania is substantially delayed in taking the support measures
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necessary to reach the targets and generally adapt to the legal framework required by the RES
Directive. Not only does the RES law not fully transpose the Directive, but also adoption of
secondary legislation has been pending for a long time.
Bosnia and Herzegovina
In Bosnia and Herzegovina only one wind park has been built so far, but several are in the pipeline
despite a comparable low level of the FIT. The wind parks are planned mainly by local investors. For
small hydro the level of FIT seems sufficient for a strong expansion.
In BiH (RS) the PPAs could give more security to investors particularly the provisions regarding oneside changing of the agreement and jurisdiction clause. An arbitration clause may be considered as
an alternative, thus ensuring increased security of investors and/or lenders investing significant
funds in RS. Also in BiH(FBiH) it is recommended that models of the PPA and preliminary PPA are
revised in order to be more investors’ friendly. The main barrier is that the preliminary PPA does not
contain obligation of the Operator to conclude the PPA, under what condition and in what time limit.
The provision regarding keeping of the guarantee by the Operator should be amended so that the
guarantee is retained by the RES Operator only in case of serious breach of the agreement by the
investor and subsequent cancellation of the agreement by the Operator. The obligations of the
investors should be clearly and precisely defined. General references to regulation and using of notdefined general terms should be avoided when possible. The arbitration clause may be considered.
The PPA should be very precise about the costs and payments and should guarantee such status for
the duration of the agreement.
Kosovo*
Kosovo* plans to expand large, medium and small hydro as well as wind and to a lower extent solar
and biomass electricity. The largest hydropower plant Zhur was supposed to start being
implemented in 2010 but the process has failed. However projects on the construction and
operation of HPPs with a considerable capacity are going to take place soon because this is part of
the new strategy of the government on energy sector. Despite the existing legal framework
providing FITs for RES production, until 2014 there was no RES generated electricity on the basis of a
FIT support scheme due to difficulties in securing the necessary financing. For wind for example the
Energy Regulatory Office (ERO) has authorised 3 x 30 MW in hydropower projects + 1 x 0.9 MW wind
plant, none of which are implemented.
To combat this, Kosovo* has recently updated its legislation introducing amendments aiming to
provide a more stable investment environment. Because these amendments are very recent, it
remains to be seen whether such initiatives will be enough to promote RES development. If not,
additional measures should also be considered, such as introducing tax exemptions, for which the
general framework already exists, or extending the validity period of guaranteed FITs for longer than
10 years. A sample Power Purchase Agreement (PPA) drafted by the Public Supplier should be
approved from ERO. The approval of such a sample agreement is expected to increase security for
investors. According to the current scheme, PPAs are signed only after the construction of RES
plants, at the time of their commissioning, which makes project funding difficult and needs to be
changed.
FYR of Macedonia
FYR of Macedonia aims to meet its 2020 target mainly by large hydro, small hydro and wind and to a
low extent by solar electricity, biogas and biomass. The draft NREAP mainly targets a 25% RES share
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instead of the 28% as set by the Energy Community. So far only one wind park has been constructed
by the state owned ELEM utility. The government tries to attract foreign investors by collecting more
data on onshore wind potentials. Also it is unlikely that the county will be able to build the planned
large hydro capacities by 2020, suggesting the need for a revision of the NREAP plans even to
achieve only 25%. To meet the 28% target additional efforts beyond what is planned in the NREAP
would be needed. In particular regarding both electricity and heat production in the areas of
biomass and solar energy utilization, with special emphasis on heat production, FYR of Macedonia
could expand more that is realistic under existing legislative, organizational and techno-economic
framework. In order to be achieved, this result calls for an additional set of measures that will
converge towards the supportive environment for additional use of solar power and biomass.
Moldova
The remuneration scheme for RE-E currently applicable in Moldova is not sufficient to safeguard
long-term security and reliability, as it is not based on central planning. The new auction system,
which shall replace the currently applicable one, addresses this issue to a certain extent, as for each
tender a certain cap of capacity will be provided, although a more general, long-term planning
should also be in place in parallel. The draft new RES law is unclear in several respects, such as with
regard to the intended frequency of such auctions, their territorial scope of application (Moldovawide or restricted in certain regions), whether each auction will be addressed only to a specific
technology etc. Moreover the lack of a market operator is striking. ANRE is the one so far to manage
the compensation scheme and assumes all responsibilities in this regard. In order for Moldova to
develop a modern regulatory framework in compliance with the Energy acquis, ANRE should be
restricted to its regulatory duties and a separate market operator should be established. In this
regard, the draft new RES law provides that a single supplier will be established, which will be
appointed by the Government and will be the entity to purchase RES electricity from eligible
producers.
Montenegro
Montenegro plans to meet its 2020 RES target mainly by an additional deployment of hydro power
and wind power (151.2 MW) technologies. Two wind parks, Mozur (46MW) and Krnovo (72 MW)
have received the construction permits by the end of the last year, meaning that the country seems
to be on track to meet its wind targets. The construction permit provides the deadline for
finalization of the construction within 2 years. In 2014 also 10 small hydro power plans at 5 sites
(totaling 23,324 MW) were granted concessions. The Montenegrin NREAP doesn’t envisage the two
planned large hydro power plants, Komarnica and Moraca to be part of the 2020 target
achievement.
However the legal framework could be improved. The sample agreement on conditions for
concluding a PPA does not provide sufficient security for the investors that the PPA shall be signed
when the construction of the plant is finalized. It also does not provide security instruments for
payment of the purchased electricity.
Serbia
Serbia plans to meet its 2020 RES target mainly by large and small hydro power and wind. There is
however no wind farm in Serbia so far (except the very small 500 kW plant, Tutin Devre) witch
obtained operational permit. According to stakeholders the FIT is sufficient in Serbia. The main
barriers are administrative ones. The FIT for biomass is, according to the opinion of the industry, not
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so encouraging. There is an issue of capacity limitation as the capacity for solar has already been
fulfilled. Due to the fact that there is a temporary privileged producer status, which reserves the
capacity, it may be lost if the project is not commenced or finalized within a time limit, the Ministry
issues once a year a list with free capacities for wind and solar. It seems that securing of its duration
and financing should be dealt with. The new PPA should deal with issues such as instruments for
securing of payments, amounts of FIT and its changes and support measures during probation period
of operation of the plant that are significant for the attractiveness of the investments.
Ukraine
Rather high FITs and tax benefits for RES developers in Ukraine, established by the legislation in
2009-2013 stimulated a strong development of the renewable energy sector in Ukraine, especially
solar and wind electricity generation. However, the remaining local content requirement (50% of
equipment, materials, component parts and/or works of Ukrainian origin in the construction of
installations generating energy from RES commissioned after 1 July 2014 and 1 January 2015) to be
met by electricity producers from RES in order to qualify for the FIT, the cancellation of a number of
tax benefits in 2014-2015, NERC's failure to comply with a legislative requirement for the monthly
revision (indexation) of FIT based on inflation and the increased EUR-UAH currency exchange rate
during August-December 2014, together with the following reduction of FIT for operating RES
producers and an increased country risk, deteriorated the investment climate in the country.
Given that the NREAP sets out ambitious goals to be achieved mainly by means of the upgrade and
restoration of existing capacities, improvement of technologies, building and commissioning of new
capacities, all requiring significant investments, it is important to improve national measures on
support schemes that would sustain Ukraine’s attractiveness for foreign and domestic investors.
2.6 Viability of national legislative measures
Within this subtask we discuss the economic viability, in other words cost-effectiveness of RES policies in
place and indicate, where adequate, proposals for modifications in order to maintain consumer / societal
acceptance for financing the required RES expansion.
Similar to above, the work within this subtask builds on the quantitative assessment of RES progress (cf.
section 3 of this report). The scenarios of future RES deployment under currently implemented/planned
RES policy initiatives (CPI+PPI) provide the quantitative basis for the assessment of cost-effectiveness.
Complementary to them, an alternative policy scenario is derived, aiming for 2020 RES target
achievement across the whole region. Doing so, we aim for identifying the needs in terms of improving
the viability of legislative measures.
In order to clarify on the need for improving the viability of implemented or planned policy initiatives a
comparison of policy costs, expressed by the need for financial support, and the triggered RES deployment
appears adequate. Thus, Figure 2 allows for doing so, expressing energy output from (up) and required
support for (bottom) new domestic RES installations (2015 to 2020) by 2020 for all assessed cases – i.e.
currently implemented and planned policy initiatives (CPI+PPI), with or without mitigation of non-cost
barriers as well as alternative policy initiatives that allow for an achievement of given 2020 RES targets
across all CPs and as discussed above (cf. section 2.5). The following observations appear of relevance:
•
It can be concluded that according to the model-based assessment only one CP shows deficits
with respect to the viability of planned/implemented RES support, that is Moldova. For Moldova,
RES generation is modest under CPI+PPI whereas support expenditures are highest among all
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assessed cases. Here the newly planned tendering scheme for RES-E may require further
detailing and elaboration since otherwise, as concluded from the modelling exercise, a
combination of technology-neutral tenders and ambitious deployment targets may lead to an
overheating of the RES market that is expected to be costly at the end.
More specifically, the information available on the newly planned tendering scheme in Moldova
at the time of computing modelling scenarios (i.e. as of April 2015) was that Moldova would aim
for introducing quite ambitious (compared to past progress) tenders for RES-E with a probably
technology-neutral approach – i.e. that the tendering process would not be technology-specific
or limited to certain technologies like wind power. Thus, within the modelling exercise it turned
out that more expensive options than wind power would be the price setting ones. In principle,
the expected shortage of sufficient supply on the RES market may consequently lead to strategic
investor behaviour and in last consequences high bidding prices and an increase of related
support expenditures. This effect, specifically the shortage of sufficient RES supply, is reduced if
non-cost barriers would be mitigated well in time and consequently RES deployment could be
increased. Moreover, an alternative policy concept that offers targeted technology-specific
incentives for the various renewables would bring the cost burden further done since then
incentive levels can then be targeted to the specific needs. According to latest information from
Moldova it appears that these recommendations are partly already considered in the detailing of
their planned tendering scheme.
•
•
•
For all other CPs currently implemented policy initiatives appear cost-effective. Taking into
account the findings discussed with respect to the effectiveness of policy measures (cf. Figure 1)
it has to be stated that currently implemented and planned initiatives are however insufficient
for achieving the targeted RES volumes. Thus, improvements in terms of effectiveness appear
necessary – for the case of Albania this means for example to offer support not only to
hydropower but also to other promising RES technologies like wind, solar or biomass. Generally,
applying targeted incentives tailored to the specific needs can be recommended, combined with
a rapid removal of prevailing non-cost barriers.
Effectiveness and viability of policy initiatives is also affected by non-cost barriers that limit the
uptake of RES. A removal of such barriers is generally recommended since this represents a
necessary preconditions for a faster deployment of affected RES technologies and consequently
the achievement of given policy targets. The impact of a mitigation of such hurdles on viability of
policy initiatives in assessed CPs depends on how individual technologies are affected:
o If on the one hand a low-cost technology like wind onshore faces significant noncost barriers at present, a mitigation of such constraints would allow for a fast
expansion of this technology (assuming sufficient support is provided) and in turn
increase both effectiveness and viability of policy initiatives.
o If on the other hand in a country sufficient financial support is offered to a
comparatively costly technology like PV a mitigation of related non-cost barriers
would increase both deployment and related support expenditures – at aggregated
level (i.e. for RES in total this would in consequence lead to a decrease of viability
(compare e.g. both CPI+PPI scenarios (with and w/o mitigation of non-cost barriers)
for Bosnia and Herzegovina, Serbia or Ukraine).
Applying strong incentives for RES that would – if combined with RES cooperation across CPs
– allow for 2020 RES target achievement has an impact on the viability of policy measures.
As can be seen in Figure 2 generally an increase of both RES deployment and related support
expenditures can be expected when moving to alternative policy initiatives (compare
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“CPI+PPI” and “alternative policy initiatives” under mitigated non-cost barriers). Exceptions
from this general rule are Montenegro and Moldova due to specifics in the case of Moldova
as discussed above and the rising demand for biomass from other CPs and, consequently,
the slight decline of domestic biomass use in both CPs. 2 Thus, while effectiveness with
respect to the triggering of RES expansion increases, cost-effectiveness would for example
decline in Albania, Kosovo*, Serbia and Ukraine due to enhanced promotion of all types of
RES technologies, incl. low-cost and more expensive RES options.
Energy production from new RES
installations (2015 to 2020) in 2020
[GWh]
35.000
30.000
CPI+PPI max
CPI+PPI, non-cost barriers mitigated
Alternative policy initiatives, non-cost barriers mitigated
25.000
20.000
15.000
10.000
5.000
0
Albania
Yearly support expenditures for new RES
installations (2015 to 2020) in 2020
[million €]
350
300
Bosnia and Kosovo*
Herzegovina
Moldova Montenegro
FYR of
Macedonia
Serbia
Ukraine
Serbia
Ukraine
CPI+PPI max
CPI+PPI, non-cost barriers mitigated
Alternative policy initiatives, non-cost barriers mitigated
250
200
150
100
50
0
Albania
Bosnia and
Herzegovina
Kosovo*
Moldova Montenegro
FYR of
Macedonia
Figure 2: Comparison of energy output from (up) and required support for (bottom) new RES installations (2015 to 2020)
by 2020.
2
As stated previously (cf. section 2.5.1), at first glance surprising appears the decrease of the expected 2020 RES share in Montenegro
and Moldova under alternative policy initiatives. The reason for that is the increased policy ambition, and consequently rising demand for
biomass in other CPs: Still both CPs, Moldova and Montenegro, remain well on track for RES target achievement but the increased
demand for biomass feedstock from other CPs reduces the availability and use of biomass feedstock in these countries and,
consequently, biomass deployment is also reduced compared to the CPI+PPI scenario in both Moldova and Montenegro
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A closer look at the electricity sector: Implications on consumer prices
In order to give an implication how support for renewables translates into energy-related
expenditures from a societal perspective, we take subsequently a closer look at the electricity sector
and how support for renewable electricity may be transferred on to end user.
As starting point, Figure 3 shows by CP the average (2015-2020) total remuneration for new
renewable installations in the electricity according to the Green-X scenarios as discussed above,
expressed in specific terms (i.e. € per MWh electricity produced). For comparison we include in this
depiction also the underlying assumptions on the development of wholesale electricity prices,
representing the default level of revenues for an electricity producer (in the absence of dedicated
support). Thus, as explained in further detail in Box 1 net support for RES-E is consequently defined
as the difference between the scenario-specific total remuneration and wholesale electricity prices
(grey bars).
Box 1: A short introduction: Support and Remuneration
Support incentives may provide total payments per kWh of electricity (e.g. fixed feed-in tariffs) or offer
payments on top of the electricity wholesale-market price (e.g. quotas with TGCs or feed-in premiums). In both
cases support payments are often limited to a certain period of time, i.e. the guaranteed duration of support.
Remuneration represents the total income of a power producer, i.e. from selling electricity on the wholesale
electricity market and/or from support incentives. For example the remuneration level contains the electricity
wholesale-market price if the support payments expire after their guaranteed duration, but the power plant
continues in operation.
The difference between total remuneration level and wholesale-market prices determines the required net
support, i.e. the amount of money that finally has to be borne by the consumer / the society. Thus, support
expenditures are consequently the sum of all financial incentives, i.e. the (net) support, offered to renewable
producers over a specific period of time – typically accounted on a yearly basis.
average wholesale electricity price
CPI+PPI max
CPI+PPI, non-cost barriers mitigated
Alternative policy initiatives, non-cost barriers mitigated
Total remuneration for new RES-E
installations (on average 2015-2020)
[€/MWhRES]
180
160
140
120
100
80
60
40
20
0
Albania
Bosnia and
Herzegovina
Kosovo*
Moldova Montenegro
FYR of
Macedonia
Serbia
Ukraine
Figure 3: Total remuneration for new RES-E installations on average in the period 2015 to 2020, compared to estimated
average wholesale electricity prices.
If support expenditures for all RES-E installations are summed up on a yearly basis and divided by
electricity consumption, the specific burden for the consumer can be expressed. This is done in
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Support expenditures for total RES-E on
average (2015-2020), expressed as premium
per MWh electricity consumed
[€/MWhDEMAND]
Figure 4, indicating support expenditures for all renewables in the power sector on average in the
period 2015 to 2020, expressed as premium per unit of electricity consumed (i.e. € per MWh of
electricity demand).
CPI+PPI max
CPI+PPI, non-cost barriers mitigated
Alternative policy initiatives, non-cost barriers mitigated
8
7
6
5
4
3
2
1
0
Albania
Bosnia and Kosovo*
Herzegovina
Moldova Montenegro
FYR of
Macedonia
Serbia
Ukraine
Figure 4: Support expenditures for total RES-E on average in the period 2015 to 2020, expressed as premium per unit of
electricity consumed.
One can see that due to the overall low amount of financially supported renewables, the consumer
burden is expected to remain comparatively low – i.e. on average around a level of 0.5 to 1.6 € per
MWh demand. An exception from that general observation is Moldova where comparatively high
support for renewables can be expected according to CPI and CPI+PPI, meaning if currently
implemented and planned policy initiatives are kept as intended.
One important remark appears necessary: The low level of support expenditures as expressed and
discussed above can only be expected if wholesale prices are transparently transferred to end user,
meaning that actual costs are passed on to consumer.
2.7 Recommendations to improve national legislative measures and policy settings
Depending on the particular requirements set out in the RES Directive, the CPs demonstrate
different levels of compliance with regard to some of the obligations they need to implement, while
in some other aspects no vast differences are identified. Respectively, recommendations on
necessary improvements of national legislative and regulatory measures are in some fields
specifically adapted to the particular situation of each CP while in some other fields
recommendations are quite similar.
In general, CPs should proceed without delay to the pending amendments to existing main
legislative instruments (RES laws, energy laws, electricity laws etc.) or to adoption of new such acts
currently in draft form. Adoption of such acts should be immediately succeeded by the issuance of
respective implementing regulations. It goes without saying that the adoption of NREAPs in the CPs,
which did not do so, is of first priority.
Regarding RES-E, emphasis in all CPs should be put on intensifying efforts for simplification of
administrative procedures. The establishment of one-stop shops appears to be the best option
allowing for better coordination of different bodies and more efficient identification and overcoming
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of administrative barriers. A step-by step approach towards a fully operational one-stop shop could
be taken. For example a step-by step approach could include authorisation of small projects or a
certain set of licenses. Also very important is that the model PPAs are prepared in cooperation with
investors and financiers particularly in regard to satisfying their need for security that after the
finalising of the power plant construction they will receive the support and the benefits existing
before beginning of the construction. Properly addressing RES integration in the network
development planning and expansion of existing infrastructure so as to facilitate integration of new
capacities needs further improvements in most CPs. Dissemination of information to interested
parties is also an issue which needs to be improved in most CPs.
As regards the RES-H&C sector, more intensive efforts are required in most CPs to adopt the
necessary measures, including setting up support schemes and implementing minimum levels for
the use of RES in buildings. This will require in some cases the adoption of primary legislation (mostly
already in draft form) in this regard while in other cases issuance of secondary legislation is
necessary for implementation purposes.
Furthermore, for the RES-T sector, a common priority for all CPs is to accelerate procedures of
adoption of all legislative and regulatory acts necessary for introducing sustainability criteria and
verification schemes for biofuels, because the delay in this regard may put at risk compliance with
the targets in this sector. Clear regulation of reporting requirements, establishment of competent
supervisory body and provision of guidance to the parties involved are some of the main issues to be
put forward by the new legislation.
In the following, we present some CP specific recommendations:
•
•
Albania’s first priority would be the adoption of the NREAP. Moreover, in relation to the
promotion of RES-E Albania should swiftly proceed to further improvement of the RES law,
now that the new power sector law has been finally adopted, and then proceed without
delay to the adoption of necessary secondary legislation. In particular, the Government and
ERE shall ensure prompt approval of support schemes for all RES technologies other than
SHHP. Necessary funds must be ensured for this purpose, considering the financial situation
of the local energy market. Emphasis shall be also put on the establishment, publication and
observance by the network operators of generally applicable, transparent, standard rules on
the connection requirements and costs bearing and sharing. Sufficient monitoring will be
indispensable in this regard. A new regulation on GoO implementing the provisions of the
RES law should be adopted replacing the existing one of 2007. More consideration shall be
given also to introducing RES-H&C support measures. Considering that the RES law only
marginally refers to this sector, issues relating to promotion of the use of RES for H&C
purposes should be properly addressed in the expected new energy efficiency law and the
relevant secondary legislation to follow. Establishment of the Energy Efficiency Fund would
constitute a positive step in this direction. Furthermore, as regards the RES-T sector, Albania
must adopt the legal amendments necessary for introduction of sustainability criteria and
verification schemes, as soon as possible.
BiH (at state level) needs to get its act together and adopt a unified NREAP. Transmission
system rules should be adjusted for RES connections and provide for bearing and sharing of
costs rules. In BiH (entity FBiH) significant regulatory and implementation improvement is
needed in order to simplify procedures and provide for clear allocation of competences on
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•
•
different levels. Establishment of a one-stop-shop would be more than welcome although
even the establishment of a one-stop information center would tremendously help the
procedures. Raising the awareness of the authorities to quickly and effectively assist
investors throughout the application procedure is needed. Preparing of detailed investors
guidelines in English with all necessary information, including costs and timeframe, which
would be regularly updated and available on the internet pages is recommended. Grid
development procedures should be improved by introduction of sharing rules for new
connections which would not be regulated only in bilateral contracts after finalisation of
construction. Model preliminary PPA should be adopted in a more bankable manner. This
may include securities that after construction of the plant a PPA would be concluded for the
guaranteed FITs and quotas secured, clarification of some vague terms, review of the
cancellation provisions and jurisdiction clause. Both BiH entities should consider providing
the security that the PPA which will be signed after the construction does not differ from the
PPA model reviewed and agreed by the investor at the time of signing of the preliminary
PPA. BiH (entity RS) should particularly improve information and promotion of RES, prepare
guidelines for investors in English and organise an one-stop information point for investors
which would be able to provide all necessary information including costs and timeframe for
the administrative procedures as well as to assist them when practicable. BiH (both entities)
GoO registers should be established and become operational. BiH (both entities) need to
significantly improve compliance with the RES Directive in regard to RES-H&C and in RES-T
including regulation of support to RES-H&C, cogeneration, blending obligations,
establishment of certification system and sustainability verification.
While Kosovo* has made substantive progress in transposing the RES Directive in the RES-E
sector, emphasis shall be put primarily on efficient practical implementation. Because the
updating of its legislation with a view to provide a more stable investment environment is
very recent, sometime will be necessary to see whether such initiatives will be enough to
promote RES development. If not, additional measures should also be considered, such as
introducing tax exemptions, for which the general framework already exists, or extending
the validity period of guaranteed FITs for longer than 10 years. Approval of a sample PPA
would increase security for investors. Simplification efforts in relation to the administrative
procedures should continue further: especially harmonisation of relevant laws and
procedures applicable to different permits (e.g. rights of use of land and forests, permits for
the use of waters) is necessary. Moreover, in order to offer a secure investment
environment, different time frames provided in the legislation should be adjusted. As
regards RES integration, in order to ensure envisaged promotion of RES, Kosovo* will need
to invest in necessary network development which will allow integration of new capacities.
Despite the existence of a mostly compliant regulatory framework on GoO, practical
implementation should also be ensured. In the RES-H&C sector the set of legislative and
regulatory acts which are currently in draft form must be adopted without delay. Financing
barriers could be overcome to a certain extent through the establishment of the Energy
Efficiency Fund. As regards the RES-T sector, Kosovo* must adopt swiftly the legal acts
(Administrative Instruction on biofuel use, law on trade with petroleum) introducing
sustainability criteria and a relevant certification scheme.
FYR of Macedonia should adopt an NREAP as a first priority. The new energy law, which
should be the main instrument to transpose the RES Directive, must also be adopted the
soonest possible. Efforts for further simplification of authorisation procedures must
continue particularly by shortening deadlines and reducing unnecessary steps; this could
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•
•
consist in excluding certain government bodies from some procedures, e.g. in connection
with urban plans and land property issues, as well as in genera shortening the deadlines for
obtaining several licenses and permits, such as construction permit, energy license, granting
the status of preferential producer etc. The establishment of a one-stop shop would be an
efficient measure to combat existing involvement of too many authorities. Moreover, it
must be ensured that the amendments performed to the transmission and distribution
network codes will be implemented in practice. This requires compliant conduct by the
competent network operators and sufficient supervision by the energy regulator ERC. Proper
planning on necessary grid expansion is also necessary for the efficient integration of new
capacities from different RES technologies. Despite the existence of a mostly compliant
regulatory framework on GoO, practical implementation should also be ensured; for this
purpose, abolishment of existing restrictions regarding the scope of application of GoO
should be considered. In the RES-H&C sector, after having adopted the main legislative and
regulatory instruments, emphasis should be put on ensuring proper implementation by the
competent central and local authorities. Establishment of the Energy Efficiency Fund for the
purpose of financing support measures in this field would also constitute a positive
development. As regards the RES-T sector FYR of Macedonia must accelerate procedures of
adoption of the new law on biofuels and necessary by-laws in order to make up for the delay
of compliance with its relevant obligations.
Moldova has a very clear first priority: adoption of the new RES law shall serve as a trigger to
finally direct RES development to the right channels. However, voting of the new RES law
should be regarded only as a starting point, because intensive efforts will be necessary after
its adoption for the issuance of all necessary by-laws and for organising all practical aspects
relating to implementation. Simplification of licensing procedures, proper organisation and
implementation of the new auctioning scheme, establishment of a market operator, and
observance of information obligations by competent authorities and operators are only
some examples of measures to follow. The establishment of a one-stop shop would also be
in the case of Moldova an efficient measure to combat involvement of too many authorities.
A proper consideration of particularities of individual RES technologies and an introduction
of simplified procedures for small-scale projects are issues not properly addressed in the
draft RES law and should attract some attention. Furthermore, RES integration must be
appropriately taken into consideration in network development planning. Efficient
monitoring is also required to ensure that the network operators meet in practice the
requirements of the law as regards setting up and observing transparent and objective rules
on connection requirements. Provisions of the draft new RES law on GoO should ensure
compliance with the RES Directive, which is not fully the case in the existing version thereof,
and respective radical amendment of the existing regulatory framework on GoO will be also
necessary. With regard to RES-H&C a significant level of progress is generally attested due to
the adoption of a series of legislative acts in 2014, but further adoption of by-laws will be
necessary for practical implementation. In the RES-T sector, after adoption of the new RES
law which includes detailed provisions in this regard, implementing regulations will need to
be immediately adopted.
Montenegro’s regulation should be significantly improved in regard to RES-E procedures and
information and promotion activities. Training of employees dealing with RES is
recommended as well as establishment of a one-stop shop or at least of an information
centre. Grid connection rules should be improved as well as information on costs and their
calculations and time frame for connection. The RES-H&C sector should be regulated in
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•
•
accordance with RES-D as the new energy efficiency law passed last December is still not in
full compliance with the RES-D. For example there is no obligation to use the minimum level
of energy from RES. In the RES-T sector blending obligations, establishment of certification
system and sustainability verification should be introduced.
Serbia should continue implementation of the simplified licensing procedures and improve
dissemination of information to potential investors available in English. The new model PPA
should be drafted in accordance with the new Law on Energy. Grid connection rules should
include sharing of costs provisions. The implementation of the GoO scheme should be
accelerated. Measures for support of H&C should be introduced at least as a framework on
the State level, which would include a framework for implementation, leaving details for the
self-government units. In the RES-T sector, blending obligations, the establishment of a
certification system and sustainability verification should be introduced.
Ukraine’s action plan for the implementation of the RES-D is very modest and should be
revised. More consistency is needed in the RES-E support schemes and more transparent
provisions, the period after 2030 should be planned and regulated. Streamlined
administrative procedures and transparent cost-related charges should be regulated as well
as transparent and cost related grid connection rules, which should also include cost sharing
rules for new applicants. Regarding the model PPA it is recommended to review the PPA
scheme as the current provide no security for the investment before finalisation of the
construction. Although now the law provides for compulsory purchase of all RES produced
electricity, the law may change, while the investor relayed on its provision without any
contractual obligation and guarantee by the purchaser or the state. Regarding GoO, the
issue of the authority which will be in charge for issuing GoOs and for supervision should be
resolved. Provisions for the compliance of H&C as well as RES-T blending obligation,
establishment of certification system and sustainability verification should also be
introduced.
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3 Quantitative assessment of progress in the share of RES in
Contracting Parties
3.1 Introduction
(c) (RES) Policy assessment
(d) Assessing guarantees of origin
(e) Assessing grid integration
(f) Assessing administrative barriers
(a) Assessment of future progress
(a) Assessment of past progress
This task aims for a detailed analysis of progress in renewable energy at CP and at aggregated level,
at present and in future. As illustrated in Figure 5, the work is clustered into six subtasks, including a
thorough quantitative (subtask (a) and (b)) and a complementary qualitative assessment (subtasks
(c) to (f)).
Figure 5: Interplay of the six subtasks of task 2.1 (assessment of progress in renewable energy)
Below we summarise the approach and present draft outcomes of the work undertaken during the
interim stage of this project, starting with the quantitative assessment of past and future progress.
3.2 Assessment of past progress (towards 2012/2013 interim targets for RES)
Subtask (a) is looking back, assessing the progress of RES deployment in each of the Contracting
Parties in 2012 and 2013 towards the 2012/2013 interim targets for RES in line with the indicative
trajectory laid down in Annex I part B of the RES Directive. The indicative trajectory is in this respect
defined as an average share of energy from renewable sources in the gross final energy consumption
(GFEC) for the two-year period 2011 to 2012.
3.2.1 Method of approach
The assessment is based on energy balances of 2011, 2012 and 2013, compiled according to
EUROSTAT methodology. This comprises data reported in the CP’s Progress Reports; complemented
by energy statistics of the International Energy Agency (IEA) and alternative data sources applicable
at CP level, such as EUROSTAT data for countries in accession process available on EUROSTAT
database (e.g. for Albania, FYR of Macedonia, Montenegro, Serbia) and data provided by the ECS for
the year 2013. In addition to the data collection on past actual RES developments the work also
includes to take stock of the planned RES expansion trajectories per technology and energy
scenarios of the (draft) NREAPs in the Energy Community CPs. This serves as basis for the evaluation
of past progress in achieving interim targets as set out, on the one hand, in the RES Directive and, on
the other hand, in the NREAPs: the mandatory 2011/2012 minimum trajectory and their nonmandatory 2012 and 2013 NREAP target.
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Please note further that the detailed quantitative assessment is complemented by qualitative
explanations of observed deviation from target based on the assessment of Contracting Parties
policies and measures, electricity grid development and administrative procedures carried out in
subtasks (c), (e) and (f).
3.2.2 Technology and sectorial coverage (related to subtask (a) and (b)):
Within the assessment of past progress (as well as in the model-based analysis of expected future
progress) overall RES deployment will be assessed as well as details on sector and technology level.
Table 7 indicates the proposed technology split used therein.
Table 7: Technology and sectorial split within the quantitative assessment
RES-Electricity
RES-Heating & Cooling
Biofuels for transport
Offshore wind
Solar thermal
Biomass (i.e. solid and liquid, incl.
biowaste)
First generation biofuels
Onshore wind
Biomass (i.e. solid and liquid, incl.
biowaste)
Biogas
Photovoltaics
Second generation biofuels
Biogas
Heat pumps
Geothermal
Hydro (incl. large- and small-scale)
Geothermal
Concentrated solar power
Tide, wave and ocean energy
3.2.3 Results
Next we summarise interim outcomes of the assessment of past RES progress, starting with a crosscountry comparison of overall RES deployment and with details on the RES deployment on sectorand technology level. For both deployment as well as target achievement is indicated in relative and
absolute terms. In relative terms this represents the share of RES in gross final energy consumption
(GFEC), which serves as the central indicator for a target achievement including binding interim
targets and the target share in 2020 defined in the RES directive. Later on, country specific results
are illustrated, indicating historic developments and the status quo of RES deployment.
Underlying statistical data and constraints
The RES targets are defined as the relative RES share of the GFEC. It is important to mention, that
the electricity generation of small-scale and large-scale hydro power plants is normalised, taking the
generation and capacity data over the last 15 years into account. For this step of normalisation of
the hydropower electricity generation, data of the Energy Information Administration (EIA) for
installed hydropower capacities was used (EIA, 2015). All other historic energy data was obtained
from the International Energy Agency (IEA, 2015), EUROSTAT (EUROSTAT, 2015) and the Energy
Community Secretariat (ECS, 2014; 2015). As of this date, only the datasets provided by EUROSTAT
were available up to the year of 2013. EIA and IEA data was obtainable till the year 2012. To
complete the missing energy balances and hydro power capacity data for the year 2013, additional
data was provided by the ECS (ECS, 2014; 2015). Within this chapter actual deployment for 2012 and
2013 as well as projected deployment for 2020 is compared to the CPs NREAPs. This comparison is
also included for the draft NREAPs of Albania and FYR of Macedonia. As there is no NREAP for Bosnia
and Herzegovina available, it is not possible to compare actual with planned deployment.
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As a further modification regarding the GFEC the biomass data, accounting for solid biomass used for
heating purposes, corrected by the ECS for all CPs and the year 2009 is used in the report 3. This
correction of the official national statistics of the CPs was applied for the official RES target
calculation for the decision D/2012/04/MC-EnC, Article 4, according to the renewable directive
2009/28/EC.
To start with, the background of the biomass data modifications is explained. Figure 7 shows the
median of the overall 2011/2012 RES shares. Two bars are included per CP. The light blue bar shows
the median overall RES share of the GFEC with respect to the datasets provided by the IEA and
EUROSTAT including normalised hydropower data, which were calculated using historical
hydropower capacity data as of the EIA data service. The exact corresponding numbers can be found
in Table 9. The dark blue bar shows the median 2011/2012 RES shares including the modifications
applied by the ECS to the solid biomass data used in the heating sector, as it was done for calculating
the official RES targets for 2020 or all CPs (DIRECTIVE 2009-28-EC; Decision 2012-04-MC-EnC).
For Kosovo* no modification of the solid biomass data was applied by the ECS. For Albania the
biomass used in the heating sector is just modified by a plus of 3 ktoe. Serbia and Montenegro
updated its reported solid biomass use for heating purposes retrospectively. As the solid biomass
consumption data provided by the IEA in 2015 for the year 2009 for Serbia is of the exact same
dimension as the modified data by the ENC, no more modifications were needed. The solid biomass
consumption data of Montenegro provided by EUROSTAT and IEA in 2015 shows amounts exceeding
the consumption data of the year 2009 used for calculating the official RES targets for 2020. Please
note that the specific case of retrospective changes in data on solid biomass use in the heating and
cooling sector in Montenegro is discussed in detail in Box 2.
The actual solid biomass data provided by the IEA for Bosnia and Herzegovina, Moldova, FYR of
Macedonia and the Ukraine for the year 2009 showed the same deviations as observed by the ECS in
2012. The energy balances provided by the ECS for the year 2013 showed additional corrections
made for Bosnia and Herzegovina and Moldova. A correction of the same dimension as done by the
ECS was applied to the historical data in this report for the year 2011 and 2012 for Bosnia and
Herzegovina and Moldova and additionally for the year of 2013 for the FYR of Macedonia and the
Ukraine. The modified data is only discussed and shown separately within Figure 7 and Figure 8.
Successively, the modifications for solid biomass consumption are always included in the data
presented for the year 2012 and 2013.
3
As this data was not used for the interim report, some deviations of the historic GFEC, total and relative RES deployment and the
regarding projections by the CPs and their NREAPs in this report can be explained.
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Box 2: Montenegro’s retrospective change of the statistical record on solid biomass use in heating & cooling.
Montenegro changed its statistical record on (past) solid biomass consumption in the heating and cooling
sector retrospectively. This modification was based on an assessment done for the study “Wood fuel
consumption in 2011 in Montenegro - New energy balances for wood fuels” by the Statistical Office of
Montenegro published in 2013 (Statistical Office of Montenegro, 2013). A comparison of recent statistical data
(from EUROSTAT) on solid biomass consumption to the data as reported originally in Montenegro’s NREAP
points out that recent EUROSTAT data shows a quantity consumed that is 3.6 times higher than the default
data as reported in the NREAP (Table 8). The correction of the statistical record on biomass use also has a
significant impact on (past) overall RES consumption: The RES share in GFEC for the year 2009 would
consequently rise from 26.3% to 39.0% if the recent actual solid biomass data were accounted for. If this
correction in absolute numbers were also applied to the planned (NREAP) trajectories up to the year 2020, the
2020 RES share would increase from 33% to 42.5%.
Table 8: Default and modified (corrected) data on past (2009) and planned 2020 solid biomass use for heating & cooling
(BM-H) (NREAP of Montenegro; EUROSTAT, 2015).
Historical NREAP
data for trajectory Unit
2009
for 2020
Indicator
Default solid biomass consumption in heating & cooling according to NREAP
59.7
108.0
ktoe
Modified solid biomass consumption in heating & cooling according to recent EUROSTAT data
224.6
272.9
ktoe
Default RES share 2009 and mandatory 2020 RES target
26.3%
33.0%
%
Modified RES shares in 2009 and 2020 - with correction for increased biomass consumption
39.0%
42.5%
%
Figure 6 depicts the discussed changes in absolute solid biomass consumption in the heating and
cooling sector (blue bars on the left-hand side) and the related impact on overall RES deployment,
illustrating the change of RES shares in GFEC (red lines and dots on the right-hand side). What can be
seen is that with the corrected solid biomass data the RED target share would have already been
fulfilled in the year 2009. A correct way forward may be to revise and adapt the target calculation for
Montenegro in accordance with the new data on biomass consumption.
250
RES share in GFEC [%]
BM-H consumption [ktoe]
300
200
150
100
50
0
2009
2020
50%
45%
40%
35%
30%
25%
20%
15%
10%
5%
0%
2009
2020
Solid biomass use for heating as of NREAP
RES share as of NREAP
Solid biomass use including correction
RES share including correction
Figure 6: Default and modified (corrected) data on past (2009) and planned 2020 solid biomass use in heating & cooling
(BM-H) (left) and the related impact on overall RES deployment (right), indicating default and modified
(corrected) RES shares in 2009 and in 2020 (NREAP of Montenegro; EUROSTAT, 2015).
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Overall RES deployment
Table 9 and Figure 7 show the median RES shares of GFEC of the years 2011/2012. This is compared
to the indicative trajectory set out in part B of Annex I of DIRECTIVE 2009/28/EC, in advance referred
to as renewable directive or RED. As the decision 2012/04/MC of the ministerial council of the
Energy Community dates back to the 18th of October 2012, the RED minimum trajectory for
2011/2012 sets a relatively strict interim target. This can be seen, when this target is compared to
the interim targets set by the CPs NREAPs and draft NREAPs which is shown in Figure 9 or in Table
10. All interim targets of the NREAPs for 2012 show a lower percentage target than the RED
Minimum Trajectory for 2011/2012. Only Montenegro achieved its RED target for 2011/2012 with its
retrospectively changed biomass data in the heating sector, which is today more than 3.6 times as
high, as the solid biomass data reported in its NREAP.
Table 9: The median RES share in gross final energy demand by 2011/2012 compared to the RED minimum trajectory.
(EIA, 2015; EUROSTAT, 2015; IEA, 2015; DIRECTIVE 2009-28-EC)
The median RES share in
gross final energy demand
by 2011/2012
Contracting Party
Albania
Bosnia and Herzegovina
Kosovo*
Moldova
Montenegro
FYR of Macedonia
Serbia
RES Share vs. RED minimum Trajectory
2011/2012 [%]
Ukraine
45%
RES share as of EIA, EUROSTAT
and IEA data
Median Median 11/12
2011/2012
modified
[%]
[%]
31,5%
31,6%
17,9%
35,1%
18,3%
18,3%
3,5%
10,1%
41,4%
41,4%
15,4%
22,2%
19,3%
19,3%
2,9%
5,8%
Median of 2011/2012 Shares
RED minimum trajectory 2011/12
Percentage points deviation of RED
minimum trajectory
RED minimum
trajectory
Median
2011/2012
[%]
32,6%
35,2%
20,1%
12,9%
27,6%
23,1%
22,4%
6,6%
Median
2011/2012
[%]
-1,1%
-17,3%
-1,8%
-9,4%
13,8%
-7,7%
-3,0%
-3,7%
Median 11/12
modified
[%]
-0,9%
-0,1%
-1,8%
-2,9%
13,8%
-0,9%
-3,0%
-0,8%
Median of 2011/2012 Shares (modified BM-H Data)
RED Target 2020
40%
35%
30%
25%
20%
15%
10%
5%
0%
Albania
Bosnia and
Herzegovina
Kosovo*
Moldova
Montenegro
FYR of
Macedonia
Serbia
Ukraine
Figure 7: The Median RES shares of in 2011/2012 and 2011/2012 including the modified BM data of the gross final
energy demand for all CPs compared to the 2011/2012 indicative trajectory in the directive. (EIA, 2015;
EUROSTAT, 2015; IEA, 2015; DIRECTIVE 2009-28-EC)
75
Percentage points deviation from RED
minimum trajectory in 2012/2011
Assessment of Renewable Energy Action Plan Implementation and Progress in the Promotion
and Use of Renewable Energy in the Energy Community – Final Report
Median 2011/2012 Achivement
15%
Median 2011/2012 Achievement (modified BM-H Data)
12%
9%
6%
3%
0%
-3%
-6%
-9%
-12%
-15%
-18%
Albania
Bosnia and
Herzegovina
Kosovo*
Moldova Montenegro
FYR of
Macedonia
Serbia
Ukraine
Figure 8: The deviation of the median 2011/2012 RES shares of GFEC from the renewable energy directive (RED)
minimum trajectory in percentage points. (EIA, 2015; EUROSTAT, 2015; IEA, 2015; DIRECTIVE 2009-28-EC)
The deviation in percentage points from the RED minimum trajectory for all CPs is shown in Figure 8.
If the modified biomass consumption data is considered Bosnia and Herzegovina misses its target by
just 0.1 percentage points, followed by Albania, FYR of Macedonia and Ukraine which all fail to reach
their target by about 1 percentage point, Kosovo* by ca. 2 and Moldova and Serbia by around 3
percentage points. The original data as of EUROSTAT and IEA is shown in Table 9, Figure 7 and Figure
8 in this case, to put the modifications of the solid biomass consumption data into perspective.
Deviations between default (light blue bars) and modified data (dark blue bars) can be found in
Figure 7 and Figure 8 for Bosnia and Herzegovina, Moldova, FYR of Macedonia and Ukraine. Thus, for
these countries data on solid biomass use has been modified for the years 2011 and 2012 to be
consistent with the data used for the base year (2009) in the 2020 RES target calculation. The data
provided by the ECS for the year 2013 showed that in the meantime Bosnia and Herzegovina and
Moldova have already revised their data on solid biomass consumption in a consistent manner with
the modifications undertaken for 2009, 2011 and 2012. Therefore, only the respective data of FYR of
Macedonia and Ukraine had to be modified to assure consistency also for 2013.
Table 10: The RES share in gross final energy demand by 2012 and 2013 compared to the NREAP planned trajectory.
(ECS, 2015; EIA, 2015; EUROSTAT, 2015; IEA, 2015; CPs NREAPs, draft NREAPs and Progress Reports)
RES share in gross
final energy demand
by 2012 and 2013
Contracting Party
Albania
Bosnia and Herzegovina
Kosovo*
Moldova
Montenegro
FYR of Macedonia
Serbia
Ukraine
RES share as of EIA,
EUROSTAT, IEA data and
data provided by the ECS
RES share as of
Progress Report
data
NREAP planned
trajectory
Percentage points
deviation from NREAP
planned trajectory
2012
2013
2012
2013
2012
2013
2012
2013
[%]
32.3%
35.9%
18.8%
10.4%
42.0%
22.6%
20.1%
5.9%
[%]
30.4%
34.9%
18.1%
12.6%
41.8%
21.1%
19.8%
6.4%
[%]
32.3%
n.a.
18.2%
10.3%
28.5%
16.8%
20.3%
3.4%
[%]
36.1%
n.a.
19.0%
11.7%
31.0%
15.1%
19.1%
4.6%
[%]
29.0%
0.0%
18.2%
12.6%
28.5%
17.8%
17.8%
5.1%
[%]
30.6%
0.0%
18.3%
13.0%
31.0%
18.0%
19.3%
5.5%
[%]
3.2%
n.a.
0.6%
-2.2%
13.5%
4.9%
2.3%
0.9%
[%]
-0.2%
n.a.
-0.1%
-0.4%
10.8%
3.1%
0.5%
0.9%
76
RES Share vs. NREAP Trajectories in 2012
and 2013 [%]
Assessment of Renewable Energy Action Plan Implementation and Progress in the Promotion
and Use of Renewable Energy in the Energy Community – Final Report
Historical Data 2012
Progress Report 2013
NREAP Planned Trajectory 2020
45%
Historical Data 2013
NREAP Planned Trajectory 2012
RED Target 2020
Progress Report 2012
NREAP Planned Trajectory 2013
40%
35%
30%
25%
20%
15%
10%
5%
0%
Albania
Bosnia and
Herzegovina
Kosovo*
Moldova
Montenegro
FYR of
Macedonia
Serbia
Ukraine
Figure 9: The RES shares calculated for 2012 and 2012 including the modified solid biomass data of the gross final energy
demand for all CPs compared to the reported shares of all available CPs Progress Reports and the non-binding
2012 and 2013 shares of the CPs NREAP trajectories. (ECS, 2015; EIA, 2015; EUROSTAT, 2015; IEA, 2015; CPs
NREAPs, draft NEAPs and Progress Reports)
Percentage points deviation of RES shares
from the NREAP trajectory by
2012 and 2013
Historical Data 2012
Historical Data 2013
Progress Report 2012
Progress Report 2013
14%
12%
10%
8%
6%
4%
2%
0%
-2%
-4%
Albania
Bosnia and
Herzegovina
Kosovo*
Moldova Montenegro
FYR of
Macedonia
Serbia
Ukraine
Figure 10: The deviation of RES shares of GFEC from the NREAP planned trajectory by 2012 and 2013 in percentage
points. (ECS, 2015; EIA, 2015; EUROSTAT, 2015; IEA, 2015; CPs NREAPs, draft NEAPs and Progress Reports)
In a next step the RES shares for the years of 2012 and 2013 and the reported shares of the CPs
Progress Reports are compared to their NREAP and draft NREAP (for Albania and FYR of Macedonia)
trajectory in Figure 9 in a graphical manner. Note that exact numbers are expressed in Table 10. In
contrary to 2011/2012 (cf. Figure 7) six CPs meet their NREAP planned trajectory in 2012 and 2013
(see also Figure 10 and Table 10 for deviation in percentage points from NREAP planned trajectory).
Only one CPs, namely Moldova, missed its NREAP target in 2012, and the resulting gap is 2.2
percentage points. Albania over achieved its target in 2012 by 3.2, Montenegro by 13.5, FYR of
Macedonia by 4.9 and Serbia by 2.3 percentage points. Kosovo* and Ukraine met their target with a
surplus of 0.6 (Kosovo*) and 0.9 (Ukraine) percentage points, respectively. As there is no NREAP for
Bosnia and Herzegovina available, it is not possible to compare actual with planned deployment in
this and all following cases. In 2013 Moldova missed its target by 0.4 percentage points. Also Albania
and Kosovo*failed to achieve their targets but the arising gap of 0.2 percentage points lies within the
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Assessment of Renewable Energy Action Plan Implementation and Progress in the Promotion
and Use of Renewable Energy in the Energy Community – Final Report
Total RES deployment vs. NREAP
Trajectory in 2012 and 2013 [ktoe]
corridor of statistical uncertainty. Montenegro over achieved its target in 2013 by aground 10.8
percentage points (see Box 2 for further explanations on the special case of Montenegro), FYR of
Macedonia by 3.1, Serbia by 0.5 and Ukraine by 0.9 percentage points.
4,500
Historical Data 2012
Progress Report 2013
NREAP Planned Trajectory 2020
Historical Data 2013
NREAP Planned Trajectory 2012
Progress Report 2012
NREAP Planned Trajectory 2013
8,475
4,000
3,500
3,000
2,500
2,000
1,500
1,000
500
0
Albania
Bosnia and
Herzegovina
Kosovo*
Moldova Montenegro
FYR of
Macedonia
Serbia
Ukraine
Figure 11: Absolute RES deployment in 2012 compared to RES deployment of 2012 and 2013 as of Progress Reports and
NREAP trajectories. (ECS, 2015; EIA, 2015; EUROSTAT, 2015; IEA, 2015; CPs NREAPs, draft NEAPs and Progress
Reports)
% Deviation of total RES deployment from
the NREAP trajectory by 2012 and 2013
Historical Data 2012
Historical Data 2013
Progress Report 2012
Progress Report 2013
45%
40%
35%
30%
25%
20%
15%
10%
5%
0%
-5%
-10%
-15%
-20%
-25%
-30%
-35%
Albania
Bosnia and
Herzegovina
Kosovo*
Moldova Montenegro
FYR of
Macedonia
Serbia
Ukraine
Figure 12: The percentage deviation of the absolute RES deployment in 2012 and 2013 from the absolute RES targets set
in the CPs NREAPs. (ECS, 2015; EIA, 2015; EUROSTAT, 2015; IEA, 2015; CPs NREAPs, draft NEAPs and Progress
Reports)
The absolute RES deployment in ktoe of 2012 and 2013 is shown in Figure 11. In addition Figure 12
depicts the percentage deviation of the CPs absolute deployment of 2012 and 2013 to the planned
absolute RES deployment as of the NREAPs. It shows that Albania surpasses its absolute target by
3.2% in 2012 and missed it by 3.5% in 2013. Kosovo* missed its target by 1.1% in 2012 and met
exactly its targets in 2013. Moldova missed its target by 3.2% in 2012 and 1.6% in 2013. Montenegro
surpassed its absolute target in 2012 by 43.4% and 32.2% in 2013. FYR of Macedonia over achieved
its target in 2012 by 26.6% and under achieved by 5.0% in 2013. The same dynamic faces Serbia with
a surplus of 2.2% in 2012 and a deficit of 4.1% in 2013. Ukraine surpassed its absolute NREAP RES
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Assessment of Renewable Energy Action Plan Implementation and Progress in the Promotion
and Use of Renewable Energy in the Energy Community – Final Report
targets by 37.5% in 2012 and 23.5% in 2013, respectively. Overall, six CPs met their absolute NREAP
targets in 2012, but only two did so in 2013.
RES deployment in the electricity sector
In a first step, Figure 13 depicts the historical and planned RES-E shares for the years 2012 and 2013.
Figure 14 shows the deviation of the RES-E shares from the planned shares as of the CPs (draft)
NREAPs in percentage points. Albania surpassed its planned RES-E share by 3.5 and 0.8 percentage
points in 2012 and 2013. Kosovo*, Moldova and Ukraine met their planned RES-E shares in 2012 and
2013 in the range of +-0.6 percentage points. Also Montenegro did so in 2012 but fell short in 2013
with a deficit of 6.2 percentage points. FYR of Macedonia missed its RES-E target by 4.7 and 2.5
percentage points in 2012 and 2013. Serbia had a surplus of 2.4 in 2012 and deficit of 1.9 percentage
points in 2013.
RES-E Share vs. NREAP Trajectory in
2012 and 2013 [%]
Historical Data 2012
Progress Report 2013
80%
Historical Data 2013
NREAP Planned Trajectory 2012
NREAP Planned Trajctory 2020
91.1%
Progress Report 2012
NREAP Planned Trajectory 2013
70%
60%
50%
40%
30%
20%
10%
0%
Albania
Bosnia and
Herzegovina
Kosovo*
Moldova
Montenegro
FYR of
Macedonia
Serbia
Ukraine
Percentage points deviation of RES -E
shares from the NREAP trajectory by
2012 and 2013
Figure 13: RES-E share in 2012 and 2013 of the gross electricity demand for all Contraction Parties compared to the not
binding NREAP targets. (ECS, 2015; EIA, 2015; EUROSTAT, 2015; IEA, 2015; CPs NREAPs, draft NEAPs and
Progress Reports)
Historical Data 2012
Historical Data 2013
Albania
Kosovo*
Progress Report 2012
Progress Report 2013
16%
14%
12%
10%
8%
6%
4%
2%
0%
-2%
-4%
-6%
-8%
Bosnia and
Herzegovina
Moldova Montenegro
FYR of
Macedonia
Serbia
Ukraine
Figure 14: The deviation of the RES-E share in 2012 and 2013 from the RES-E target shares set in the CPs NREAPs in
percentage points. (ECS, 2015; EIA, 2015; EUROSTAT, 2015; IEA, 2015; CPs NREAPs, draft NEAPs and Progress
Reports)
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and Use of Renewable Energy in the Energy Community – Final Report
RES-E deployment vs. NREAP Trajectory in
2012 and 2013 [GWh]
The absolute RES-E deployment as of statistical data and Progress Reports and NREAP trajectories
for 2012 and 2013 are shown in Figure 14. It remains unclear if the difference between the statistical
data and Progress Reports is due to the reason that the CPs have not undertaken a normalisation for
the data on actual electricity generation from hydropower in their Progress Reports, as this has been
done for the historical statistical data included in this report. The percentage deviation of the
absolute RES-E deployment in 2012 and 2013 from the absolute RES-E targets set in the CPs NREAPs
are shown in Figure 16. Albania, Montenegro and Ukraine met their planned absolute deployment
according to statistical data for 2012 and 2013. FYR of Macedonia and Serbia did so in 2012 but fell
short of their panned absolute deployment in 2013. Kosovo* and Moldova both showed a deficit in
2012 and 2013, although Kosovo* showed a deficit of around 30% in 2012 and 2013 and Moldova
only around 4% for both years.
16,000
Historical Data 2012
Progress Report 2013
NREAP Planned Trajectory 2020
Historical Data 2013
NREAP Planned Trajectory 2012
Progress Report 2012
NREAP Planned Trajectory 2013
26,000
14,000
12,000
10,000
8,000
6,000
4,000
2,000
0
Albania
Bosnia and Kosovo*
Herzegovina
Moldova Montenegro
FYR of
Macedonia
Serbia
Ukraine
Figure 15: Absolute RES-E deployment in 2012 and 2013 for all CPs compared to the indicative NREAP targets. (ECS,
2015; EIA, 2015; EUROSTAT, 2015; IEA, 2015; CPs NREAPs, draft NEAPs and Progress Reports)
% Deviation from indicative RES-E target
(NREAP trajectory) by 2012 and 2013
Historic deployment of 2012
Historical deployment of 2013
Progress Report 2012
Progress Report 2013
40%
30%
20%
10%
0%
-10%
-20%
-30%
-40%
-50%
-60%
Albania
Bosnia and
Herzegovina
Kosovo*
Moldova Montenegro
FYR of
Macedonia
Serbia
Ukraine
Figure 16: The percentage deviation of the absolute RES-E deployment in 2012 and 2013 from the absolute RES-E targets
set in the CPs NREAPs. (ECS, 2015; EIA, 2015; EUROSTAT, 2015; IEA, 2015; CPs NREAPs, draft NEAPs and
Progress Reports)
Figure 17 to Figure 22 depict the historic and planned deployment at technology level.
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and Use of Renewable Energy in the Energy Community – Final Report
Biomass-E deployment vs. NREAP
Trajectory in 2012 and 2013 [GWh]
In a first step, Figure 17 shows the actual and planned biomass deployment in the electricity sector.
The Albanian NREAP sets out a target for 23 GWh generated for 2012 and 46 GWh for 2013. The
statistics of EUROSTAT show no actual deployment of biomass technologies in the electricity sector
in 2012 and 2013. Also the draft NREAP of the FYR of Macedonia shows 6 GWh planned for 2013 and
the EUROSTAT statistics show no deployment. The opposite is true for the Ukraine. The IEA statistics
show a generation of 134 GWh of electricity by biomass for the year of 2012 and the ECS statistics
for 2013. The Progress Report of the Ukraine cites 18 GWh for 2012 and 32 GWh for 2013, whereas
there was no deployment planned in the Ukrainian NREAP.
200
180
160
140
120
100
80
60
40
20
0
Historical Data 2012
Historical Data 2013
Progress Report 2012
Progress Report 2013
NREAP Planned Trajectory 2012
NREAP Planned Trajectory 2013
NREAP Planned Trajectory 2020
Albania
Bosnia and
Herzegovina
Kosovo*
640
Moldova Montenegro
FYR of
Macedonia
Serbia
2,950
Ukraine
Figure 17: Biomass deployment in the electricity sector in 2012 and 2013 for all CPs compared to the indicative NREAP
targets. (ECS, 2015; EUROSTAT, 2015; IEA, 2015; CPs NREAPs, draft NREAPs and Progress Reports)
Biogs-E deployment vs. NREAP Trajectory
in 2012 and 2013 [GWh]
The FYR of Macedonia planned to generate 5 GWh of electricity with the use of biogas technologies.
Actual production with the use of biogas technologies was only reported by the amount of 1 GWh
for 2012 and 4 GWh for 2013 by EUROSTAT in Serbia. Serbia reported amounts of 6 GWh in 2012
and 22 GWh in 2013 in its Progress Report. Also Moldova and Ukraine reported some generation of
electricity by the use of biogas, which could not be confirmed by historical data.
35
Historical Data 2012
Historical Data 2013
Progress Report 2012
Progress Report 2013
NREAP Planned Trajectory 2012
NREAP Planned Trajectory 2013
NREAP Planned Trajectory 2020
305
1,270
30
25
20
15
10
5
0
Albania
Bosnia and
Herzegovina
Kosovo*
Moldova Montenegro
FYR of
Macedonia
Serbia
Ukraine
Figure 18: Biogas deployment in the electricity sector in 2012 and 2013 for all CPs compared to the indicative NREAP
targets. (ECS, 2015; EUROSTAT, 2015; IEA, 2015; CPs NREAPs, draft NEAPs and Progress Reports)
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Assessment of Renewable Energy Action Plan Implementation and Progress in the Promotion
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Hydropower deployment vs. NREAP
Trajectory in 2012 and 2013 [GWh]
There was no planned or actual use of geothermal technologies in the electricity sector by any CPs.
The Ukraine plans to include geothermal technologies in the year 2014, as reported in their NREAP.
15,000
13,500
12,000
10,500
9,000
7,500
6,000
4,500
3,000
1,500
0
Historical Data 2012
Historical Data 2013
Progress Report 2012
Progress Report 2013
NREAP Planned Trajectory 2012
NREAP Planned Trajectory 2013
NREAP Planned Trajectory 2020
Albania
Bosnia and
Herzegovina
Kosovo*
Moldova Montenegro
FYR of
Macedonia
Serbia
Ukraine
Figure 19: Electricity generated by Hydropower in 2012 and 2013 for all CPs compared to the indicative NREAP targets.
(ECS, 2015; EIA, 2015; EUROSTAT, 2015; IEA, 2015; CPs NREAPs, draft NEAPs and Progress Reports)
% Deviation from indicative target (NREAP
trajectory) for Hydropower in 2012 and
2013
Historical Data 2012
Historical Data 2013
Progress Report 2012
Progress Report 2013
50%
40%
30%
20%
10%
0%
-10%
-20%
-30%
-40%
-50%
-60%
Albania
Bosnia and Kosovo*
Herzegovina
Moldova Montenegro
FYR of
Macedonia
Serbia
Ukraine
Figure 20: The percent deviation of hydropower generation in 2012 and 2013 from the targets set in the CPs NREAPs.
(ECS, 2015; EIA, 2015; EUROSTAT, 2015; IEA, 2015; CPs NREAPs, draft NEAPs and Progress Reports)
Figure 19 shows actual and planned electricity generation by hydropower. Deviations in percent are
presented in Figure 20. Only Kosovo* shows a negative deviation of 28.4% in the year 2012 when the
normalised hydropower data is considered, which was calculated using capacity data provided by
the U.S. Energy Information Administration (EIA) until the year 2012 and the “Annual
Implementation Report 2013/2014” of the ECS for 2013 (ECS, 2014). It remains unclear whether the
data reported in the CPs Progress Reports was normalised or not, but as the differences for the
reported data for 2012 and 2013 are relatively high, it seems that it was not. As a result it is not very
useful to compare the Progress Report data to the planned trajectories for hydropower of the CPs
NREAPs, as the data requires to be normalised, to correct for yearly fluctuations because of
differences in the yearly precipitation.
82
PV deployment vs. NREAP Trajectory in
2012 and 2013 [GWh]
Assessment of Renewable Energy Action Plan Implementation and Progress in the Promotion
and Use of Renewable Energy in the Energy Community – Final Report
600
Historical Data 2012
Historical Data 2013
Progress Report 2012
Progress Report 2013
NREAP Planned Trajectory 2012
NREAP Planned Trajectory 2013
NREAP Planned Trajectory 2020
2,420
500
400
300
200
100
0
Albania
Bosnia and
Herzegovina
Kosovo*
Moldova Montenegro
FYR of
Macedonia
Serbia
Ukraine
Figure 21: PV deployment in 2012 and 2013 for all CPs compared to the indicative NREAP targets. (ECS, 2015; EUROSTAT,
2015; IEA, 2015; DIRECTIVE 2009-28-EC)
Wind onshore deployment vs. NREAP
Trajectory in 2012 and 2013 [GWh]
Only the FYR of Macedonia planned to deploy some photovoltaic (PV) technology in its NREAP by
2013 and to generate 10 GWh of electricity and managed to do so as was reported by EUROSTAT
and in their Progress Report. Moreover the Ukraine deployed PV technology and generated 333
GWh in the year 2012 and 570 GWh in 2013. Its Progress Report shows a generation 563 GWh for
2013.
700
Historical Data 2012
Historical Data 2013
Progress Report 2012
Progress Report 2013
NREAP Planned Trajectory 2012
NREAP Planned Trajectory 2013
NREAP Planned Trajectory 2020
1,000
5,900
600
500
400
300
200
100
0
Albania
Bosnia and
Herzegovina
Kosovo*
Moldova Montenegro
FYR of
Macedonia
Serbia
Ukraine
Figure 22: Wind onshore deployment in 2012 and 2013 for all CPs compared to the indicative NREAP targets. (ECS, 2015;
IEA, 2015; EUROSTAT, 2015; CPs NREAPs, draft NEAPs and Progress Reports)
Ukraine planned to generate 1024 GWh of electricity in 2012 and 1352 GWh in 2013 by the use of
onshore wind technology. For 2012 the IEA reported a generation of 288 GWh and the data provided
by the ECS 638.6 GWh for 2013. For 2013 the Ukrainian Progress Report cited a generation of 637
GWh. All other CPs have neither planned nor reported any generation by wind technology for this
timespan as can be seen in Figure 22.
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Assessment of Renewable Energy Action Plan Implementation and Progress in the Promotion
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RES deployment in the heating and cooling sector
RES-H Share vs. NREAP Trajectory in
2012 and 2013 [%]
The actual and planned development of the CPs RES shares in the heating and cooling sector (RES-H
shares) is depicted in Figure 23. The deviations of actual vs. planned deployment in percentage
points are depicted in Figure 24. Kosovo*, Montenegro, FYR of Macedonia, Serbia and Ukraine
managed to meet their RES-H target shares in 2012 missed its targets for renewables in the heating
and cooling sector in 2012 and 2013. Moldova showed a deficit in 2012 but met its target in 2013.
The deviation in percentage points of the CPs actual and planned RES share in the heating and
cooling sector in 2012 and 2013 is depicted in Figure 24.
Historical Data 2012
Historical Data 2013
Progress Report 2012
Progress Report 2013
NREAP Planned Trajectory 2012
NREAP Planned Trajectory 2013
NREAP Planned Trajectory 2020
80%
70%
60%
50%
40%
30%
20%
10%
0%
Albania
Bosnia and
Herzegovina
Kosovo*
Moldova
Montenegro
FYR of
Macedonia
Serbia
Ukraine
Figure 23: RES-H share in 2012 and 2013 of the gross heating and cooling demand for all Contraction Parties compared to
the indicative NREAP targets. (ECS, 2015; EUROSTAT, 2015; IEA, 2015; CPs NREAPs, draft NEAPs and Progress
Reports)
Percentage points deviation from
indicative RES-H target (NREAP trajectory)
in 2012 and 2013
Historical Data 2012
Historical Data 2013
Progress Report 2012
Progress Report 2013
35%
30%
25%
20%
15%
10%
5%
0%
-5%
-10%
-15%
-20%
-25%
Albania
Bosnia and Kosovo*
Herzegovina
Moldova Montenegro
FYR of
Macedonia
Serbia
Ukraine
Figure 24: The deviation in percentage points of the RES-H shares in 2012 and 2013 from the RES-H target shares set in
the CPs NREAPs. (ECS, 2015; EIA, 2015; EUROSTAT, 2015; IEA, 2015; CPs NREAPs, draft NEAPs and Progress
Reports)
If the absolute deployment is considered, as it is depicted in Figure 24, only Albania fell short of its
target in 2013. All other absolute targets for the RES-H sector were met or even surpassed by a large
amount in 2012 and 2013.
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RES-H deployment vs. NREAP Trajectory in
2012 and 2013 [ktoe]
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3,200
Historical Data 2012
Progress Report 2013
NREAP Planned Trajectory 2020
Historical Data 2013
NREAP Planned Trajectory 2012
Progress Report 2012
NREAP Planned Trajectory 2013
5,850
2,800
2,400
2,000
1,600
1,200
800
400
0
Albania
Bosnia and
Herzegovina
Kosovo*
Moldova Montenegro
FYR of
Macedonia
Serbia
Ukraine
Figure 25: The absolute RES-H deployment in 2012 and 2013 of the gross heating and cooling demand for all Contraction
Parties compared to the indicative NREAP targets. (ECS, 2015; EUROSTAT, 2015; IEA, 2015; CPs NREAPs, draft
NEAPs and Progress Reports)
Biomass-H deployment vs. NREAP
Trajectory in 2012 and 2013 [ktoe]
Figure 26 to Figure 30 compare the RES deployment in the heating and cooling sector on a
technology specific level. Albania did not define technology specific trajectories for the heating and
cooling as well as the transport sector. Because of that it is not possible to compare actual data at
technology level with a specific NREAP target. This is the fact why Albania is not included in the
consecutive figures on NREAP planned trajectories at technology level.
3,200
Historical Data 2012
Historical Data 2013
Progress Report 2012
Progress Report 2013
NREAP Planned Trajectory 2012
NREAP Planned Trajectory 2013
NREAP Planned Trajectory 2020
4,850
2,800
2,400
2,000
1,600
1,200
800
400
0
Albania
Bosnia and
Herzegovina
Kosovo*
Moldova Montenegro
FYR of
Macedonia
Serbia
Ukraine
Figure 26: The biomass deployment in the heating and cooling sector for the years 2012 and 2013 compared to the
NREAP trajectory. (ECS, 2015; EUROSTAT, 2015; IEA, 2015; CPs NREAPs, draft NEAPs and Progress Reports)
Figure 26 and Figure 27 compare the biomass deployment in 2012 and 2013 to the CPs NREAP
trajectories. A special case within these candidates is Montenegro. In the actual EUROSTAT data
Montenegro reports a solid biomass use for the year 2009 which was 3.6 times as high as it was laid
down in its NREAP and assessed by the ECS in 2012 for the target calculation (see Box 2 for further
details).
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% Deviation from indicative target (NREAP
trajectory) for Biomass-H in 2012 and 2013
Historical Data 2012
Historical Data 2013
Progress Report 2012
Progress Report 2013
140%
120%
100%
80%
60%
40%
20%
0%
-20%
-40%
Albania
Bosnia and
Herzegovina
Kosovo*
Moldova Montenegro
FYR of
Macedonia
Serbia
Ukraine
Geothermal-H deployment vs. NREAP
Trajectory in 2012 and 2013 [ktoe]
Figure 27: The percentage deviation of biomass deployment in 2012 and 2013 from the indicative NREAP targets. (ECS,
2015; EIA, 2015; EUROSTAT, 2015; IEA, 2015; CPs NREAPs, draft NEAPs and Progress Reports)
22.5
2012 Historical Data
2013 Historical Data
Progress Report 2012
Progress Report 2013
NREAP Planned Trajectory 2012
NREAP Planned Trajectory 2013
NREAP Planned Trajectory 2020
49
50
20.0
17.5
15.0
12.5
10.0
7.5
5.0
2.5
0.0
Albania
Bosnia and
Herzegovina
Kosovo*
Moldova
Montenegro
FYR of
Macedonia
Serbia
Ukraine
Figure 28: Geothermal deployment in the heating and cooling sector in 2012 and 2013 compared to the indicative NREAP
targets. (ECS, 2015; EUROSTAT, 2015; IEA, 2015; CPs NREAPs, draft NEAPs and Progress Reports)
The FYR of Macedonia planned to generate 15 ktoe of heat by the use of geothermal technologies in
2012 and 21 ktoe in 2013 in their NREAP. EUROSTAT reported 9.5 ktoe for 2012 and 7.8 ktoe for
2013. Their Progress Report cited 8.9 ktoe each year (see Figure 28). Serbia planned to generate 6
ktoe of thermal energy each year by the use of geothermal technology and reported that it did in
their Progress Report. The EUROSTAT statistics stated 6.2 ktoe for 2012 and 4.5 for 2013 (see Figure
28).
To apply solar thermal for generating heat was planned by Kosovo*, Montenegro and the FYR of
Macedonia, and reported in their NREAPs (see Figure 29). Kosovo* and Montenegro also reported
that they did produce 0.7 ktoe in 2012 and 2013. This fact cannot be confirmed by official statistics.
Albania reported to make use of 11.8 ktoe thermal energy by the use of solar thermal technology,
which is also stated by EUROSTAT.
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Solar thermal deployment vs. NREAP
Trajectory in 2012 and 2013 [ktoe]
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14
2012 Historical Data
2013 Historical Data
Progress Report 2012
Progress Report 2013
NREAP Planned Trajectory 2012
NREAP Planned Trajectory 2013
NREAP Planned Trajectory 2020
200
12
10
8
6
4
2
0
Albania
Bosnia and
Herzegovina
Kosovo*
Moldova
Montenegro
FYR of
Macedonia
Serbia
Ukraine
Figure 29: Solar thermal deployment in the heating and cooling sector in 2012 and 2013 compared to the indicative
NREAP targets. (ECS, 2015; EUROSTAT, 2015; IEA, 2015; CPs NREAPs, draft NEAPs and Progress Reports)
Heatpump deployment vs. NREAP
Trajectory in 2012 and 2013 [ktoe]
Montenegro and Ukraine planned to use heat pumps for the production of thermal energy.
Montenegro did so by a relatively small amount of around 3 ktoe in 2012 and 2013, and stated that
it did so in its Progress Report. This cannot be confirmed by official statistics. Ukraine planned to use
94 ktoe in 2012 and 112 ktoe in 2013 of heat generated by heat pumps, but failed to do so.
120
110
100
90
80
70
60
50
40
30
20
10
0
2012 Historical Data
2013 Historical Data
Progress Report 2012
Progress Report 2013
NREAP Planned Trajectory 2012
NREAP Planned Trajectory 2013
NREAP Planned Trajectory 2020
Albania
Bosnia and
Herzegovina
Kosovo*
600
Moldova
Montenegro
FYR of
Macedonia
Serbia
Ukraine
Figure 30: Heat pump deployment in the heating and cooling sector in 2012 and 2013 compared to the indicative NREAP
targets. (ECS, 2015; EUROSTAT, 2015; IEA, 2015; CPs NREAPs, draft NEAPs and Progress Reports)
Biofuel deployment in the transport sector
Biofuels play a minor role in CPs NREAPs. Just the FYR of Macedonia planned to produce biofuels
with an amount of 30 ktoe in 2012 and 37 ktoe in 2013. EUROSTAT statistics and their Progress
Report confirmed just 0.9 ktoe per year for this timespan. The Albanian and Ukrainian Progress
Reports cited relatively large volumes of biofuels. Reported data could however only be verified in
the case of Ukraine for the year 2013.
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Biofuel deployment vs. NREAP Trajectory in
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45
Historical Data 2012
Historical Data 2013
Progress Report 2012
Progress Report 2013
NREAP Planned Trajectory 2012
NREAP Planned Trajectory 2013
NREAP Planned Trajectory 2020
79
245
390
40
35
30
25
20
15
10
5
0
Albania
Bosnia and
Herzegovina
Kosovo*
Moldova
Montenegro
FYR of
Macedonia
Serbia
Ukraine
Figure 31: Biofuel deployment in 2012 and 2013 for all Contraction Parties compared to the NREAP trajectory. (ECS,
2015; EUROSTAT, 2015; IEA, 2015; CPs NREAPs, draft NEAPs and Progress Reports)
3.2.4 Summary of key findings
Several challenges have been identified within the assessment of past (2012/2013) RES progress in
CPs:
•
•
•
First, reliable and comprehensive statistical data related to the historic deployment of
renewables and of overall energy consumption was not applicable for all CPs.
Second, reporting on past progress was not delivered by all CPs (i.e. seven out of eight CPs)
and the information provided was partly incomplete or inconsistent when compared to
official statistical data.
In addition corrections and modifications to CPs reporting was indispensable, specifically for
data on biomass used in heating and cooling and for energy demand (i.e. when comparing
NREAP projections with actual data).Thus, for delivering a complete picture for the historic
development of renewable energies in all CPs, the original and modified data is presented in
this report.
The assessment of past RES progress comprises a comparison of actual RES deployment with
required (2011/2012) minimum trajectory targets (according to the RED) and with CPs plans as
outlined in their NREAPs (for 2012 and 2013):
•
We start with assessing compliance with required minimum trajectory targets (according to
the RES Directive). It can be seen that only Montenegro achieved its RED target for
2011/2012 whereas all other CPs fall short in complying. For the case of Montenegro it has
to be taken into account that national energy balances have been corrected retrospectively
for a final consumption of solid biomass in the heating and cooling sector. Therefore its
share of RES in GFEC increased anyways without any additional deployment (see Box 2 for a
detailed description). Of interest, the RED minimum trajectory for 2011/2012 sets a
relatively strict interim target. This can be seen when comparing these with interim targets
defined by CPs in their NREAPs: all interim targets of the NREAPs for 2012 show a lower
percentage target than the RED Minimum Trajectory for 2011/2012.
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•
•
•
•
A comparison of actual and planned RES shares in GFEC (in accordance with CP’s NREAPs)
shows that almost all of the CPs have managed to meet their planned overall RES shares for
the years 2012 and 2013. The CP who missed its targets was Moldova by 2.2 percentage
points in 2012 and 0.4 in 2013. The strongest positive deviations of actual to planned RES
shares in GFEC in 2012 occur for Albania (3.2 percentage points (p.p.)), Montenegro (13.5
p.p.), FYR of Macedonia (4.9 p.p.) and Serbia (2.3 p.p.). In 2013 Montenegro over achieved
its target by 10.8 (see Box 2 for further explanations on the special case of Montenegro) and
FYR of Macedonia by 3.1 percentage points, respectively. If the absolute RES deployment is
considered, six CPs met their absolute NREAP targets in 2012, but only two did so in 2013.
The negative deviations in 2013 range from minus 1.1% for Kosovo* to minus 5% of planned
vs. actual deployment for FYR of Macedonia. In this case positive examples are Ukraine who
surpassed its absolute NREAP RES targets by 37.5% in 2012 and 23.5% in 2013, and
Montenegro who surpassed its absolute target in 2012 by 43.4% and 32.2% in 2013,
respectively.
With respect to the deployment of renewable electricity it can be seen that most CPs are
well on track. When statistics are compared to NREAPs Albania surpassed its planned RES-E
share by 3.5 in 2012 and 0.8 percentage points in 2013. Kosovo*, Moldova and Ukraine met
their planned RES-E shares in 2012 and 2013 by +-0.6 percentage points. Also Montenegro
did so in 2012 but fell short in 2013 with a deficit of 6.2 percentage points. FYR of
Macedonia missed its RES-E target by 4.7 and 2.5 percentage points in 2012 and 2013.
Serbia had a surplus of 2.4 and deficit of 1.9 percentage points in 2012 and 2013.
The status of renewable energies in the heating and cooling sector depends very much on
the statistical records of solid biomass use for every CP. As such, the picture for the absolute
RES-H deployment and NREAP trajectory fulfilment in this report depends significantly on
the (necessary) correction of national biomass data. The assessment of these corrections
dates back to the RES target setting process of the ECS in 2012. If these corrections are
applied Kosovo*, Montenegro, FYR of Macedonia, Serbia and Ukraine managed to meet
their RES-H target shares in 2012 and 2013. Moldova showed a deficit in 2012 but met its
target in 2013. Finally, Albania is the only CP that missed its RES-H target in both years.
Only Albania, Ukraine and to a very small amount the FYR of Macedonia report some biofuel
deployment in the transport sector for the year 2013 in their Progress Reports. The planned
deployment of Montenegro and the FYR of Macedonia as reported in their NREAPs for 2012
and 2013 were not fulfilled at all. Official statistics could only verify a small production of
biofuels in the FYR of Macedonia and a more respectable volume in Ukraine in 2013.
3.3 Assessment of future progress (towards meeting the 2020 targets)
3.3.1 Method of approach
The general approach used for this analysis of Contracting Parties expected future progress is to
conduct a model-based quantitative assessment of future RES deployment in absolute (i.e. GWh
produced) and relative terms (i.e. RES shares on gross demands), reflecting assumptions also on
future energy demand, comprising trend expectations for 2020.
The scenario calculation is performed by applying the Green-X model (explained in Box 3), a wellestablished simulation tool for policy instruments in the European RES market indicating
consequences of policy choices on deployment and cost of RES technologies in a comprehensive
manner. Although Green-X is capable of providing details for a broad set of RES technologies used
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for power generation or in heating and cooling, for the transport sector Green-X is only capable to
model biofuel deployment but not electro-mobility. For the assessment of overall RES target
achievement at Contracting Party level this does not represent any constraint since RES target
achievement is measured by summing up RES use in the electricity sector, in heating and cooling and
biofuels in transport, and the sum is subsequently divided by gross final energy demand. For the
transport-specific sector RES target, where a minimum RES share of 10% shall be achieved by 2020,
however only the contribution of biofuels can be assessed.
Box 3: Short characterisation of the Green-X model
Short characterisation of the Green-X model:
The model Green-X has been developed by the Energy Economics Group (EEG) at the Vienna University of Technology
under the EU research project “Green-X–Deriving optimal promotion strategies for increasing the share of RES-E in a
dynamic European electricity market" (Contract No. ENG2-CT-2002-00607). Initially focussed on the electricity sector, this
modelling tool, and its database on renewable energy (RES) potentials and costs, has been extended to incorporate
renewable energy technologies within all energy sectors.
Green-X covers the EU-28, the Western Balkans, Turkey and North Africa and has been be extended within the course of
this study to other countries, such as Ukraine or Moldova. It allows the investigation of the future deployment of RES as
well as the accompanying cost (including capital expenditures, additional generation cost of RES compared to conventional
options, consumer expenditures due to applied supporting policies) and benefits (for instance, avoidance of fossil fuels and
corresponding carbon emission savings). Results are calculated at both a country- and technology-level on a yearly basis.
The time-horizon allows for in-depth assessments up to 2030, accompanied by concise outlooks for the period beyond
2030 (up to 2050).
The Green-X model develops nationally specific dynamic cost-resource curves for all key RES technologies, including for
renewable electricity, biogas, biomass, biowaste, wind on- and offshore, hydropower large- and small-scale, solar thermal
electricity, photovoltaic, tidal stream and wave power, geothermal electricity; for renewable heat, biomass, sub-divided
into log wood, wood chips, pellets, grid-connected heat, geothermal grid-connected heat, heat pumps and solar thermal
heat; and, for renewable transport fuels, first generation biofuels (biodiesel, biomethane and bioethanol), second
generation biofuels (lignocellulosic bioethanol, biomass to liquid), as well as the impact of biofuel imports. Besides the
formal description of RES potentials and costs, Green-X provides a detailed representation of dynamic aspects such as
technological learning and technology diffusion.
Through its in-depth energy policy representation, the Green-X model allows an assessment of the impact of applying
(combinations of) different energy policy instruments (for instance, quota obligations based on tradable green certificates /
guarantees of origin, (premium) feed-in tariffs, tax incentives, investment incentives, impact of emission trading on
reference energy prices) at both country or European level in a dynamic framework. Sensitivity investigations on key input
parameters such as non-economic barriers (influencing the technology diffusion), conventional energy prices, energy
demand developments or technological progress (technological learning) typically complement a policy assessment.
Within the Green-X model, the allocation of biomass feedstock to feasible technologies and sectors is fully internalised into
the overall calculation procedure. For each feedstock category, technology options (and their corresponding demands) are
ranked based on the feasible revenue streams as available to a possible investor under the conditioned, scenario-specific
energy policy framework that may change on a yearly basis. Recently, a module for intra-European trade of biomass
feedstock has been added to Green-X that operates on the same principle as outlined above but at a European rather than
at a purely national level. Thus, associated transport costs and GHG emissions reflect the outcomes of a detailed logistic
model. Consequently, competition on biomass supply and demand arising within a country from the conditioned support
incentives for heat and electricity as well as between countries can be reflected. In other words, the supporting framework
at MS level may have a significant impact on the resulting biomass allocation and use as well as associated trade.
Moreover, Green-X was recently extended to allow an endogenous modelling of sustainability regulations for the energetic
use of biomass. This comprises specifically the application of GHG constraints that exclude technology/feedstock
combinations not complying with conditioned thresholds. The model allows flexibility in applying such limitations, that is to
say, the user can select which technology clusters and feedstock categories are affected by the regulation both at national
and EU level, and, additionally, applied parameters may change over time.
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The modelling work is closely linked to other parts of this study. Thus, the assessment of future
progress builds on the analysis of historic RES deployment (cf. section3.1), using for example
corrected (i.e. modified) data concerning the use of solid biomass in heating & cooling. Moreover,
the prospective assessment reflects findings gained with respect to achieved progress in mitigating
non-cost barriers. Obviously, this quantitative assessment is also closely linked to the overall
qualitative RES policy assessment (see section 3.3), building on the collected policy information and
providing input to the overall policy analysis.
3.3.2 Scenario definition
Subtask (b) comprises the prospective RES policy assessment, dedicated to provide a model-based
analysis to what extent currently implemented RES policies (Current Policy Initiatives (CPI)),
complemented by Planned Policy Initiatives (CPI+PPI) appear sufficient to trigger the targeted RES
deployment in subsequent years up to 2020 at Contracting Party level.
Information on Current (RES) Policy Initiatives (CPI) has been initially based on the RES policy
database developed within the IEE project BETTER (with its last update in June 2014) and was
recently updated by information gained through the RES-legal database (cf. www.res-legal.eu) as
well as first findings that stem from the survey of national legislative measures done in Task 1 of this
study. Where adequate (e.g. for biofuels in transport where information is difficult to extract from
publicly available information sources) this is complemented by information gained through the
Contracting Party’s NREAPs as well as through Contracting Party experts.
Information on Planned Policy Initiatives (PPI) and Current Policy Initiatives (CPI) was collected from
CP’s NREAPs and Progress Reports. Since CPs reported on planned improvements in a nonhomogenous manner a comprehensive reassessment of the originally provided information was
needed. As a first step, measures were differentiated between current and planned measures.4
Next, reported country-specific measures were grouped into:
•
•
non-cost barriers, and
financial support measures.
Please note that the detailed approach with respect to the incorporation into the model’s policy
database is described for both types of measures in Annex IV to this report.
3.3.3 Sensitivity analysis
Note that an extended sensitivity analysis has been undertaken for both assessed cases, relating to
the following aspects:
•
4
Expected future energy demand (growth): two revised scenarios of future energy demand
developments up to 2020 (i.e. efficiency and reference demand development) form the basis for
our assessment whereas CPs default demand trends as reported in their NREAPs are used for a
sensitivity assessment. More precisely, expectations on future energy demand were originally
Current measures where actual implementation was confirmed by alternative data sources (i.e. the survey of national legislation or
RES-legal) have been consequently incorporated in the CPI scenario, so that only additional planned future measures remain under the
PPI case.
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•
taken from the CPs NREAPs but have been compared with actual data for the status quo (2011
and 2012) and were corrected, respectively. 5
Contracting Party-specific financing risk: as default the assumption was taken that currently
prevailing financing risks will be mitigated in forthcoming years. In contrast to that, within a
complementary sensitivity analysis it was researched how RES progress is affected by a
remaining of these risk elements. 6
3.3.4 Results
Next the outcomes of our model-based assessment of expected future progress are discussed. For
RES overall, two figures will be presented for 2020:
(1) Overview figure comparing for each CP expected RES deployment with RED minimum
trajectory targets (i.e. required deployment) and indicative NREAP targets (i.e. planned
progress);
(2) CP’s deviation from planned deployment, i.e. the indicative NREAP target as set for 2020.
All data on expected RES deployment stems from Green-X modelling, in particular the “Current
Policy Initiatives (CPI)” and the “CPI plus planned measures (CPI+PPI)” scenarios. For the three
sectors RES-E, RES-H&C, and biofuels in transport, we present figures (1) and (2) as well but since no
minimum targets are prescribed at sector or technology level expected deployment is only
compared to the planned one (i.e. the indicative NREAP target). Moreover, for each of the three
sectors we present the deviation from indicative NREAP targets (the figure (2)) for the main
technologies in the report. Moreover, please note that for Bosnia & Herzegovina a comparison of
expected to (in accordance with NREAP) planned deployment could not be undertaken – neither at
technology nor at aggregated levels – because no NREAP has been provided so far by that CP.
Overall RES deployment
Modelling results show the projected future progress by 2020 (i.e. against the binding 2020 RES
target), indicating by CP the likeliness of delivering as required under the RES directive (i.e. minimum
targets for overall RES deployment under the indicative trajectory, Annex I part B of the RES
directive). As a starting point, Figure 32 shows the expected RES deployment in relative terms,
5
Demand projections provided by most CPs NREAPs appeared to reflect latest developments generally more adequate than alternative
data sources. A correction and validation process at CP level in order to reflect recent changes in energy consumption, i.e. incorporating
the impact of the financial/economic crisis that was significant in magnitude in parts of Europe, was however indispensable for being
capable to provide suitable short-term projections. Implications arising from this validation and correction process on future energy
demand developments are subject of the corresponding sensitivity assessment on future energy demand (growth) where we propose
that, in short, either a permanent change (low demand) or only an short-term change followed later on (up to 2020) by a full alignment
with past NREAP projections (high demand case) will be assumed. For details on the underlying demand trends we refer to Annex V of
this report.
6
Nowadays investment risks are prominently discussed as a consequence of the global financial crisis and the subsequent state debt
crisis that popped up in recent years. Thus, CP-specific risk adder will be used assuming that they equally affect all RES options within a
CP. The impact of such a risk adder can be described as follows:
•
For CPs with a high risk rating one can expect a strong decline of RE investments and, consequently, a significant decrease of
•
In contrast to above, CPs that offer a good climate for risk-averse investors perform better than the remainder. This leads generally
related deployment if no proactive risk mitigation measures are taken.
to a stronger RES deployment if other (financial or non-economic) constraints allow for that.
As default the assumption will be taken that differences between CPs remain (until 2020). In the sensitivity analysis under an optimistic
variant with respect to CP-specific financing conditions a rapid alignment (i.e. until 2020) will be assumed.
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expressing the RES share in gross final energy demand in 2020 by CP according to assessed Green-X
scenarios. The basket of assessed cases includes four distinct scenarios: two policy scenarios (i.e. CPI
and CPI + PPI) combined with two distinct demand developments (i.e. reference and efficiency
trend, originally based on CPs NREAPs but corrected in accordance with actual demand
developments).This graph allows for a comparison with targeted RES volumes, showing the binding
2020 RES target as given by the RES directive. Results suggest that only one CP, that is Montenegro,
is expected to reach the given 2020 target with currently implemented and planned policy
measures. Another CP, namely Moldova may be added to that list where expected 2020 RES
deployment is slightly below the given target according to Green-X scenarios. 7 Despite the expected
increase in absolute terms, Bosnia Herzegovina and Ukraine would for example fail to achieve their
2020 RES targets. At the aggregated level (all Contracting Parties in total) a comparison of the
expected and targeted 2020 RES share points out that a gap in size of about 4 to 6 percentage points
would occur if no additional policy revisions (to the ones implemented or planned) are undertaken.
RES Share vs. RED/NREAP Trajectories 2020
[%]
CPI min
50%
CPI max
CPI+PPI min
CPI+PPI max
NREAP Planned Trajectory 2020
RED Target 2020
Expected future RES deployment
(Green-X scenarios)
40%
30%
20%
10%
0%
Albania
Bosnia and
Herzegovina
Kosovo*
Moldova
Montenegro
FYR of
Macedonia
Serbia
Ukraine
Figure 32: Expected RES share in 2020 vs. 2020 RED minimum trajectory and 2020 indicative (NREAP) target (%).
Next a closer look is taken on the expected progress in meeting planned (i.e. according to NREAPs)
RES deployment by 2020 (see Table 9 and Figure 33). More precisely, Table 9 lists ranges for the
expected 2020 RES deployment in accordance with currently implemented policy initiatives (CPI) and
if in addition also planned measures are taken into consideration (CPI + PPI) and compares them
with the required (RED target) and the planned RES shares by CP. A graphical illustration of the
deviation of expected RES deployment from the indicatively targeted one – that is the planned
progress as prescribed in the CP’s progress reports – is given by Figure 33. As applicable from Table
9, only few CPs have established a higher RES deployment target than their required one, namely
Moldova and Montenegro. Thus, the number of countries that are expected to meet their planned
trajectory is diminishing compared to above – i.e. only Montenegro of the CPs is expected to meet
its indicative NREAP target. This does not change even if optimistic framework conditions like a low
7
Considering the underlying uncertainty a target achievement appears feasible for Moldova under more enhanced RES market
developments than the projected ones.
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demand growth (in accordance with the energy efficiency demand scenario) are assumed and
planned RES policy initiatives in addition to currently implemented ones are taken into
consideration. Generally, deviations are modest in Serbia and highest in Ukraine.
Table 11: Expected, planned and required RES shares in 2020.
RES share in gross final
energy demand by 2020
Contracting Party
Albania
Bosnia and Herzegovina
Kosovo*
Moldova
Montenegro
FYR of Macedonia
Serbia
Ukraine
% Deviation from indicative target (NREAP
trajectory) by 2020
CPI min
Expected RES
share 2020 (CPI
scenario)
Expected RES
share 2020
(CPI+PPI
scenario)
RED target
2020
NREAP Deviation of expected
Deviation of expected
planned
from minimum
from planned 2020
trajectory - trajectory 2020 share
share (CPI and
(CPI and CPI+PPI
RES share
CPI+PPI scenario)
scenario)
2020
Mi n.
Ma x.
Mi n.
Ma x.
Mi n.
Ma x.
Mi n.
[%]
[%]
[%]
[%]
[%]
[%]
[%]
[%]
[%]
[%]
27,1%
31,7%
17,6%
13,2%
43,9%
23,3%
23,5%
5,6%
29,9%
33,6%
19,4%
15,7%
46,5%
24,4%
25,6%
6,1%
28,3%
30,9%
17,9%
14,1%
45,1%
23,0%
23,8%
6,6%
31,2%
32,7%
19,7%
16,7%
47,8%
24,1%
25,9%
7,1%
38,0%
40,0%
25,0%
17,0%
33,0%
28,0%
27,0%
11,0%
38,1%
40,0%
25,0%
20,0%
35,9%
28,0%
27,0%
11,0%
-28,6%
-17,9%
-28,7%
-18,0%
-22,7%
-16,0%
-22,7%
-16,0%
-29,5%
-21,2%
-29,5%
-21,2%
-22,2%
-1,9%
-33,8%
-16,6%
CPI max
CPI+PPI min
Ma x.
33,0%
44,8%
22,3%
33,1%
-17,8%
-13,0%
-17,9%
-13,1%
-12,8%
-4,0%
-12,8%
-4,0%
-48,8%
-35,5%
-48,8%
-35,5%
CPI+PPI max
Expected future RES deployment (Green-X scenarios)
30%
20%
10%
0%
-10%
-20%
-30%
-40%
-50%
Albania
Bosnia and
Herzegovina
Kosovo*
Moldova
Montenegro
FYR of
Macedonia
Serbia
Ukraine
Figure 33: Deviation of expected RES shares (Green-X scenarios) from indicative (NREAP) target by 2020.
Complementary to above, Figure 34 indicates for each CP the expected 2020 RES deployment in
absolute terms, that is, the sum of electricity, heat and transport fuels stemming from renewable
sources. For comparison also historic data is provided, showing actual RES generation (with
normalisation of the electricity produced at hydropower plants) in the year 2013. Apparently, in all
CPs a moderate increase in RES deployment can be expected in forthcoming years. Remarkably are
for example expected developments in Bosnia & Herzegovina and in Ukraine where the scenarios
indicate considerable increases in RES deployment in forthcoming years. Despite these growth
trends, it can however be expected that – with the exception of Montenegro – all CPs fail to comply
with their own plans.
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RES deployment vs. NREAP Trajectory 2020
[ktoe]
CPI min
9.000
CPI max
CPI+PPI min
CPI+PPI max
NREAP Planned Trajectory 2020
status quo (2013)
Expected future RES deployment
(Green-X scenarios)
8.000
7.000
6.000
5.000
4.000
3.000
2.000
1.000
0
Albania
Bosnia and
Herzegovina
Kosovo*
Moldova Montenegro
FYR of
Macedonia
Serbia
Ukraine
Figure 34: Actual (2012) and expected RES deployment (in absolute terms) in 2020 vs. 2020 indicative (NREAP) target.
RES deployment in the electricity sector
Next a closer look is taken at the electricity sector, presenting the outcomes of the assessment of
expected future progress in generating electricity from renewable sources in all CPs of the Energy
Community. For the year 2020 Figure 35 compares the expected (according to Green-X scenarios)
and the planned (i.e. the indicative NREAP targets) progress of RES in the electricity sector, showing
RES-E deployment in relative terms, that is the RES-E share in gross electricity demand by CP.
Complementary to this graph, Figure 36 illustrates the deviation of expected RES-E deployment from
the indicatively targeted one (i.e. the planned progress as prescribed in the CP’s NREAPs). In both
figures uncertainty related to the development of future energy demand is reflected, illustrating
lower (i.e. CPI min, CPI + PPI min) and upper levels (CPI max, CPI + PPI max) of expected RES-E shares
in gross electricity consumption.
RES-E Share vs. NREAP Trajectory 2020 [%]
CPI min
80%
CPI max
CPI+PPI min
CPI+PPI max
NREAP Planned Trajectory 2020
Expected future RES deployment
(Green-X scenarios)
70%
60%
50%
40%
30%
20%
10%
0%
Albania
Bosnia and
Herzegovina
Kosovo*
Moldova
Montenegro
FYR of
Macedonia
Serbia
Ukraine
Figure 35: Expected RES-E share in 2020 vs. 2020 indicative (NREAP) target (%).
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% Deviation from indicative target (NREAP
trajectory) by 2020
30%
CPI min
20%
CPI max
10%
CPI+PPI min
0%
CPI+PPI max
-10%
-20%
-30%
-40%
-50%
-60%
-70%
-80%
Albania
Bosnia and
Herzegovina
Kosovo*
Moldova Montenegro
FYR of
Macedonia
Serbia
Ukraine
Figure 36: Deviation of expected RES-E shares (Green-X scenarios) from indicative (NREAP) target by 2020.
It is applicable that none of the eight CPs is expected to comply with own deployment plans. Thus, in
all CPs expected deployment lacks behind the planned one. The gap appears comparatively low in
CPs like Moldova, Montenegro or Serbia, whereas high deviations are apparent for Kosovo*, FYR of
Macedonia, Albania and Ukraine. Thus, in those CPs a strengthening and fine tuning of policy
initiatives offering adequate support for all available RES-E technologies and a rapid removal of noncost barriers that hinder a rapid take-off of RES-E appear indispensable for achieving 2020
deployment plans and for meeting overall binding RES targets. As stated in the introductory part to
this section, for Bosnia & Herzegovina a comparison of expected to (in accordance with NREAP)
planned deployment could not be undertaken since no NREAP has been provided so far.
RES-E deployment vs. NREAP Trajectory
2020 [ktoe]
CPI min
30.000
CPI max
CPI+PPI min
CPI+PPI max
NREAP Planned Trajectory 2020
Expected future RES deployment
(Green-X scenarios)
25.000
20.000
15.000
10.000
5.000
0
Albania
Bosnia and
Herzegovina
Kosovo*
Moldova Montenegro
FYR of
Macedonia
Serbia
Ukraine
Figure 37: Expected RES-E deployment (in absolute terms) in 2020 vs. 2020 indicative (NREAP) target.
In accordance with above, Figure 37 provides the corresponding illustration for 2020 RES-E
generation in absolute terms, comparing again planned with expected 2020 RES-E deployment.
Generally, results show a similar picture as discussed above when looking at RES-E deployment in
relative terms. Only for Montenegro a slight change can be identified: expected renewable
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electricity deployment comes closer to the planned one, indicating a higher demand growth than
originally anticipated (in NREAPs).
Table 12: Comparison of planned and expected deployment - Biomass
Comparison of planned (NREAP) and expected deployment (Green-X) by 2020 [GWh]
Solid & liquid biomass
(incl. biowaste) for
electricity generation
Albania
Indicate Target (NREAP
trajectory)
Expected deployment (Green-X)
min.
CPI
max.
min.
CPI+PPI
max.
Bosnia and
Herzegovina
Kosovo*
Moldova Montenegro
FYR of
Macedonia
Serbia
Ukraine
186.1
0.0
37.5
0.0
81.2
50.0
640.0
2950.0
0.7
0.7
2.1
2.1
45.5
45.5
45.5
45.5
3.9
3.9
8.0
8.0
0.0
0.0
0.0
0.0
11.6
11.6
26.1
26.1
62.6
62.6
116.0
116.0
223.6
223.6
288.6
288.6
140.5
140.5
301.0
301.0
% Deviation from indicative target (NREAP
trajectory) by 2020
150%
CPI min
100%
CPI max
CPI+PPI min
50%
CPI+PPI max
0%
-50%
-100%
-150%
Albania
Bosnia and
Herzegovina
Kosovo*
Moldova
Montenegro
FYR of
Macedonia
Serbia
Ukraine
Figure 38: Deviation from indicative target - Biomass
With respect to electricity production from solid and liquid biomass, Figure 38 highlights the
deviations from the actually planned progress to the expected development according to the CPI and
PPI scenarios for the year 2020 on CP level. At first it has to be mentioned that due to the missing
NREAP of Bosnia and Herzegovina a comparison was not feasible. Secondly, according to its NREAP
Moldova has not planned to use biomass for electricity generation. Looking at the modelling results
of the expected deployment of the other six CPs, only FYR of Macedonia will reach its target for this
technology. In case all where planned policy initiatives are assumed being implemented the target
would be overachieved by more than 100%.
All other CPs are expected not to meet their targets for electricity generation from biomass by at
least 50%. The strongest deviations can be observed in Albania and Ukraine.
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Table 13: Comparison of planned and expected deployment - Biogas
Comparison of planned (NREAP) and expected deployment (Green-X) by 2020 [GWh]
Biogas for electricity
generation
Albania
Indicate Target (NREAP
trajectory)
Expected deployment (Green-X)
min.
CPI
max.
min.
% Deviation from indicative target (NREAP
trajectory) by 2020
CPI+PPI
max.
Bosnia and
Herzegovina
Kosovo*
Moldova Montenegro
FYR of
Macedonia
Serbia
Ukraine
0.0
0.0
0.0
31.0
19.8
30.0
305.0
1270.0
14.6
14.6
23.6
23.6
29.4
29.4
29.4
29.4
12.2
12.2
15.9
15.9
8.9
8.9
17.1
17.1
0.0
0.0
0.0
0.0
14.7
14.7
22.1
22.1
65.6
65.6
87.7
87.7
264.7
264.7
392.5
392.5
0%
-20%
-40%
-60%
-80%
-100%
CPI min
CPI max
CPI+PPI min
CPI+PPI max
-120%
Albania
Bosnia and
Herzegovina
Kosovo*
Moldova
Montenegro
FYR of
Macedonia
Serbia
Ukraine
Figure 39: Deviation from indicative target - Biogas
Figure 39 shows the deviations between planned and expected deployment of electricity generation
from biogas. Albania, Bosnia and Herzegovina and Kosovo* have not planned to use biogas for
electricity generation, but modelling results indicate expectations to reach a comparatively
significant biogas deployment in the range of 12 to 29 GWh by 2020.
All other CPs are expected not to reach their envisaged deployment targets. Among all CPs strongest
deviations are expected in Montenegro since they are not expected to reach any deployment of
biogas electricity.
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Table 14: Comparison of planned and expected deployment - Geothermal
Comparison of planned (NREAP) and expected deployment (Green-X) by 2020 [GWh]
Geothermal electricity
Indicate Target (NREAP
trajectory)
Expected deployment (Green-X)
min.
CPI
max.
min.
CPI+PPI
max.
Albania
Bosnia and
Herzegovina
Kosovo*
Moldova Montenegro
FYR of
Macedonia
Serbia
Ukraine
0.0
0.0
0.0
0.0
0.0
0.0
7.0
120.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
4.0
4.0
4.0
4.0
0.0
0.0
0.0
0.0
% Deviation from indicative target (NREAP
trajectory) by 2020
0%
CPI min
CPI max
CPI+PPI min
CPI+PPI max
-10%
-20%
-30%
-40%
-50%
-60%
-70%
-80%
-90%
-100%
Albania
Bosnia and
Herzegovina
Kosovo*
Moldova
Montenegro
FYR of
Macedonia
Serbia
Ukraine
Figure 40: Deviation from indicative target - Geothermal
Only Serbia and Ukraine stated any technology specific targets for electricity generation from
geothermal sources in their NREAPs. Whereas Serbia is expected to meet 57% of its target, Ukraine
seems not to reach any significant deployment of geothermal electricity generation due to missing
policy initiatives.
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Table 15: Comparison of planned and expected deployment - Hydro
Comparison of planned (NREAP) and expected deployment (Green-X) by 2020 [GWh]
Hydropower
Albania
Indicate Target (NREAP
trajectory)
Expected deployment (Green-X)
min.
CPI
max.
min.
% Deviation from indicative target (NREAP
trajectory) by 2020
CPI+PPI
max.
Bosnia and
Herzegovina
Kosovo*
Moldova Montenegro
FYR of
Macedonia
Serbia
Ukraine
9271.0
0.0
965.4
81.0
2050.0
2800.0
11415.0
13340.0
6209.7
6209.7
6548.9
6548.9
6738.0
6738.0
6738.0
6738.0
365.0
365.0
415.3
415.3
109.5
109.5
143.7
143.7
2191.1
2191.1
2285.6
2285.6
1803.3
1803.3
1849.4
1849.4
11350.8
11350.8
11667.5
11667.5
12663.4
12663.4
12653.2
12653.2
100%
80%
CPI min
60%
CPI max
40%
CPI+PPI min
CPI+PPI max
20%
0%
-20%
-40%
-60%
-80%
-100%
Albania
Bosnia and
Herzegovina
Kosovo*
Moldova Montenegro
FYR of
Macedonia
Serbia
Ukraine
Figure 41: Deviation from indicative target – Hydro
Table 15 shows the comparison between planned and expected deployment of electricity generation
from hydropower. Compared to the before mentioned technologies Figure 41 shows a more diverse
picture among the CPs.
Whereas Albania, Kosovo* 8 and FYR of Macedonia are not expected to meet their targets for
hydropower, Montenegro, Serbia and Ukraine are on track to reach the envisaged generation from
hydropower. The expected result for electricity generation from hydropower in Moldova shows a
comparatively significant overachievement of the envisaged target. This is true only if all
hydropower plants are built well in time to assure their contribution towards target achievement by
2020.
8
In particular for Kosovo* it appears consequently necessary to adapt renewable energy planning to assure overall RES target
achievement in the likely event that planned large-scale hydropower plants will not become operational by 2020.
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Table 16: Comparison of planned and expected deployment - Photovoltaics
Comparison of planned (NREAP) and expected deployment (Green-X) by 2020 [GWh]
Photovoltaics
Albania
Indicate Target (NREAP
trajectory)
Expected deployment (Green-X)
min.
CPI
max.
min.
% Deviation from indicative target (NREAP
trajectory) by 2020
CPI+PPI
max.
Bosnia and
Herzegovina
Kosovo*
Moldova Montenegro
FYR of
Macedonia
Serbia
Ukraine
0.0
0.0
10.3
0.0
16.5
43.0
13.0
2420.0
0.0
0.0
0.0
0.0
49.6
49.6
49.6
49.6
0.0
0.0
0.0
0.0
11.9
11.9
29.1
29.1
0.0
0.0
0.0
0.0
0.2
0.2
0.2
0.2
24.5
24.5
51.0
51.0
109.9
109.9
187.6
187.6
Kosovo*
Moldova Montenegro
350%
300%
250%
200%
150%
CPI min
CPI max
CPI+PPI min
CPI+PPI max
100%
50%
0%
-50%
-100%
-150%
Albania
Bosnia and
Herzegovina
FYR of
Macedonia
Serbia
Ukraine
Figure 42: Deviation from indicative target – Photovoltaics
Looking at Figure 42 one can see that only Serbia will reach its target for electricity generation from
photovoltaics. In case Serbia would implement all planned policy initiatives this could even lead to a
surplus in target achievement by more than 250%.
Albania, Bosnia and Herzegovina and Moldova did not indicate a specific target for photovoltaics, so
a comparison was not feasible.
According to the modelling results neither Kosovo* nor Montenegro nor FYR of Macedonia will
reach any significant deployment of photovoltaics with their current and planned policy initiatives.
Ukraine would reach a modest deployment of photovoltaics which would not be high enough to
reach its target as stated in its NREAP.
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Table 17: Comparison of planned and expected deployment - Wind onshore
Comparison of planned (NREAP) and expected deployment (Green-X) by 2020 [GWh]
Wind onshore
Albania
Indicate Target (NREAP
trajectory)
Expected deployment (Green-X)
min.
CPI
max.
min.
CPI+PPI
max.
% Deviation from indicative target (NREAP
trajectory) by 2020
Albania
Bosnia and
Herzegovina
Kosovo*
Moldova Montenegro
FYR of
Macedonia
Serbia
Ukraine
165.0
0.0
125.2
372.2
347.8
400.0
1000.0
5900.0
0.0
0.0
0.0
0.0
75.2
75.2
75.2
75.2
0.0
0.0
0.0
0.0
196.1
196.1
409.5
409.5
265.6
265.6
285.8
285.8
95.7
95.7
95.7
95.7
110.0
110.0
110.0
110.0
909.3
909.3
1299.2
1299.2
Bosnia and
Herzegovina
Kosovo*
FYR of
Moldova Montenegro Macedonia
Serbia
Ukraine
20%
0%
-20%
-40%
-60%
-80%
-100%
CPI min
CPI max
CPI+PPI min
CPI+PPI max
-120%
Figure 43: Deviation from indicative target - Wind onshore
Figure 43 shows the deviation of the CPs expected deployment of wind onshore compared to their
NREAP targets. According to the modelling results Albania and Kosovo* fail to reach any wind
onshore deployment despite their currently implemented and planned policy initiatives. FYR of
Macedonia succeeded to finish its first wind farm but fails to expand its wind onshore capacities any
further.
Serbia and Ukraine are expected to manage installing some wind onshore capacities but not enough
to reach their targets as indicated in their NREAPs.
Regarding target achievement Moldova and Montenegro show the most promising picture.
Montenegro is expected to reach at least close to 80% of its target, whereas Moldova has the
chance to slightly overachieve its target, given that all planned policy initiatives will be implemented.
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RES deployment in heating and cooling
Expected and planned progress in using renewables in heating and cooling is compared below across
all CPs. In this context, a comparison of the expected (according to Green-X scenarios) and the
planned (i.e. the indicative NREAP targets) progress in terms of RES in heating and cooling is shown
in Figure 44, expressing RES-H deployment in relative terms, that is the share of RES-H in the
corresponding sector demand by CP. A closer look at the deviation of the expected RES-H share from
the indicatively targeted one (i.e. the planned progress as prescribed in the CP’s NREAPs) is then
provided in Figure 45. Similar to above, in both figures uncertainty related to the development of
future energy demand is reflected, illustrating lower (i.e. CPI min, CPI + PPI min) and upper levels
(CPI max, CPI + PPI max) of expected RES-H shares in gross final heat consumption.
RES-H Share vs. NREAP Trajectory 2020 [%]
CPI min
90%
CPI max
CPI+PPI min
CPI+PPI max
NREAP Planned Trajectory 2020
Expected future RES deployment
(Green-X scenarios)
80%
70%
60%
50%
40%
30%
20%
10%
0%
Albania
Bosnia and
Herzegovina
Kosovo*
Moldova
Montenegro
FYR of
Macedonia
Serbia
Ukraine
% Deviation from indicative target (NREAP
trajectory) by 2020
Figure 44: Expected RES-H share in 2020 vs. 2020 indicative (NREAP) target (%).
CPI min
120%
CPI max
CPI+PPI min
CPI+PPI max
100%
80%
60%
40%
20%
0%
-20%
-40%
-60%
Albania
Bosnia and
Herzegovina
Kosovo*
Moldova
Montenegro
FYR of
Macedonia
Serbia
Ukraine
Figure 45: Deviation of expected RES-H shares (Green-X scenarios) from indicative (NREAP) target by 2020.
It is applicable that four of the eight CPs, namely Kosovo* (in the case of a low demand growth),
Montenegro, FYR of Macedonia and Serbia, are on track for complying with expressed deployment
plans, whereas substantial positive deviations are applicable for Ukraine. Please note however that
Montenegro represent here a special case because of the retrospective change of the statistical
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accounting for solid biomass in the heating and cooling sector as explained in Box 2. In the
remainder of CPs expected deployment is below the planned one and a significant gap can be
identified, in addition to Ukraine, also for Albania and Moldova.
RES-H deployment vs. NREAP Trajectory 2020
[ktoe]
CPI min
6.000
CPI max
CPI+PPI min
CPI+PPI max
NREAP Planned Trajectory 2020
Expected future RES deployment
(Green-X scenarios)
5.000
4.000
3.000
2.000
1.000
0
Albania
Bosnia and
Herzegovina
Kosovo*
Moldova
Montenegro
FYR of
Macedonia
Serbia
Ukraine
Figure 46: Expected RES-H deployment (in absolute terms) in 2020 vs. 2020 indicative (NREAP) target.
Complementary to above, Figure 46 shows RES-H generation in absolute terms, comparing again
planned with expected 2020 renewables deployment. It can be seen that CPs like Moldova or
Albania achieve a higher progress than when comparing RES-H deployment in relative terms
whereas for Serbia non-compliance with expressed plans can be identified. This points out that
demand expectations do not in all cases match properly with actual (or according to recent statistics
expected) demand developments – for example in Serbia actual demand is lower than the expected
one (as reported in the Serbian NREAP).
Compared to other sectors, the sector of heating and cooling offers comparatively promising
potentials for renewables due to suitable framework conditions like high solar infeed in Western
Balkans or a high potential of biomass feedstock. Thus, renewables in heating and cooling can be
classified as “low hanging fruits” in all CPs. As discussed subsequently, biomass is here the key
renewable source both in terms of planned and according to modelling expected deployment
whereas other promising renewable options like solar thermal heat, the use of heat pumps or of
geothermal resources are generally underrepresented in policy making and in market
establishments. A combination of tailored incentives and campaigns to increase public awareness
may consequently serve well to increase demand for renewable sources in heating and cooling.
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Table 18: Comparison of planned and expected deployment - Biogas (Heat)
Comparison of planned (NREAP) and expected deployment (Green-X) by 2020 [ktoe]
Biogas for heat generation
(incl. heat from CHP)
Albania
Indicate Target (NREAP
trajectory)
Expected deployment (Green-X)
min.
CPI
max.
min.
CPI+PPI
max.
% Deviation from indicative target (NREAP
trajectory) by 2020
Albania
Bosnia and
Herzegovina
Kosovo*
Moldova Montenegro
FYR of
Macedonia
Serbia
Ukraine
0.0
0.0
0.0
0.0
0.0
8.0
10.0
150.0
0.1
0.1
0.1
0.1
0.2
0.2
0.2
0.2
0.1
0.1
0.1
0.1
0.3
0.3
0.3
0.3
0.0
0.0
0.0
0.0
0.3
0.3
0.3
0.3
0.9
0.9
0.9
0.9
2.5
2.5
2.5
2.5
Bosnia and
Herzegovina
Kosovo*
FYR of
Moldova Montenegro Macedonia
Serbia
Ukraine
0%
-20%
-40%
-60%
-80%
-100%
CPI min
CPI max
CPI+PPI min
CPI+PPI max
-120%
Figure 47: Deviation from indicative target - Biogas (Heat)
Figure 47 shows the deviation of the CPs expected deployment of biogas in the heat sector
compared to their targets of the NREAPs. Albania, Bosnia and Herzegovina, Kosovo*, Moldova and
Montenegro did not state any specific targets for biogas in the heat sector, so no comparison was
applicable. FYR of Macedonia, Serbia and Ukraine stated targets for this technology in their NREAPs
but all of them are expected to meet only less than 10% of their targets.
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Table 19: Comparison of planned and expected deployment - Biomass (Heat)
Comparison of planned (NREAP) and expected deployment (Green-X) by 2020 [ktoe]
Solid & liquid biomass
(incl. biowaste) for heat
generation
Albania
Indicate Target (NREAP
trajectory)
Expected deployment (Green-X)
min.
CPI
max.
min.
CPI+PPI
max.
% Deviation from indicative target (NREAP
trajectory) by 2020
120%
100%
80%
Bosnia and
Herzegovina
Kosovo*
Moldova Montenegro
FYR of
Macedonia
Serbia
Ukraine
0.0
0.0
284.1
334.0
108.0
250.0
1142.0
4850.0
295.4
295.4
302.2
302.2
1025.7
1025.7
983.5
983.5
284.3
284.3
284.5
284.5
339.2
339.2
337.8
337.8
229.7
229.7
230.4
230.4
441.0
441.0
425.0
425.0
1125.7
1125.7
1114.5
1114.5
3578.9
3578.9
3584.1
3584.1
Kosovo*
Moldova
Montenegro
CPI min
CPI max
CPI+PPI min
CPI+PPI max
60%
40%
20%
0%
-20%
-40%
Albania
Bosnia and
Herzegovina
FYR of
Macedonia
Serbia
Ukraine
Figure 48: Deviation from indicative target - Biomass (Heat)
Table 19 shows that only Albania and Bosnia and Herzegovina have not expressed any plans for the
use of biomass in the heating sector. Looking at Figure 44 it appears that Kosovo* and Serbia are
well on the way to meet their NREAP targets, while Montenegro and FYR of Macedonia are expected
to reach an overachievement of its NREAP target of at least 110% (Montenegro) and 70% (FYR of
Macedonia), respectively. In the case of Montenegro the overachievement is mainly caused by the
retrospective change in the statistical accounting for solid biomass in the heating and cooling sector
explained in Box 2.
According to the modelling results Ukraine is not going to reach the envisaged deployment of
biomass in the heating sector – thus, it is expected to meet approximately only three quarters of its
respective targets. This has important consequences on overall RES target achievement since
biomass heat would be a key contributor.
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Table 20: Comparison of planned and expected deployment - Geothermal (Heat)
Comparison of planned (NREAP) and expected deployment (Green-X) by 2020 [ktoe]
Geothermal heat
Albania
Indicate Target (NREAP
trajectory)
Expected deployment (Green-X)
min.
CPI
max.
min.
% Deviation from indicative target (NREAP
trajectory) by 2020
CPI+PPI
max.
150%
100%
50%
Bosnia and
Herzegovina
Kosovo*
Moldova Montenegro
FYR of
Macedonia
Serbia
Ukraine
0.0
0.0
0.0
0.0
0.0
49.0
10.0
50.0
0.1
0.1
0.1
0.1
0.3
0.3
0.3
0.3
0.1
0.1
0.1
0.1
0.2
0.2
0.2
0.2
0.1
0.1
0.1
0.1
5.4
5.4
5.4
5.4
5.4
5.4
6.4
6.4
102.1
102.1
102.1
102.1
CPI min
CPI max
CPI+PPI min
CPI+PPI max
0%
-50%
-100%
Albania
Bosnia and
Herzegovina
Kosovo*
Moldova
Montenegro
FYR of
Macedonia
Serbia
Ukraine
Figure 49: Deviation from indicative target - Geothermal (Heat)
Table 20 shows that three CPs indicated targets for the deployment of geothermal heat generation
in their NREAPs. FYR of Macedonia and Serbia are expected to fail meeting their targets, whereas
Ukraine appears to reach a deployment twice as high as its 50 ktoe target.
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Table 21: Comparison of planned and expected deployment - Solar thermal (Heat)
Comparison of planned (NREAP) and expected deployment (Green-X) by 2020 [ktoe]
Solar thermal heating &
cooling (incl. hot water
supply)
Albania
Indicate Target (NREAP
trajectory)
Expected deployment (Green-X)
min.
CPI
max.
min.
% Deviation from indicative target (NREAP
trajectory) by 2020
CPI+PPI
max.
Bosnia and
Herzegovina
Kosovo*
Moldova Montenegro
FYR of
Macedonia
Serbia
Ukraine
0.0
0.0
12.9
8.0
3.3
9.0
5.0
200.0
21.9
21.9
21.9
21.9
3.9
3.9
3.9
3.9
6.5
6.5
6.5
6.5
1.6
1.6
2.9
2.9
0.8
0.8
0.8
0.8
2.5
2.5
2.5
2.5
0.0
0.0
0.0
0.0
18.7
18.7
18.7
18.7
0%
-20%
-40%
-60%
-80%
CPI min
CPI max
-100%
CPI+PPI min
CPI+PPI max
-120%
Albania
Bosnia and
Herzegovina
Kosovo*
Moldova
Montenegro
FYR of
Macedonia
Serbia
Ukraine
Figure 50: Deviation from indicative target - Solar thermal (Heat)
According to the modelling assessment none of the examined CPs will meet its target in the solar
thermal heating sector. Table 21 shows that with the currently implemented and planned policy
initiatives Serbia is not expected reach any deployment in the solar thermal heating sector. Kosovo*,
Moldova, Montenegro Serbia and Ukraine will miss their targets by 50% to 90%.
Table 21 also shows that Albania, Bosnia and Herzegovina and Kosovo* did not state any technology
specific target but are expected to deploy some solar thermal capacities which would lead to an
annual heat generation between 4 and 22 ktoe.
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Table 22: Comparison of planned and expected deployment - Heat pumps (Heat)
Comparison of planned (NREAP) and expected deployment (Green-X) by 2020 [ktoe]
Heat pumps
Albania
Indicate Target (NREAP
trajectory)
Expected deployment (Green-X)
min.
CPI
max.
min.
% Deviation from indicative target (NREAP
trajectory) by 2020
CPI+PPI
max.
Bosnia and
Herzegovina
Kosovo*
Moldova Montenegro
FYR of
Macedonia
Serbia
Ukraine
0.0
0.0
1.3
0.0
10.2
0.0
0.0
600.0
2.2
2.2
2.2
2.2
2.6
2.6
2.4
2.6
3.5
3.5
3.5
3.5
2.4
2.4
2.9
2.9
0.4
0.4
0.4
0.4
1.4
1.4
1.4
1.4
5.1
5.1
5.9
5.9
46.0
46.0
46.0
46.0
200%
CPI min
CPI max
CPI+PPI min
CPI+PPI max
150%
100%
50%
0%
-50%
-100%
Albania
Bosnia and
Herzegovina
Kosovo*
Moldova Montenegro
FYR of
Macedonia
Serbia
Ukraine
Figure 51: Deviation from indicative target - Heat pumps (Heat)
Table 22 shows that all CPs will reach a certain deployment of heat pumps even though only three
CPs stated indicative targets in their NREAPs. The expected generation of the respective capacities
ranges from 0.4 ktoe (Montenegro) to 46 ktoe (Ukraine). From the CPs, that stated technology
specific targets for heat pumps only Kosovo* will reach its target. According to the modelling results
Kosovo* will reach 3.5 ktoe instead of its envisaged 1.3 ktoe.
In contrast to Kosovo*, neither Montenegro nor Ukraine will reach their envisaged targets.
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Biofuels deployment in the transport sector
Expected and planned progress in using biofuels in the transport sector is discussed next. First,
Figure 52 indicates the expected (according to Green-X scenarios) progress in terms of using biofuels
as transport fuel. More precisely, this graph shows biofuels deployment in relative terms, that is the
share of biofuels in total transport fuel demand by CP. Note that a comparison to CP plans as set out
in the NREAPs with respect to the biofuel share is not feasible since CPs were not asked to specify
demand trends in that detail in their NREAPs. In contrast to above, a comparison of biofuel
deployment in absolute terms, that is consumed diesel or gasoline of biomass origin, is feasible with
data provided in NREAPs. In accordance with above, Figure 53 shows biofuel deployment in absolute
terms, comparing planned with expected 2020 deployment. The deviation of the expected from the
indicatively targeted one (i.e. the planned progress as prescribed in the CP’s NREAPs) is then
illustrated in Figure 54.
CPI min
CPI+PPI min
CPI+PPI max
Expected future RES deployment (Green-X scenarios)
7%
6%
5%
4%
3%
2%
Ukraine
Serbia
FYR of
Macedonia
Montenegro
Moldova
Kosovo*
0%
Bosnia and
Herzegovina
1%
Albania
Biofuel share in road transport 2020 [%]
8%
CPI max
Figure 52: Expected biofuel share in 2020 (%).
It is applicable that only one of the eight CPs, namely Ukraine, is on track for achieving expressed
deployment plans. In all other CPs expected deployment is below the planned one, or, more
precisely, in the absence of clear policy incentives (i.e. a blending obligation put into force) no
biofuel consumption in 2020 is expected in all assessed cases.
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Biofuel deployment vs. NREAP Trajectory
2020 [ktoe]
CPI min
CPI max
900
CPI+PPI min
CPI+PPI max
NREAP Planned Trajectory 2020
Expected future RES deployment
(Green-X scenarios)
800
700
600
500
400
300
200
100
0
Albania
Bosnia and
Herzegovina
Kosovo*
Moldova
Montenegro
FYR of
Macedonia
Serbia
Ukraine
Figure 53: Expected biofuel deployment (in absolute terms) in 2020 vs. 2020 indicative (NREAP) target.
% Deviation from indicative target (NREAP
trajectory) by 2020
150%
CPI min
100%
50%
CPI max
CPI+PPI min
CPI+PPI max
0%
-50%
-100%
-150%
Albania
Bosnia and
Herzegovina
Kosovo*
Moldova Montenegro
FYR of
Macedonia
Serbia
Ukraine
Figure 54: Deviation of expected biofuel deployment (Green-X scenarios) from indicative (NREAP) target by 2020.
With respect to biofuels in transport it can be concluded that the establishment of a real market for
biofuel is key for almost all of the CPs. Blending obligations, partly combined with tax exemptions for
the use of biofuels, are simple and straightforward policy measures that allow for that. This would
increase overall renewables deployment significantly in all CPs that have failed to do so in prior, and,
consequently, increase overall progress in terms of achieving binding 2020 RES targets.
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4 Analysis of biofuels and bioliquids consumed in Contracting
Parties
4.1 Overview of biofuel consumption, by type and origin of feedstock in Contracting
Parties
The production and consumption of biofuels in the transport sector is depicted in Table 23 for the
Energy Community Contracting Parties. The existing biofuel plants in each CP are presented in Table
24. Among the Contracting Parties FYR of Macedonia, Montenegro, Serbia and Ukraine have some
biofuel production and/or consumption. In the other CPs the production and consumption are either
null or only limited to self-consumption, mainly at the farmers level, and therefore regarded as null
in the table. While the very limited amount of current production and consumption relate to
biodiesels, Ukraine is the only CP with known bioethanol production.
In Albania, there is a biodiesel plant with a production capacity of 100.000 tons/year (86 ktoe)
however, only 10-15 kton are produced annually. All raw material (vegetable oil) is being imported
(countries of origin not exactly known) and the majority of the produced biodiesel is exported to
Italy, so the biofuel does not count towards the Albanian target.
A large biodiesel plant with a capacity of 500 ton/day exists in Bosnia and Herzegovina. The plant is
flexible to include feedstock such as vegetable oils, used cooking oil (UCO) and animal fats, but the
exact supply and how it has varied over the years is not known.
According to the Ministry of Economy in FYR of Macedonia, there are currently four companies with
biofuel production licenses issued. Makpetrol AD is the biggest producer with a production capacity
of 20 kton/year. This plant produces FAME biodiesel principally from non-refined oil from rapeseed
that is mainly imported. The majority of this biodiesel is exported since there is currently no
obligation on fuel suppliers to blend biofuels in the FYR of Macedonia. The other three companies
have a cumulative production capacity of 5 kton/year. Two other biodiesel plants have been planned
for construction, including a 13 kton/year privately owned plant which will produce FAME from
sunflower, rapeseed and soya. The vast majority of biofuel currently supplied is imported and
blended locally within FYR of Macedonia (E4Tech, 2014).
The information obtained so far (from the contacted stakeholders) only shows that there is no
bioethanol and biodiesel production nor consumption in Moldova. Biodiesel was previously
produced by Bio-Company-Raps, using rapeseed oil in a facility with a capacity of ~50 ton/day in
Moldova. However due to poor rapeseed harvests the company terminated production in 2009
(Exergia, 2014). The main ethanol plant is operated by Garma-Grup SRL and has a capacity of ~40
ton/day. However this ethanol is not sold domestically for road fuel (E4Tech; Exergia, 2014).
In Montenegro there is no biodiesel production and the biodiesel consumed is imported from Bosnia
and Herzegovina, and the country of origin is Austria (Ministry of Economy, Montenegro, 2015).
In Serbia, the lack of any government incentives for biofuel production and the high excise tax has
made biodiesel production unprofitable. For instance, a biodiesel factory with an annual installed
capacity of 100 kton (Victoria Group) produced around 25 ton of biodiesel from rapeseed in 2007.
However, they switched to edible oils rather than producing biodiesel for transport sector (Maslac,
2012). Another factory, FAM Kusevac, for which constructions started in 2011 as a state-owned
company, failed to be completed. Bioethanol as fuel is still not produced in Serbia. There are a few
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plants that produce ethanol for the production of alcoholic beverages and in the food and
pharmaceutical industry, with a total production capacity of around 23 kton/year. These amounts
are even not enough to fulfil the ethanol needs for beverages, medical and pharmaceutical purposes
in Serbia (Mojovic et al., 2013) (see Table 24).
Table 23: CP Biodiesel & bioethanol production and consumption in transport sector in 2009-2012 expressed as absolute
volumes (tons) (rounded up to nearest whole figure)
2009
Prod.
Albania
BiH
FYR of
Macedonia
Kosovo*
Moldova
Montenegro
Serbia
Ukraine
9
2010
Cons.
Prod.
2011
Cons.
Prod.
2012
Cons.
Prod.
2013
Cons.
29
Prod.
9
Cons.
Biodiesel
0
0
0
0
0
0
0
35
Bioethanol
0
0
0
0
0
0
0
0
0
0
biodiesel
0
0
0
0
0
0
0
0
0
0
Bioethanol
0
0
0
0
0
0
0
0
0
0
biodiesel
0
137
1502
557
4198
329
884
678/
267
74
678/
1047
Bioethanol
0
0
0
0
0
0
0
0
0
0
biodiesel
0
0
0
0
0
0
0
0
0
0
Bioethanol
0
0
0
0
0
0
0
0
0
0
biodiesel
0
0
0
0
0
0
0
0
0
biodiesel
0
0
0
0
0
0
0
1628
Bioethanol
0
0
0
0
0
0
0
0
0
biodiesel
0
0
0
0
0
0
0
1990
8371
bioethanol
0
0
0
0
0
0
0
0
0
0
biodiesel
0
0
0
0
0
0
0
0
0
0
Bioethanol
bioethanol
5814
0
384
This figure has been presented as ktoe in the progress report. Based on the contacts with the relevant stakeholders we concluded that
there has been a confusion with the unit and it should have been tons.
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Table 24: Names and the capacities of existing biodiesel and bioethanol factories
Name/owner of the plant
Albania
Green Fuel
Bosnia and Herzegovina
System Ecologica
FYR of Macedonia
Marpetrol AD
Biodi Kom
Bio International
Eko-biodiesel-mam
Moldova
Bio-Company-Raps
Garma-Grup SRL
Serbia
Victoria Oil, Šid
FAM Kruševac ( completed 85%,
stalled)
Bioplanta, Bačka Topola
BioenergoOil, Sombor
Crevnka-new plant
Crvenka – old plant
Kadaks – Crvenka
Kovin
Lukas – Bajmok
Srbobran
Vrenje- Belgrade
Ukraine
-
Type of product
Production capacity (kton/year)
biodiesel
100
biodiesel
164 10
biodiesel
biodiesel
biodiesel
20
5 (Cumulative)
biodiesel
biodiesel
Bioethanol (for other purposes
than road transport)
99 11
Biodiesel
100
Biodiesel
25
Biodiesel
biodiesel
Bioethanol (for other purposes
than road transport)
Bioethanol (for other purposes
than road transport)
Bioethanol (for other purposes
than road transport)
Bioethanol (for other purposes
than road transport)
Bioethanol (for other purposes
than road transport)
Bioethanol (for other purposes
than road transport)
Bioethanol (for other purposes
than road transport)
4 (with 16 planned)
1.4
bioethanol
-
13
6.2
3.1
0.5
6.2
0.3
0.8
There are a few interesting initiatives to develop biofuels in CPs. For instance, the government of
FYR of Macedonia joined a Memorandum of Understanding to facilitate the development of the
cellulosic ethanol market in the Pelagonia region between Ethanol Europe and DuPont in October
10
Production capacity is 500 ton/day. A 90% annual capacity is assumed to be utilized.
11
Capacity of Bio-company-Raps was 50 tons/day. We applied a 90% annual capacity utilization.
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2014. In Northern Serbia, a bioethanol refinery was being developed (investment 380 million € by
the Hungarian-American company BiotechEnergy). It is considered to be the largest Greenfield
investment in southeast Europe and envisaged to develop a technological process of bioethanol
production from cellulose.
Currently, there is no double counting of biofuels produced from wastes, residues, non-food
cellulosic material, and ligno-cellulosic material in the CPs.
4.2 Assessment biofuel potential of the Contracting Parties
In this study technical potentials of biofuel production, that depend on the land availability, residues
and feedstock and investment costs are analysed for each CP. Maximum technical potentials are
calculated and illustrated Figure 55. A more detailed description of the methodology can be found in
Annex II. In Figure 55 the comparison to the 2020 NREAP targets are also presented (for four of the
CPs: Moldova, Montenegro, Serbia and Ukraine). Overall, the technical potential of biofuels in each
CP is much higher when compared with the 2020 set targets. There is significantly more potential for
using ethanol-producing feedstock (such as wheat and corn) than oil seeds (such as soy and oilseed
rape).
According to the results, overall, domestic oilseed production would not be sufficient to satisfy the
2020 biodiesel targets set by the CPs. For instance, in Montenegro the set demand for biodiesel is
around 4 times the calculated potential in 2020. For Serbia, this is even much higher, approximately
6 times the technical potential. It should, however, be noted that the biofuel potential assessment
doesn’t include potentials for used cooking oils (UCO) 12 in this study. While imports of oilseed crops
or biodiesel will be crucial to meeting the target, the role of domestic crops such as wheat and corn
in producing ethanol and contributing to the target should be considered.
More details of the potential assessment results can be found in Annex II.
12
For instance, around 10 kton UCO for biodiesel production is estimated for Serbia (E4Tech, 2015; Program for realisation of the Energy
strategy for the period 2007-1212
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Figure 55: Biofuel potentials of the CPs in 2020 in comparison to the NREAP demand (ktoe)
4.3 Assessment of national measures to comply with EU sustainability criterial for
biofuels
Article 17(7) of the RES Directive requires CPs to report on the impact of biofuels on soil, air and
water protection as well as on social sustainability issues resulting from increased demand for
biofuel. This chapter reviews the existing or planned measures in the CPs based on the NREAPs and
Progress Reports to respect EU sustainability criteria, including measures for soil, water and air
protection and is split into three parts. The first part documents the status of the transposition of
the measures to respect sustainability criteria – a review of NREAPs and progress reports. Section
two looks into the measures to safeguard impacts on air, water and soil in the CPs, if there are any.
And the last section presents what has been done so far at the EU level to inform the Energy
Community Secretary and the respective CPs.
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4.3.1 Transposition of the measures to respect sustainability criteria
Review of NREAPs and Progress Reports
The Progress Reports are reviewed to address whether the legislation or regulations mentioned to
be adopted in the NREAPs have been adopted in the relevant period (until the Progress Report
issuance date).
Only FYR of Macedonia has drawn up the draft version of the law on biofuels, which is planned to be
adopted in the first half of 2015, including the introduction and implementation of sustainability
criteria for the production and supply of biofuels and bioliquids.
The draft Law on petroleum and petroleum products market in Kosovo* deals with biofuel-related
issues in general, while the targets for consumption of biofuels in transport and sustainability criteria
will be set by Administrative Instruction (AI) on Biofuel use in transport. The enactment of the draftlaw was planned in the second part of 2013, whereas the AI on use of biofuels in transport was
adopted within 2013 and entered into force in January 2014. According to the Progress Report of
Kosovo* the drafts have been made and they will be finalised and can be provided during 2015.
Currently, there is no specific legislation on sustainability criteria for biofuels in the Republic of
Moldova. However, ANRE will be the regulatory body in charge of monitoring the fulfilment of
sustainability criteria, once implemented.
In Montenegro, the Directive on the promotion of the use of biofuels or other renewable fuels for
transport (2003/30/EC), as well as part of the Directive on the promotion of the use of energy from
renewable energy sources (2009/28/EC) relating to biofuels and bioliquids, have not been
transposed into the legal system of Montenegro yet. Through the realisation of an IPA (2011) project
‘’Developing sustainable energy use’’ the sustainability criteria for biofuels and bioliquids and the
procedure for verification of the compliance with the sustainability criteria, as well as the calculation
methodology of the impact of biofuels and bioliquids on greenhouse gas emissions, are planned to
be established in secondary legislation. The service tender procedure for this project was cancelled
in 2012 due to deficiencies of the published procurement notice. In the same year a new tender had
been issued and again cancelled. This time, none of the tenders submitted were been found to be
technically compliant. In 2014, a contract notice has been issued and the provisional
commencement data of the contract is set as May 2015.
In Serbia, the Ministry of Energy, Development and Environmental Protection has formed a working
group, consisting of representatives of competent ministries. This Group will 1) decide on the system
and criteria to be applied for evaluation of sustainability of biofuels and bioliquids, and 2) prepare a
corresponding act on methods and conditions of implementation of the requirement of
sustainability in the production and use of biofuels. Within the preparation of the act, the manner of
implementation of the certification procedure will be defined. In the act on methods and conditions
of implementation of the requirement of biofuel sustainability a financial operator and the
authorized body will be appointed. So far (up to the PR) the by-laws defining sustainability criteria
and their verification have still not been adopted.
In Ukraine, measures that are set out in Directive 2009/28/EC (RED) related to the sustainability
criteria for biofuels and bioliquids have not yet been transposed. According to the 2014 PR, the
Cabinet of Ministers of Ukraine, the Ministry of Agricultural Policy and the State Agency on Energy
Efficiency and Energy Saving are working to develop the sustainability criteria for liquid and gaseous
fuels made from biomass and used in transport, as well as for liquid fuels made of biomass and
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intended for energy uses other than transport, taking into account the generation of electricity and
thermal energy.
Currently, the legislative framework to comply with the EU sustainability criteria is not in place in the
CPs. However, these will be essential in order to establish the conditions for their introduction and
subsequent contribution towards the renewable energy targets established in the Renewable Energy
Directive.
4.3.2 Measures taken for soil, water and air protection
In the Progress Reports, information on the estimated impacts of the production of biofuels and
bioliquids on biodiversity, water resources, water quality and soil quality in the preceding 2 years,
have been requested. The majority of the reactions have been either there was no production,
therefore, no impact or there was no information on estimated impacts of biofuel production.
In Serbia, the project “Elaboration of the Land Cadastre” is currently in course in the Ministry of
Agriculture, Forestry and Water Management. The Land Cadastre is expected to contain the
following information:
1) quality of soil (soil classification)
2) ownership data
3) land status
4) cultures grown on the land
5) photographs of the land.
Elaboration of the land cadastre should be completed in 2014 and it is planned to be used as the
basis for determination of sustainability criteria of biofuel and bioliquids. On the other hand Serbia is
already a major exporter of agricultural raw materials for biofuel production elsewhere. Serbian
maize is exported to Spain, Italy, Austria and Romania for ethanol production. It is likely that much of
this feedstock has already achieved certification under relevant voluntary schemes, in order to meet
the sustainability reporting requirements in these Member States (E4Tech, 2014)
Next to Serbia, Ukraine is also a major exporter of agricultural raw materials for biofuel production
elsewhere. In particular, significant quantities of corn, rapeseed and wheat are exported to the EU.
According to the NREAP, 17 feedstock suppliers have achieved certification under EU-approved
voluntary schemes for biofuel sustainability. The State Food Grain Corporation achieved certification
under the Abengoa RBSA scheme. This demonstrates that feedstock producers and suppliers are
already engaged in the EU biofuels market and taking steps towards complying with the required
standards (E4Tech, 2014).
Also in the FYR of Macedonia Makpetrol is exporting biofuel produced to the EU, which implies that
their production complies have achieved sustainability certification.
When looking at the EU Commission and Member States' monitoring of the need for specific
measures for air, soil and water protection, generally the consideration is that all current EU
agricultural practices obligatory under EU Common Agricultural Policy and environmental legislation
apply to biofuel feedstock production (since the bulk of biofuels are produced from agricultural
crops), and as such, separate biofuels-specific measures are not necessary. In this respect, the
environment and climate change chapters of the recent progress reports of the EU Commission that
are prepared regularly to the Council and Parliament on the progress made by the CPs of the
Western Balkans region towards European integration are looked into to give indications in terms of
how far the environment regulations related to air, water and soil are aligned with the EU
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legislations. These reports assess the efforts to comply with the Copenhagen criteria and the
conditionality of the Stabilisation and Association Process are looked into (DG ENLARGMENT, 2015).
According to the 2014 progress reports:
•
•
•
•
In Albania, the National Strategy for Air Quality, the Law on Ambient Air Quality and
implementing legislation on air quality assessment have not yet been adopted. Overlap and
fragmentation of responsibilities between the National Environment Agency and the Institute of
Public Health still persist regarding air quality monitoring. There are no plans at local level to
ensure ambient air quality and no measures have been undertaken to combat known breaches
of the standard values. In the area of water quality, the law on integrated water management
has come into force, however, the water supply and sewerage strategy has not yet been
adopted. Implementation of the acquis in the area of water quality remains at a very early stage.
In Bosnia and Herzegovina, steps were taken towards preparing the Implementation Plan for the
Convention on Environmental Impact Assessment (EIA) and the Protocol on Strategic
Environmental Assessment. Alignment with Strategic Environmental Assessment and Public
Participation Directives still needs to be improved in both Entities. As regards air quality,
Republika Srpska adopted implementing legislation on monitoring, zones and agglomerations,
and air quality values. Implementation of the relevant acquis is at an early stage. Air quality
planning and monitoring systems need upgrading. A countrywide air monitoring network has not
yet been established. Regarding water quality, the country still lacks a consistent and
harmonised approach to water management at State level. This includes implementing water
laws, monitoring and river basin management plans. The water policy at State level remains to
be adopted, while alignment with and implementation of the acquis significantly slowed down.
Some steps were taken in drawing up river-basin management plans for the rivers NeretvaTrebisnjica and Sava. The country’s capacities to implement water-related EU Directives remain
insufficient.
The Law on the Inspectorate of Environment, Waters, Nature, Spatial Planning and Construction
was adopted in October 2013, in Kosovo*. The implementation of legislation to address
increasing environmental challenges in Kosovo* remains incomplete. The Air Quality Monitoring
System, which now covers the whole of Kosovo*, is fully equipped and includes an advanced
analytical laboratory. However, the monthly air quality reports that the Kosovo* Environmental
Protection Agency (KEPA) publishes since March 2014 provide very basic information on only 10
locations. There is no air polluter’s inventory and pollution from the main sources needs to be
measured accurately (in particular from the Kosovo* A power plant). Lack of maintenance and
calibration jeopardises the accuracy of air quality monitoring. In the area of water, Kosovo* has
not established River Basin Authorities or an independent water management authority (as
envisaged in last year’s law). Investment needs in water security are considerable (leaking pipe
losses are estimated at around 75 % of the water carried). Water utilities are hampered by low
collection levels. The water resource monitoring system is incomplete. Kosovo* does not have a
groundwater monitoring system. Most of the surface water measuring stations (some provided
through past EU assistance) no longer in operation due to stolen and vandalised equipment.
Monitoring of the quality of drinking water has improved because of increased capacity (also
funded by the EU) at the Institute of Public Health and an administrative instruction to monitor
the chemical parameters of drinking water. However, the institute faces difficulties due to
insufficient funding to operate and maintain the donated equipment.
Only limited progress has been made in FYR of Macedonia in implementing the national plan for
the protection of air quality. Air pollution levels (PM10) significantly above EU limits were
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•
•
recorded during a sustained period last winter, in 2013. Alignment with the acquis continued
with the adoption of the Law on the Control of Volatile Organic Compound (VOC) Emissions and
of implementing legislation related to air quality assessment and emissions ceilings for
pollutants. The CP became a full Party to the Gothenburg Protocol. Alignment with the acquis is
less advanced in the area of water quality. Management structures for river basins have been set
up, but are still not operational. The poor coordination between the competent authorities
continues to hamper implementation of the legislation. The country needs to address the gaps in
the water monitoring system.
As regards the environment in Montenegro, the government adopted amendments to the
decree on projects that are subject to environmental impact assessment (EIA) to fully align with
the relevant directive. Further efforts are needed to implement EIA and Strategic Environmental
Assessments (SEA) Directives, both at national and local level. The government adopted the first
report on the implementation of the national strategy for air quality management for 2013. In
line with the national strategy, plans for air quality management have been produced for the
two most affected municipalities, Niksic and Pljevlja. The Environmental Protection Agency has
developed an online platform for air quality monitoring and reporting in real time. Water quality
remains an issue of concern. Significant efforts are needed to align water quality legislation with
the acquis and to implement it. Monitoring networks and river-basin water management plans
are in their infancy.
In Serbia, improvements in environmental reporting have continued, however, additional efforts
are required to improve reporting from the agricultural and mining operators. The annual
update of air quality showed that seven of Serbia’s eight urban agglomerations fall into air
quality category III, exceeding the margin of tolerance of several pollutants. Air quality plans for
Belgrade remain to be adopted and planning for the remaining urban agglomerations needs to
be accelerated. Serbia has started work on a National Emission Reduction Plan (NERP) for its
power sector, in order to achieve nationwide emission reduction. As regards water quality, the
decree on limit values for priority and priority hazardous surface water pollutants was amended
in February 2014. The amended decree increases the number of priority substances to be
monitored in line with the requirements of the Water Framework Directive.
4.3.3 Measures taken by the EU to protect soil, water and air from the negative impacts of
from biofuel production
According to the EU renewable energy progress report (Hamelinck et al., 2012) only Belgium,
Romania and Germany have taken concrete steps to analyse the impacts of biofuel consumption on
soil, water and air. In Romania, based on the environmental legislation and Decision of the Minister
of the Environment and Water, a report on the environmental impacts of the National Renewable
Energy Action Plan was drawn up and made available for comments to the public. It commissioned
to examine the possible impacts of the implementation of these renewable energy technologies,
including production of biofuels for transport sector, on the components of the environment. The
Belgian royal Institute of Natural Sciences has been conducting a study on the impact of very short
rotation coppice crops and of biofuels on biodiversity. In Germany quite a number of research
projects have been conducted or started to gauge the impacts of biofuel and bioliquid production on
biodiversity, water resources and water and soil quality.
Several other EU MS assume impacts should be minimal based on existing legislation and codes of
practice, such as:
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•
In Austria, through compliance with the Alpine Convention (protection of animal and plant
species) and the Ministerial Conference on the Protection of Forests in Europe (MCPFE) as
well as Cross-Compliance, ÖPUL, GLÖZ and compliance with RED criteria;
•
In the UK, the ACCS (now Red Tractor Farm Assurance) requires compliance with the UK
Government code of practice: Protecting our Water, Soil and Air: A Code of Good
Agricultural Practice for farmers, growers and land managers. It also requires compliance
with the UK’s Environmental Impact Assessment Regulations;
•
In the Czech Republic, no impact is expected since biomass is covered by the same rules as
other crops – compliance with the principles of good agricultural and environmental
condition (GAEC);
•
In Italy it is assumed that compliance with CAP obligations oblige producers to apply a crop
rotation system such that the same crop cannot be rotated on the same land, thus favouring
agricultural biodiversity;
The Commission and Member States' monitoring of the need for specific measures for air, soil and
water protection generally find that all current EU agricultural practices obligatory under EU
Common Agricultural Policy and environmental legislation apply to biofuel feedstock production
(since the bulk of biofuels are produced from agricultural crops) and as such, separate biofuelsspecific measures are not necessary. In fact, the current sustainability regimes and voluntary
schemes often include requirements of good agricultural practice and so best agricultural practice
for air, soil and water protection is encouraged by the schemes. However, as pressure on agricultural
resources increases, it will be important to ensure protection measures in place continue to be
adequate.
4.4 Impacts of biofuel consumption
This section focuses on the future likely impacts of biofuel demand in each CP as the current
production and consumption rates are either zero or very small. The section consist of assessment of
land use impacts, literature survey on environmental impacts, including GHG emissions and impacts
to soil, water and air.
4.4.1 Assessment of land use impacts
Reported impacts
The CP progress reports provide no evidence about the impact of biofuel production on the national
land use patterns as there have been very little or no biofuel production in the CPs.
Possible future land use impacts based on the 2020 biofuels demand
According to the existing draft NREAPs (Albania, Bosnia and Herzegovina and FYR of Macedonia are
excluded) the biofuel demand in the 5 CPs for 2020 are approximately 727 ktoe. When compared
with the EU27 it is only 7.5% of the EU’s 2010 biofuel consumption. As such, any possible future land
use impacts of the CPs biofuel demand will be well below the EU’s current/recent land use impacts.
Nevertheless, it is important to highlight that any increase in demand, regardless where it comes
from, will increase the direct and indirect land use effects of biofuel consumption.
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In this study, we applied a back-casting calculation to define the possible land requirements of the
2020 biofuel targets set by the CPs based on a number of assumptions (related to combinations of
feedstock types, the feedstock yield data and conversion efficiencies). The detailed methodology
and the assumptions are introduced in Annex III. The results are rough estimations of land use
requirements if the CPs are to produce biofuels domestically and illustrated in Figure 56. The likely
global net use impacts are not assessed as they will depend on a number of factors, such as the
share of imported biofuels or the biofuel feedstock, the origin of imports, the production
intensification on existing agricultural lands, amount of additional use of cultivated land that can be
attributed to biofuels, the demand form other regions of the world etc., that are highly uncertain at
the moment.
Currently, biofuel production is either negligible or null in the CPs and many of the Parties plan to
import rather than produce biofuels domestically. For instance, Moldova and Montenegro plan to
import 100% of the demand and Serbia has plans to import more than 50% of the 2020 biofuel
demand. Montenegro set no bioethanol target for 2020, and the oily crop yields are not available at
FAO as either there was no production or the yields were very low, therefore, they are not included
in Figure 56.
The results indicate land use requirements of on average 440 thousand ha 13, Serbia having the
highest land demand for oily crops and Ukraine for the sugar crops. This total amount corresponds
to approximately 1% of total arable and fallow land of the CPs. For comparison, the worldwide total
land use to produce the feedstock for EU-consumed biofuels in 2010 was estimated to be about 5.7
Mha. Of this, 3.2 Mha (57%) is within the EU and 2.4 Mha (43%) resides outside the EU (Hamelinck et
al., 2012).
13
These figures have not included the positive land effects of co-products
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Figure 56: Average Land required to produce the 2020 biofuel demand (Ha)
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Land use change (LUC) accounts for about 15 % of total anthropogenic CO2 emissions
globally. Biofuel production can lead to both gains and losses in biospheric carbon
stocks. This can be through changed land management practices, converting land to
produce biofuel feedstocks or by displacing activities to other areas and causing land
use change somewhere else (iLUC) due to macroeconomic mechanisms and/or regional
economic development induced by biofuel initiatives. Studies show that conversion of
natural ecosystems or pastures containing significant carbon stocks into conventional
crop cultivations for biofuels (i.e. maize, sugar beet or rapeseed) can cause large upfront C emissions that drastically reduce the mitigation benefit of the biofuels initiative.
Productivity increases in response to increasing demand reduces the LUC effect. The
relative contributions of yield growth and cropland expansion to increasing crop output
depends on the relative economics of these two principal supply side options, which
varies between crops and regions. However, large and rapid increase in inelastic biofuel
demand increases the relative contribution of cropland expansion, since this is the major
near term response to food price spikes. Scientists are challenged by quantifying iLUC
and linking it to specific biofuel projects. The uncertainties make consideration of iLUC
effects a controversial matter when policy instruments are developed. On the other
hand, policy makers have to respond to the concerns that iLUC can drastically reduce
the climate benefit of ambitious bioenergy initiatives. Current policies driving the biofuel
demand may lose public acceptance unless iLUC effects are considered in a satisfactory
way (Berndes et al., 2010).
4.4.2 Environmental impacts
This section focuses on items such as GHG emissions reductions, biofuel impacts on biodiversity,
water, air and soil. Since the current biofuel production and consumption rates in each CP are either
very small or null this section provides a literature survey on environmental impacts of biofuel
production in general.
GHG emission reductions
Greenhouse gas emission savings resulting from the domestic consumption of biofuels reported by
the CPs are presented in Table 25.
Table 25: Estimated GHG emission reductions of RES in transport sector (in ton CO2-equivalents)(based on the Progress
Reports)
CP
2012
2013
methodology
Albania
Bosnia & Herzegovina
FYR of Macedonia
Kosovo*
Moldova
232523
357
0
-
280631
1424
0
-
the RED methodology
Montenegro
10429
19624
Avoided CO2 emission from transport is determined by the
difference of emissions from diesel fuel and biodiesel.
Serbia
Ukraine
“-“ no info available
-
-
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The greenhouse gas (GHG) emissions of the biofuels consumed in the CPs in 2012 and 2013 are very
low and therefore any estimation on the GHG savings are considered unnecessary.
4.4.3 Impacts on biodiversity
The current production and consumption of biofuels in each CP is either null or very small. In this
respect, we can conclude that the current deployment impacts on biodiversity are negligible. It is,
however, important to highlight that the sustainability criteria focusing on the biodiversity aspects of
the 2009 RED (Article 17.3 and 17.4) shall be adopted to avoid any possible negative impacts of
increased biofuel production and consumption to biodiversity in the future. The relevant
sustainability criteria in the RED directive are as follows:
• Biofuels and bioliquids for transport sector shall not be made from raw materials obtained from
land with high biodiversity value, namely land that had one of the following status in or after
January 2009, whether or not the land continues to have the status (Article 17.3):
(a) primary forest and other wooded land, namely forest and other wooded land of native
species, where there is no clearly visible indication of human activity and the ecological
processes are not significantly disturbed;
(b) areas designated:
(c) highly
bio
diverse
grassland
Biofuels can be beneficial to biodiversity when appropriate
crops are grown in suitable areas. Furthermore, if they
• Biofuels and bioliquids taken
contribute to climate change mitigation, they have the
into account for the purposes
potential to be indirectly beneficial to biodiversity as a
referred to in points (a), (b)
whole. However, biofuels have already been shown to
and (c) of paragraph 1 shall
negatively impact biodiversity when direct conversion of
not be made from raw
natural ecosystems or indirect land conversion of nonmaterial obtained from land
degraded land occurs. The expansion of biofuel production
with high carbon stock,
in the tropics has resulted in the loss of tropical forest and
namely land that had one of
wetlands, and in temperate regions biofuel production has
the following statuses in
encroached into set-aside lands. Biofuel feedstock
January 2008 and no longer
plantations (particularly oil palm and maize plantations),
has that status(Article 17.4):
have been shown to support far lower levels of biodiversity
(a) wetlands, namely land
than natural ecosystems, and can cause soil erosion and
that is covered with or
the pollution of watercourses. How a feedstock plantation
saturated
by
water
is managed influences the level of biodiversity impacts.
permanently or for a
Well managed plantations can in some instances prove
significant part of the
beneficial to biodiversity especially if these are on
year;
degraded or marginal lands (UNEP-WCMB, 2009)
(b) continuously
forested
areas,
namely
land
spanning more than one
hectare with trees higher than five metres and a canopy cover of more than 30 %, or trees
able to reach those thresholds in situ;
(c) land spanning more than one hectare with trees higher than five metres and a canopy cover
of between 10 % and 30 %, or trees able to reach those thresholds in situ, unless evidence is
provided that the carbon stock of the area before and after conversion is such that, when
the methodology laid down in part C of Annex V is applied, the conditions laid down in
paragraph 2 of this Article would be fulfilled.
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According to the EC 2014 progress reports (DG ENLARGMENT, 2015), chapter on environment and
climate change:
•
•
•
•
•
•
In Albania effective protection for designated protected areas still needs to be guaranteed.
Illegal activities such as hunting, fishing, logging, natural resources extraction and
construction remain frequent in protected areas.
Republika Srpska of Bosnia and Herzegovina adopted a law on nature protection advancing
towards alignment with the Birds and the Habitats Directives. The CP took steps to identify
an initial list of 95 potential NATURA 2000 ecological areas that account for approximately
20% of its territory. Regulations implementing the nature conservation acquis have been
drafted in consultation with the responsible ministries of both Entities and the Brčko District,
but remains to be adopted.
Two laws on national parks were adopted in 2013 in Kosovo*, as well as administrative
instructions and planning documents. The Ministry of Environment and Spatial Planning
began measures to combat illegal construction activities in the ‘Sharri’ national park.
Activities for the establishment of the Natura 2000 network of protected areas have not
started. Institutions in this area remain weak in terms of the numbers and skills of civil
servants and state inspectors for nature protection
In FYR of Macedonia alignment with the EU acquis on nature protection, specifically natural
habitats and wild fauna and flora has been delayed. No progress has been made on the
identification of future Natura 2000 sites and management plans for protected areas have
been developed and need to be implemented.
In December 2013, in Montenegro, the parliament amended the law on nature protection,
mainly as regards the evaluation of plans, programmes, projects, actions and activities that
may have a significant impact on the maintenance and integrity of the ecological network
and ecologically significant sites, together with compensatory measures. It still misses out
essential articles of the Habitat and Birds Directive.
In Serbia, as regards nature protection, legislation implementing the Convention on
International Trade in Endangered Species of Wild Fauna and Flora (CITES) has been updated
to include protected species listings. Important seizures of illegally traded endangered
species were made. The capacity of the CITES unit and that of enforcement agencies needs
to be enhanced to keep up with the challenges of illegal wildlife trade. The institutional
framework for designating and managing future Natura 2000 sites needs to be upgraded and
adequately resourced.
4.4.4 Impacts on water, soil, and air
Water
In principle, environmental impacts of conventional biofuel crop production are no different from
those of other farm crops. Crops require large quantities of water and pursuing biofuel production in
water-scarce areas will put pressure on an already stressed resource, in particular if production
requires irrigation. Table 26 presents the water availability and water quality impacts of the biofuel
supply chain. Among the complete biofuels supply chain, feedstock cultivations accounts for 99% of
water impacts for most of the crops (Fingerman et al. 2010). While resource consumption in
processing step is rather limited it has greater negative impacts due to potential chemical and
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thermal pollution loading to aquatic systems from refinery effluents and fate of waste or coproducts (de Fraiture and Berndes, 2009).
Table 26: Potential Water Impacts within Biofuel Supply Chains (Hamelinck et al., 2012)
Supply chain steps
Water availability impacts
Water quality impacts
Land preparation and post-harvest
-Land flattering, compaction and
vegetation clearance alters natural
waterways and reduces groundwater
infiltration.
-Clearing vegetation and deforestation
lead to increased runoff and soil
erosion/water sedimentation
-Peatland or wetland drainage lead to
increased flooding due to destruction
of natural drainage.
Cultivation
-Irrigation and water withdrawal;
feedstock cultivation accounts for the
vast majority of biofuel water
consumption. May lead to water
scarcity downstream, exposure of dry
riverbeds, etc.
-Burning residues or vegetation lead to
increased runoff.
-Soil erosion due to land exposure to
wind post-harvest for row crops
caused sedimentation.
-Nutrients runoff to surface water and
infiltrate in groundwater from
applications of fertilisers.
-Leaching of toxins from pesticides and
herbicides into surface water and
infiltrate groundwater.
-Soil erosion due to exposures to wind
for row crops causes sedimentation
Harvest
-Burning (e.g. for sugarcane ) leads to
increased demand for water
-Contamination from accidental
spillage of intermediate production
products, by-products and fuels
Transportation
Processing and refining
-Preharvest burning (e.g. for
sugarcane) leads to increased runoff
containing sediments and nutrients.
-Extraction of water cooling, cleaning,
boilers and processing the feedstock
and production of the fuel
-Processing/industrial effluents
contaminated water
When compared with the biofuels based on lignocellulosic crops biodiesel and bioethanol derived
from conventional food crops typically require more water. For instance, soybean biodiesel has the
highest water requirement, in average 259 m3/GJ (see Table 27), followed by corn-to-ethanol and
wheat-to-ethanol pathways. A rapeseed-to-biodiesel pathway is less energy intensive and lies
between corn- and wheat-grain-based ethanol pathways and consumes an average of 138 m3 of
water per GJ of energy produced. The wide ranges presented in Table 27 are due to (de Fraiture and
Berndes, 2009):
• the water productivity of the crop depending on crop type, variety, soil, climate, day length
and agronomic practices
• the variation in share of aboveground biomass usable as feedstock
• differences in conversion efficiencies of technology and options for coproduction of
electricity/ fuels which increase the bio-energy output per unit water input.
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Table 27: Water requirements of different types of biofuel feedstock per unit of energy produced (de Fraiture and
Berndes, 2009)
Feedstock
Rapeseed
Oil palm
Soybean
Sugarcane
Sugarbeet
Corn
Wheat
Sweet sorghum
Linocellulosic crops
Lignocellulosic crops
Lignocellulosic crops
Fuel
Biodiesel
Biodiesel
Biodiesel
Ethanol
Ethanol
Ethanol
Ethanol
Ethanol
Ethanol
Methanol
Hydrogen
3
ET (m3/GJ) (Berndes 2002 14)
ET(m /GJ) (WWF 2006 15)
Low
100
Low
High
46
143
18
48
100
143
56
250
500
35
76
323
500
233
High
175
37
71
73
40
155
188
346
351
11
10
10
171
137
124
ET: evapotranspiration
14
Estimates by Berndes 2002 include liquid fuel, heat and power; lower range numbers include systems tat deliver both biofuels for
transport and heat/electricity.
15
The WWF estimates the energy content per crop without specifying the energy carrier.
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The future water demand of biofuels and the likely impacts will depend on the location where the
energy crop will be grown; the scope of increase in water productivity of main feedstock crops and
the water stress level of the region. According to the study conducted by WRI(2013) most of the CPs
water stress level are indicated
as low stress (<10%). Albania
Taken as a whole, the Western Balkans have relatively
and Moldova are classified as
low to medium stress (10-20%),
abundant freshwater resources but in many parts of the
whereas FYR of Macedonia and
region, water is scarce, particularly in summer months. In
Ukraine highlighted as medium
Albania, for example, although human consumption uses
to high stress (20-40%). The
less than 10 % of total freshwater resources, in the
water stress level indicates the
summer many rivers carry less than 10 % of their
average exposure of water
wintertime flow (irrigation uses are particularly significant
users in each CP to baseline
in the summer: about 49 % of Albania's cropped land is
water stress, the ratio of total
irrigated). In addition, water is scarce in the summer in
withdrawals to total renewable
some coastal areas and on islands. CPs in the region have
supply in a given area. A higher
also been affected by droughts. Albania, for example, sees
percentage means more water
large variations between normal and drought years.
users are competing for limited
Much of the region's water resources are shared: over 70
water supplies.
% of Bosnia and Herzegovina's territory lie in the Danube
River basin. In Serbia, over 90 % of water resources flow
While the biofuel demand of
from neighbouring countries. The FYR of Macedonia's
each CP up to 2020 are much
main river basins flow through Albania into the Adriatic
less when compared with the
current EU biofuel consumption
Sea and through Greece into the Aegean Sea (SIDA, 2012)
levels it is important to monitor
the impacts of increasing
biofuel demand and water,
particularly for the regions where the water stress level is high. If the biofuel is imported it is equally
important to take the implications of increased water consumption in those regions. As a reference,
according to the renewable energy progress report of the EU 27 (Hamelinck et al., 2012), water use
associated with the EU biofuel consumption in 2010 was low when compared with the total water
use for agricultural production globally (less than 0.01% of total agricultural water use). Water stress
as result of feedstock production for EU biofuels consumption mainly occurs in the EU, especially in
Belgium, where a significant fraction of the total agriculture water footprint seems to be related to
biofuels. Further large contributions are seen in Germany, France and Hungary. Outside the EU, the
largest impacts are seen in Argentina and Paraguay (Hamelinck et al., 2012). Areas of particular
concern include Southern Brazil (sugarcane), the Mid-Western United States (soybeans and maize),
Malaysian Borneo (palm oil), and Indonesian Borneo and Sumatra (palm oil).
Overall, it is useful to have regulatory frameworks to ensure sustainable water use in biofuel
production, but if the institutions to enforce these regulations are weak, additional incentives will be
needed. For example, markets for commodities raised under best managements practices may
provide a premium price that rewards voluntary adoption of improved management practices for
which compliance is validated by a third party (de Fraiture and Berndes, 2009).
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Impacts on Soil
There is a concern that increased demand for biofuel feedstock may increase the pressure on
agriculture and encourage expansion of cropping area, shift from diversity to monoculture, increase
use of inputs that in return result in negative impact on soil. Management practices that include high
yielding crop varieties combined with tillage, use of heavy machinery, excessive use of inputs like
fertilizers, herbicides, pesticides, and irrigation may result in soil erosion, loss of organic matter, loss
of biodiversity, soil contamination, groundwater pollution, salinity and acidity (Hamelinck et al.,
2012). Thus, soil degradation may result from mismanagement of any or all of these practices. The
nature and extent of these impacts are dependent on factors such as scale of production, type of
feedstock, cultivation and land-management practices, location and downstream processing routes.
Evidence remains limited on the impacts specifically associated with intensified biofuel production
(FAO, 2009). According to the study conducted for the EC (Hamelinck et al., 2012) there are
indications that increase in the area under biofuel crops most likely occurred at the cost of other
crops. Next to that, the FAO statics indicate a trend toward expansion and/or intensification of
biofuel crops. This trend may be interpreted as indicators of progress towards soil degradation;
however, no definitive conclusions can be drawn.
Agricultural land in the Republic of Moldova represents more than 74 % of the country’s territory (as
for comparison, 50% average in EU and 71% in Ukraine). About one quarter of the total land area
suffers from one or many forms of soil erosion (RIO20 - United Nations Conference on Sustainable
Development, Rio de Janeiro, Brazil, June 2012, Government of Moldova, National Report for UN
CSD 2012 Rio+20). This equals approximately to 850 thousand hectares (NREAP Moldova).
The Ministry of Environment and Spatial Planning of Kosovo* estimates that approximately 5000 ha
of agricultural land are lost annually due to permanent (movement into industry, commercial, etc.)
and temporary losses (waste, degradation and erosion). In terms of erosion, 75 percent of farmland
is in class 3 – class 5 levels of erosion (the severity of erosion increases with class number) (MESP,
2010). Depending on how biofuels are produced in Kosovo*, it may exacerbate or improve the issue
of soil erosion on agricultural land (NREAP, Kosovo*).
Proper crop rotation (e.g., cereals with legumes), cover crops, minimum tillage, and residue
management along with proper amount of fertilizers can help maintain soil condition and
productivity (FAO, 2000; Sullivan, 2001). On the other hand, poor management may degrade even
the best of lands.
4.4.5 Socio-economic impacts
This section focuses on the possible socio-economic impacts of increased biofuel consumption on
food prices, on land rights and issues, on employment and impacts on other uses of biomass related
resources.
Food prices and affordability
Biofuels policies have been accused of increasing food prices. A number of studies have focused on
this aspect and analysed the possible linkages between food prices and the increasing demand for
biofuels. The factors influencing global food prices, especially regarding the recent peak in 2010 in
food prices on the global market, are defined as (LEI, 2011; FAO & OECD, 2011; FAO, 2011; Headey &
Fan, 2010; Brahmbhatt & Christiaense, 2009; FAO, 2008; Nelleman et al., 2009; Hamelinck, et al.,
2012):
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•
Tight market: growing and richer population (with changing food patters); biofuel demand
adds to this tight market.
• Weather induced elements: drought, flooding, etc., influence harvests and thus availability
of crops.
• Low stocks: historic results from harvest, export and market trends resulting in lower stocks
per country.
• Export bans/restrictions: regulation imposed by certain countries that distort international
market.
• Weak US exchange rate: international commodity markets use the US exchange rate as
main currency.
• High oil price: directly and indirectly impacts the food prices. Increased fuel prices in
agricultural production directly impacts the food prices and their use as fertilizers and
increase fertiliser prices indirectly impacts food prices.
Speculations and increased influence from international financial markets are often indicated as a
factor strongly influencing international commodity and food prices.
While the exact impact of biofuel policies on food prices is not clear several studies acknowledge
that biofuel policies and targets put further pressure on the demand for the oily crops and grains.
The demand for biofuels in the form of quotas or targets does not respond to changing markets
prices but does influence the market prices (FAO et al, 2011). As such, it sets a volume that impacts
the price differently than the other markets, which makes the markets less predictable and
transparent (Hamelinck et al., 2012).
The EU Renewable energy progress report (Hamelinck et al., 2012) has analysed the likely impacts of
demand growth for biofuel feedstock in recent years on prices and conventional demand for food
and feed uses of crops using a world food system model. The results indicate that the variations
from the decadal trend in 2006/07 to 2010/11 for both factors, biofuel production expansion and
crop production, have contributed to widening the demand-supply gap in 2008 and 2010 and can
explain a significant part of the observed historical price increases. The analysis suggests that the
combination of the two factors caused a combined impact that was larger than the sum of the two
individual impacts, i.e. there was a non-linear and mutually reinforcing interaction of the two stress
factors. EU-27 expanding biofuel use has contributed only little to the historical cereal price increases
in 2007 to 2010: by simulation of EU-27 historical biofuel use (with biofuels in rest of the world fixed
to the 2000 situation), the wheat and coarse grain prices increase by about 1-2%, compared to a
scenario without biofuel expansion in the EU-27 during 2000-2010.The impact of EU-27 historical
biofuel use was more substantial for price increases of non-cereal food commodities, notably through
its demand for vegetable oil in the production of biodiesel: the price of other crops, including oil
crops, increases by about 4% percent, compared to a scenario without biofuel expansion in the EU-27
during 2000-2010.
However, other studies present other indications. For instance LEI (2011) presents an overview of
various studies indicating their found connection between biofuel policies and food prices. Some of
the more quantified statements are (Hamelinck et al., 2012):
• Rosegrant et al. (2008) argues that biofuels have been a major contributor to rapid price
increases on the international grain markets in the 2000’s; if biofuel production were to
remain at its 2007 levels, maize prices would be 14% lower in 2015 and 6% lower in 2020;
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•
•
FAO and OECD (LEI 2011) concluded that vegetable oil prices would be 15-16% lower and
wheat and coarse prices 5-7% lower in 2018 compared to a baseline scenario in which
biofuel support policies would continue;
Studies that found little direct evidence that the demand for biofuel feedstock caused the
price increases are among other Gilbert (2010) and Baffes and Haniotis (2010). They both do
not quantify the effect on prices.
Land use rights
Institutions such as the World Bank and the International Fund for Agricultural Development (IFAD)
have argued that large scale land deals can have win-win opportunities for investors as well as the
local population. This only under the condition that local government ensures a proper regulation,
such that selling the land could increase land productivity, foreign investment, skills acquisition,
improved infrastructure and overall economic development for the poor (World Bank, 2010). They
key problem, they point out, is that national policies to regulate such deals are not comprehensive
or do not exist at all.
There have been concerns related to the likely negative impacts of increased demand for biofuels in
land use rights. Anseeuw et al. (2012) have conducted a comprehensive global study about this issue
for the International Land Coalition (ILC) and concluded that worldwide about 71 million ha of crossreferenced land deals were closed in the period 2000 to 2010. 73% of the cross-referenced 16 deals
were for agriculture production and there-quarters of this were for biofuels. They concluded that
over 50% of global land deals were for biofuels. This study further stresses the risks for negative
impacts from land deals, especially in developing countries, resulting in los of excess to land, water
and other natural resources by local communities, and leading to poverty and hunger.
In their assessment Hamelinck et al. (2012) criticises the Land Matrix database that has been the
main basis of the ILC study as containing several serious flaws that should be corrected. According to
Hamelinck et al. (2012) many ‘deal’ references given in the Land Matrix database do not correspond
to specific deals. Many of the areas quoted are mere stated objectives or potentials, or large multistakeholder government programmes. Many sources are reports or articles that cover large, multideal projects, countries or regions, thus very likely leading to overlap between sources and deals
mentioned in the Land Matrix database. Furthermore, Cotula and Polack (2012) stress that the data
must be treated with caution. The Land Matrix is based on reports from the media and NGOs which
often overestimate scale. Ecosys (2012) concludes that between 9% and 30% of the deals in the
database, on acreage basis, could be related to biofuels. This implies that the biofuels (worldwide)
could be linked to between 0.5 and 1.6 Mha of land deals with significant to serious concerns. They
conclude that between 0.05 and 0.16 Mha of land deals with concerns about socioeconomic impacts
and land-use rights could be linked to the EU market.
Although land grabbing most associated with developing countries on the Southern Hemisphere, it is
a serious concern in Europe as well. In the EU 3% of the 12 million farms own 50% of the farmed
16
The Land Matrix is a database of large-scale land-based investments, that include transactions that entail a transfer of rights to use,
control, or own land through sale, lease, or concession. The database contains two sets of data: reported (from published research
reports and media reports and government registers) and cross referenced (data that is referenced from multiple sources and
triangulated for reliability with other information sources and in-country partners in some cases). The database and its details can be
accessed at http://landportal.info/landmatrixhttp://landportal.info/landmatrix.
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land (Franco and Borras, 2013). One of the drivers of this land concentration is said to be the
Common Agricultural Policy (CAP), which “explicitly favours large land holdings, marginalises small
farms, and blocks entry by prospective farmers” (ARC2020, 2015).
Explicit case studies on land grabbing in Serbia and Ukraine are presented in Franco and Borras
(2013). In the first privatisation of formerly socially owned land lead to large amounts of land being
in the hands of a few landowners and although foreign land ownership is not allowed, it seems
foreign investors have found a way around this using domestic companies. Also in Ukraine
privatisation allowed few foreign and national agri-businesses to obtain control over domestic
agriculture. It is not unlikely that this situation is similar in the other Energy Community Contracting
Parties.
Employment and impacts on local economy
The labour intensity of renewable energy technologies is higher than that of energy from fossil fuel
sources (IRENA, 2011). However, it is hard to find reliable quantitative data regarding the
employment effect of biofuels. Little data is available and the high variety in methodologies of
studies makes it hard to compare results. Furthermore, the effect is highly dependent on factors
such as what type of jobs are created (temporary vs. long-term, seasonal vs. continuous) and
whether these are of high or low wage and skill. This makes it very difficult to make conclusive
statements about the employment effect of biofuels in the Energy Community.
In the EU the overall effect of the biofuels policy under different scenarios is “modest in all cases”
with an increase in jobs of around 300,000 against a base of 200 million jobs in the EU in total
(Neuwahl et al., 2008). Furthermore, according to the same study though some sectors may see a
growth in employment (e.g. food and industrial sectors), others will feel losses (e.g. refinery and
service sectors). However, on the other hand it could be argued that this is a high growth within the
biofuel production industry, which is estimated to include around 220,000 jobs in 2010 in the EU
(Urbanchuk, 2012). EurobservER estimated that for the EU27 countries 150,000 jobs were covering
the agricultural supply chain (EurobservER 2011, p 157).
The advantage of biofuels over technologies such as wind energy or solar PV is that it is more labour
intensive where the feedstock is grown and refined into a biofuel (IRENA, 2011). Furthermore, in a
study conducted in the APEC (Asia Pacific Economic Cooperation) countries concluded that
“[b]iofuels not only create jobs in rural areas through new biorefineries and new feedstock
harvesting, seeding, and transportation activities, but biofuels also provide a logical growth path into
increased mechanization and higher productivity” (Macedo, 2005).
When looking at biomass energy in a broader sense Domac et al. (2005) have looked into different
studies regarding the socio-economic consequences of bioenergy and concludes that many
ambiguity exists regarding the definitions of the determining descriptions (e.g. full-time vs. part-time
employment, direct vs. indirect employment), making it hard to compare results even if similar
methodologies have been used. The authors also concludes that although many studies highlight
positive employment effects of bioenergy, this is not the case for all time periods and certain
conditions need to be met to make this true.
They also note that a higher employment is not necessarily a good thing, as it can be of low
wage/capacity/training. Domac et al. (2005) explain that while those working with lignocellulosic
biomass can earn an average income in developed countries, in developing countries those jobs will
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probably earn a wage well below average. It can be discussed whether many low wage job are of the
same value as fewer jobs but raising the economic level of employees.
The employment effect of biofuels also depends on whether the biofuels produced are of first or
second generation. Analyses in the REFUEL project (2008) have shown that for first generation
biofuels although creating more employment in rural areas, this is mainly low qualified employment
in the agricultural sector. Second generation biofuels on the other hand require higher skilled
employment in the industrial sector. A policy focusing more on second generation biofuels will thus
likely result in the creation of more highly educated employment in industry, and less lowly
educated employment in agriculture. However, this analysis also shows that the impacts on the
sectors are relatively minor when compared to the total employment in the two sectors.
Another effect of the production of second generation biofuels such as cellulosic ethanol is that it
will give added value to agricultural residues, resulting in a diversification of farmers’ income and in
the EU could lead to additional revenues of 15 billion euros annually (ePure, 2014). Production of
crops for second generation biofuels is also possible on degraded or marginal land that currently lies
fallow (ePure, 2014), thus creating extra value there. Another economic effect is seen in countries
that do not (only) produce biofuels for their own consumption but also for export. In a study
performed by Hamelinck et al. (2012) the effect of biofuel production in non-EU countries, such as
the US, Brazil, Argentina, and Indonesia can be seen in the overall wealth of the countries, as “in the
exporting countries to the EU, GDP is increasing”.
Impacts to other biomass using sectors (possible competition)
Increasing demand of biofuels may affect other sectors that also use biomass as raw material for
their production of goods, such as the pulp and paper industry, the chemical industry, the oleochemical industry and food processing industry. The sector organisations, such as the chemical
industry CEFIC 17 and the pulp and paper industry CEPI 18 have been claiming that the increasing
demand for bioenergy and biofuels, supported by the policies, may have undesired and adverse
impacts on these sectors.
Currently bio-based products in general make up only a small portion of the total markets compared
to their petroleum-based counterparts and therefore any competition or interaction with the biofuel
sector are not that aspirant. When the emerging bio-economy sector grows it is likely that the
competition for the same raw materials will also increase. One concrete example is the effects of the
EU biodiesel production on the oleo-chemical industry. Animal fats (Tallow) are the main renewable
feedstock for the European oleo-chemical industry and oleo-chemical products serve as building
blocks for a diverse range of consumer goods, such as detergents, soaps, lubricants, paints,
cosmetics, candles, tires, plastics and textiles. The Renewable Energy Directive has been encouraging
the use of animal fats for biofuels by allowing them to be counted double to the national biofuel
targets. Increasing demand from the biodiesel industry to animal fats has increased the prices and
negatively influenced the industry as animal fats have been covering more than 50% of the raw
material requirements in the EU oleo-chemical industry (Ecofys, 2011). Next to that, increased
17
http://www.cefic.org/documents/PolicyCentre/Energy-Roadmap-The%20Report-European-chemistry-for-growth.pdf
18
http://www.icfpa.org/uploads/_Documents/keymessages0510.pdf
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biodiesel production resulted in increased glycerine as by-product. Increasing quantities of glycerol
caused a strong decrease in glycerine prices and negatively affected the oleo-chemical industry.
The demand for biomass from the second generation biofuel technologies is negligible at present.
However, when technologies become commercially available and penetrate the market the demand
volume and the paying capacity from that sector can be significant. A high „ability to pay‟ is related
to the economies of scale of second generation biofuel plants – where the feedstock cost share is
relatively smaller than for first generation biofuel plants – and the policy measures supporting them.
The raw material availability at a competitive price is a critical factor for the forest-based industries
market competitiveness as woody raw material comprises a substantial part of the total variable
production costs – more than 30 % of total costs in paper making and reaching up to 65 to 70 % in
the sawmill industry (EC, 2008). While the developments in wood based energy production may
have positive effects on sawmill industry as they can get a higher price for secondary products (slabs,
chips and sawdust), the wood based panel industries are likely to be negatively affected due to the
increasing competition for slabs, chips and sawdust from the sawmills as well as for roundwood.
Exacerbating challenges for this industry is the fact that they have little or no secondary products to
be fed into the burgeoning energy markets (Uslu et al., 2010) 19.
On the other hand, biofuels can be produced along with wood-based chemicals and other products
in bio refineries that optimize biomass use and outputs according to market trends.
19
http://www.elobio.eu/fileadmin/elobio/user/docs/Policy_paper_5_fin.pdf
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5 RES perspectives in the Contracting Parties beyond 2020
This chapter briefly reflects on RES perspectives and presents key considerations for the CPs for the
period beyond 2020. Reflections and recommendations are largely influenced by current and
expected developments taking place in both the CPs as well EU. Although at present the Energy
Community treaty acquis is extended to 2026, we can assume with high certainty that there will be a
further extension to 2030 and beyond, and continue to be the most important framework for the
expansion of RES for CPs. Therefore the reflections in this chapter concerning implications the 2030
RES target below also will apply to the CPs. Some of the CPs however maybe members of the EU
after 2020 and will have to comply with the EU’s 2030 framework and all other relevant legislation
related to RES and climate policy. An early alignment of support schemes with EU requirements and
other policies leading to decarbonisation therefore is strongly advisable.
As a starting point, it is important to mention that the proposed EU 2030 RES framework will be
different from the EU 2020 RES framework. Instead of national binding RES targets the 2030
framework will include an overall EU RES target and the introduction of a governance structure to
ensure that the 27% RES target will be met. More clarity on how this governance structure and how
it will function in practice remains. On the one hand, this new approach will require more
cooperation across EU Member States and with the Energy Community countries as well as with
southern Mediterranean countries to ensure that a 2030 RES target is met, what is also stated in the
Council Conclusions. On the other hand, it will create more uncertainty with what is to be achieved
by Member States and CPs.
There are however a number of aspects related to RES deployment that we are more certain about.
For example, large amounts of additional RES will be needed to reach the overall target for the EU,
also in the CPs. Variable RES-E will have more and more impact on the electricity market. RES costs
are expected to decline further, and for certain RES technologies ‘grid parity’ will be reached. This
will have implications for the design of support schemes as well as for the phasing out of support
schemes. Investors are very sensitive to risks, and stable, predictable and long term framework for
promoting RES is a key pre-requisite for further RES deployment.
Some general and sector specific considerations are presented below.
General:
•
•
At present, FIT (which are stable and predictable in order to create investor confidence) can
be considered a key support instrument for RES deployment, in particular RES-E
deployment. However, the EU considers Feed-in premium (FIP) combined with tendering
schemes to be more appropriate market-based schemes to use for promoting RES, especially
in the context of the internal (electricity) market. Since CPs generally at this stage have not
established electricity markets, the introduction of more market based support schemes,
such as the FIP, will have to wait. As an intermediary step towards the in the introduction of
a more market-based (efficient) support mechanism for RES deployment, CPs could consider
public procurement and tendering.
CPs should anticipate when the electricity reform will be complete and plan for the
implementation of more market-based support schemes, such as FIP. When introducing new
schemes, CPs can harvest from lessons learned in EU MS rather than paving the way through
indigenous ‘learning-by-doing’ experiences. It is particularly important to avoid ‘stop-and-go’
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in support schemes, as this could create investor uncertainty and also increase the cost of
capital for RES investments.
RES-E
•
•
CPs should anticipate grid integration implications of increasing shares of RES in the post
2020 framework, and look for ways to deal with the issue. Complete transposition of the RES
Directive provisions concerning grid integration is a crucial starting point, however, for the
longer term CPs should be looking at enabling the development of a portfolio of different
RES-E technologies and favouring RES-E generation investments that can help to improve
system stability and/or reduce balancing costs.
In recent years, one has seen a significant decrease in the cost of solar PV. Until now this
technology has been considered expensive and little deployment of solar PV has taken place.
Given the significant cost reductions that have taken place, CPs should anticipate its uptake
and be prepared for this also beyond 2020. In doing so, governments should look at
opportunities for creating industries to provide and service solar PV technologies
indigenously.
RES-H&C
•
•
•
In the RES-H&C there are almost no policies in place but high potentials for RES H&C call for
an update of then current support frameworks.
Most CPs use and plan the use of biomass for heating but often in very inefficient way, e.g.
using inefficient stoves. A more efficient use of biomass could help to easier increase the
biomass heat share. This includes either the implementation of more efficient biomass
stoves or investigating options for biomass district heating that is almost non-existent in CPs
Only few CPS such as Albania and Montenegro are considering the use of solar heating, it
should be investigated by all southern CPs including e.g. FYR of Macedonia or Kosovo*.
RES-T
•
Recently, the European Parliament’s environment committee has approved new biofuel
rules that consider a cap of 7% to the amount of conventional biofuels that can be counted
towards the 10% target for renewable energy in transport, including a non-binding target of
0.5% for advanced biofuels. The European Commission has not proposed new targets for the
transport sector after 2020 in its 2014 Communication “A policy framework for climate and
energy in the period from 2020 to 2030”, however, acknowledged that the future of EU
transport development should be based on alternative, sustainable fuels as an integrated
part of a more holistic approach to the transport sector. As such, the current EC proposal
suggests that the specific targets of the Fuel Quality Directive (FQD) and RED would be
discarded post 2020 and the only expected policy is vehicle CO2 targets beyond 2020 that
sets 95 gCO2 /km for new vehicle sales in 2021 compared to 130 gCO2 /km in 2015
(Regulation (EU) 333/2014). In this respect, electrification is expected to make a growing
contribution. Nevertheless, energy dense liquid fuels are likely to provide a significant share
of road transport energy even beyond 2030. It is advisable that the CPs reflect the EC’s
future transport policy considerations and shape their policies accordingly. While the
conventional biofuels are likely to stay as an important mean to decarbonise the transport
system more advanced biofuels and other alternatives such as electrification will become
more and more important.
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6 Conclusions and recommendations
Key findings and conclusions related to the assessment of national legislative measures
(in relation to NREAPs and Progress Reports)
Concerning the implementation of national legislative measures related to the RES Directive, the
following challenges were observed:
•
•
•
•
•
•
•
•
•
In general, there is clear evidence of efforts to improve RES legislative and regulatory
framework, including amendments of existing (or introducing of new) major primary
legislation, such as RES laws, energy or electricity laws, laws on biofuels etc.
In the last 2-3 years, undoubtedly the most significant progress in adopting legislative
measures to comply with the RES Directive have by most CP been made in the RES-E sector.
A few efforts have been made in some cases in the RES-H&C sector, while the RES-T sector
seems to have been left behind in all CPs. However, adoption and implementation of RESrelated primary and secondary legislation is generally rather slow and often very delayed.
The main compliance gaps with respect to the RES Directive across all CPs are the provisions
on improving the administrative procedures for RES deployment, i.e. simplification of
authorisation and licensing rules and improvement of coordination of different bodies are
issues which are still not properly addressed in most cases.
Compliance with information requirement mostly consist of uploading most of the relevant
legislation and regulation on the internet pages of the respective authorities and most often
only in English language. More effective would be to have regularly updated guidelines for
investors and other stakeholders in English with relevant data concentrated in one piece of
information.
It should also be highlighted that three of the eight CPs have yet to adopt an NREAP, noting
that the NREAP is a key (planning) document both in terms of defining trajectories towards
reaching the national 2020 RES targets as well as defining and describing the measures that
will be implemented to reach the 2020 RES target.
Apart from introducing attractive support measures, legislation is still not very investorfriendly, which is reflected among others in the insufficient regulations on the adoption and
proper formulation of, for example, Power Purchase Agreements. Assistance to applicants
and dissemination of information to interested parties in general is also an issue which
needs to be improved in all CPs. Also, notably, CPs rarely initiate the promotion of RES
without a viable financed programme.
While rules aiming to ensure access of RES-E producers to the networks are in most CPs
developed (or in some cases in the process of being implemented), network development
for the purpose of integration of new RES-E capacities is very important in this respect and
is generally not on a satisfactory level.
Most CPs have, to date, failed to regulate the minimum use of RES in the housing sector and
exemplary role of public sector in the development of RES-H&C which would be the
necessary initial compliance requirement.
There is absolute minimum compliance in the CPs regarding RES-T. Albania, BiH and Ukraine
have passed respective regulations some time ago, although in most cases the provisions
have in practice not been implemented. In several CPs sustainability criteria, blending
obligation and other support schemes are currently included in draft legal acts which have
not been adopted yet.
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Key findings and conclusions related to the quantitative assessment of past RES
progress (2012/2013):
Several challenges have been identified within the assessment of past (2012/2013) RES progress in
CPs:
•
•
•
First, reliable and comprehensive statistical data related to the historic deployment of
renewables and of overall energy consumption was not applicable for all CPs.
Second, reporting on past progress was not delivered by all CPs (i.e. seven out of eight CPs)
and the information provided was partly incomplete or inconsistent when compared to
official statistical data.
In addition corrections and modifications to CPs reporting was indispensable, specifically for
data on biomass used in heating and cooling and for energy demand (i.e. when comparing
NREAP projections with actual data).Thus, for delivering a complete picture for the historic
development of renewable energies in all CPs, the original and modified data is presented in
this report.
The assessment of past RES progress comprises a comparison of actual RES deployment with
required (2011/2012) minimum trajectory targets (according to the RED) and with CPs plans as
outlined in their NREAPs (for 2012 and 2013):
•
•
•
•
We start with assessing compliance with required minimum trajectory targets (according to
the RES Directive). It can be seen that only Montenegro achieved its RED target for
2011/2012 whereas all other CPs fall short in complying. For the case of Montenegro it has
to be taken into account that national energy balances have been corrected retrospectively
for a final consumption of solid biomass in the heating and cooling sector. Therefore its
share of RES in GFEC increased anyways without any additional deployment (see Box 2 for a
detailed description). Of interest, the RED minimum trajectory for 2011/2012 sets a
relatively strict interim target. This can be seen when comparing these with interim targets
defined by CPs in their NREAPs: all interim targets of the NREAPs for 2012 show a lower
percentage target than the RED Minimum Trajectory for 2011/2012.
A comparison of actual and planned RES shares in GFEC (in accordance with CP’s NREAPs)
shows that almost all of the CPs have managed to meet their planned overall RES shares for
the years 2012 and 2013. The CP who missed its targets was Moldova by 2.2 percentage
points in 2012 and 0.4 in 2013. The strongest positive deviations of actual to planned RES
shares in GFEC in 2012 occur for Albania (3.2 percentage points (p.p.)), Montenegro (13.5
p.p.), FYR of Macedonia (4.9 p.p.) and Serbia (2.3 p.p.). In 2013 Montenegro over achieved
its target by 10.8 (see Box 2 for further explanations on the special case of Montenegro) and
FYR of Macedonia by 3.1 percentage points, respectively. If the absolute RES deployment is
considered, six CPs met their absolute NREAP targets in 2012, but only two did so in 2013.
The negative deviations in 2013 range from minus 1.1% for Kosovo* to minus 5% of planned
vs. actual deployment for FYR of Macedonia. In this case positive examples are Ukraine who
surpassed its absolute NREAP RES targets by 37.5% in 2012 and 23.5% in 2013, and
Montenegro who surpassed its absolute target in 2012 by 43.4% and 32.2% in 2013,
respectively.
With respect to the deployment of renewable electricity it can be seen that most CPs are
well on track. When statistics are compared to (draft)
NREAPs Albania surpassed its planned RES-E share by 3.5 in 2012 and 0.8 percentage points
in 2013. Kosovo*, Moldova and Ukraine met their planned RES-E shares in 2012 and 2013 by
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•
•
+-0.6 percentage points. Also Montenegro did so in 2012 but fell short in 2013 with a deficit
of 6.2 percentage points. FYR of Macedonia missed its RES-E target by 4.7 and 2.5
percentage points in 2012 and 2013. Serbia had a surplus of 2.4 and deficit of 1.9 percentage
points in 2012 and 2013.
The status of renewable energies in the heating and cooling sector depends very much on
the statistical records of solid biomass use for every CP. As such, the picture for the absolute
RES-H deployment and NREAP trajectory fulfilment in this report depends significantly on
the (necessary) correction of national biomass data. The assessment of these corrections
dates back to the RES target setting process of the ECS in 2012. If these corrections are
applied Kosovo*, Montenegro, FYR of Macedonia, Serbia and Ukraine managed to meet
their RES-H target shares in 2012 and 2013. Moldova showed a deficit in 2012 but met its
target in 2013. Finally, Albania is the only CP that missed its RES-H target in both years.
Only Albania, Ukraine and to a very small amount the FYR of Macedonia report some biofuel
deployment in the transport sector for the year 2013 in their Progress Reports. The planned
deployment of Montenegro as reported in its NREAP for 2012 and 2013 were not fulfilled at
all and in the case of FYR of Macedonia only to a very small amount. Available energy
balances for 2012 and 2013 could only verify a small production of biofuels in the FYR of
Macedonia and a more respectable volume in Ukraine in 2013.
Key findings and conclusions related to the quantitative assessment of future RES
progress (2020):
Modelling results on the expected future progress by 2020 (i.e. against the binding 2020 RES target)
indicate by CP the likeliness of delivering as required under the RES directive. The basket of assessed
cases includes four distinct scenarios: two policy scenarios (i.e. CPI and CPI+PPI) combined with two
distinct demand developments (i.e. reference and efficiency trend, originally based on CPs NREAPs
but corrected in accordance with actual demand developments).
•
•
Results suggest that only one CP, that is Montenegro, is expected to reach the given 2020
target with currently implemented and planned policy measures. Another CP, namely
Moldova may be added to that list where expected 2020 RES deployment is slightly below
the given target. All other CPs appear to fail in complying with 2020 their binding 2020 RES
target whereby a comparatively small gap is expected for Serbia. Despite the expected
increase in absolute terms, Bosnia Herzegovina and Ukraine would for example fail to
achieve their 2020 RES targets. At the aggregated level (all Contracting Parties in total) a
comparison of the expected and targeted 2020 RES share points out that a gap in size of
about 4 to 6 percentage points would occur if no additional policy revisions (to the ones
implemented or planned) are undertaken.
Next a closer look is taken on the expected progress in meeting planned (i.e. according to
NREAPs) RES deployment by 2020: Only a few CPs have established a higher RES deployment
target than their required one, namely Albania, Moldova and Montenegro. Thus, the
number of countries that are expected to meet their planned trajectory is diminishing
compared to above – i.e. none of the CPs is expected to meet its indicative NREAP target.
This does not change even if optimistic framework conditions like a low demand growth (in
accordance with the energy efficiency demand scenario) are assumed and planned RES
policy initiatives in addition to currently implemented ones are taken into consideration.
Deviations are modest in Moldova, Montenegro and Serbia and highest in Ukraine.
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•
•
•
It is applicable that none of the eight CPs is expected to comply with own deployment plans
for renewable electricity. In all CPs expected deployment lacks behind the planned one. The
gap appears comparatively low in CPs like Moldova, Montenegro or Serbia, whereas high
deviations are apparent for Kosovo*, FYR of Macedonia, Albania and Ukraine. Thus, in those
CPs a strengthening and fine tuning of policy initiatives offering adequate support for all
available RES-E technologies and a rapid removal of non-cost barriers that hinder a rapid
take-off of RES-E appear indispensable for achieving 2020 deployment plans and for meeting
overall binding RES targets.
Compared to other energy sectors, the sector of heating and cooling offers comparatively
promising potentials for renewables due to suitable framework conditions like high solar
infeed in Western Balkans or a high potential of biomass feedstock in almost all CPs. Thus,
renewables for heating and cooling can be classified as “low hanging fruits”. Biomass heat
used in households or industry is here the key renewable source both in terms of planned
and according to modelling expected deployment whereas other promising renewable
options like solar thermal collectors, the use of heat pumps or of geothermal resources are
generally underrepresented in policy making and in market establishments. A combination
of tailored financial incentives and campaigns to increase public awareness may
consequently serve well to increase demand for renewable sources in heating and cooling
which, in turn, would significantly contribute towards overall RES target achievement.
With respect to biofuels in transport it can be concluded that the establishment of a real
market for biofuel is key for almost all of the CPs. Blending obligations, partly combined with
tax exemptions for the use of biofuels, are simple and straightforward policy measures that
allow for that. This would increase overall renewables deployment significantly in all CPs
that have failed to do so in prior, and, consequently, increase overall progress in terms of
achieving binding 2020 RES targets.
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ANNEX I: Summary of findings per Contracting Party
SUMMARY REPORT FOR EACH CONTRACTING PARTY ARE ATTACHED AS SEPARATE REPORTS
TO THIS REPORT:
ALBANIA
BOSNIA AND HERZEGOVINA
KOSOVO*
FYR OF MACEDONIA
MONTENEGRO
MOLDOVA
SERBIA
UKRAINE
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ANNEX II: Biofuel potential assessment
Methodology
Biofuel potentials are analysed depending on land availability, residues, policies, and feedstock and
investment costs.
The modelling details and the assumptions included in this study are as follows:
•
•
•
•
•
•
•
•
The assumption for the estimates of potentials is that 30% of total arable and fallow land
can be used for growing feedstock (FS) for biofuels (BF).
Next we have to split up this area and dedicate it to different areas related to the three
biofuels categories biodiesel (BD), bioethanol (BE), and biogas (BG).
We start with biodiesel analysis as among the different feedstock, oil seeds are most
sensitive with respect to soil quality. Hence, current area used for oil seeds can be extended
only limited. We assume that only 10% additional area for oil seeds can be used. Based on
2012 production total oil seed area is calculated.
From max. oil seed areas we calculate the part for biodiesel as 30%.
This amount is deducted from the total area available for biofuels and the reminder remains
available for bioethanol and biogas. Based on European tradition we assume 10% of this
area can be used for biogas and 90% for bioethanol.
Among the other areas especially the “Permanent meadows and pastures” can also be used
to some extent for biofuels. We assume that part of grass land (10%) is usable for biogas.
The decision from which feedstock biodiesel will be produced is based on the typical oil
seed feedstock used in the country in 2012.
Following the results from other projects we assume that 2nd generation bioethanol will
not be relevant before 2030.
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CP Biofuel potential results
ALBANIA
Figure 57 Biofuel potential (on the left side) and the amount of required feedstock (on the right) to produce biofuels in
Albania up to 2030
BOSNIA and HERZEGOVINA
Figure 58 Biofuel potential (on the left) and the amount of required feedstock (on the right) to produce biofuels in
Bosnia and Herzegovina up to 2030
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FYR of MACEDONIA
Figure 59 Biofuel potential (on the left) and the amount of required feedstock (on the right) to produce biofuels in FYR of
Macedonia up to 2030
KOSOVO*
Figure 60 Biofuel potential (on the left) and the amount of required feedstock (on the right) to produce biofuels in
Kosovo* up to 2030
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MOLDOVA
Figure 61 Biofuel potential (on the left) and the amount of required feedstock (on the right) to produce biofuels in
Moldova up to 2030
MONTENEGRO
Figure 62 Biofuel potential (on the left) and the amount of required feedstock (on the right) to produce biofuels in
Montenegro up to 2030
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SERBIA
Figure 63 Biofuel potential (on the left) and the amount of required feedstock (on the right) to produce biofuels in Serbia
up to 2030
UKRAINE
Figure 64 Biofuel potential (on the left) and the amount of required feedstock (on the right) to produce biofuels in
Ukraine up to 2030
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ANNEX III: 2020 Biofuel Demand related Land use requirements
Methodology
Based on the 2020 bioethanol and biodiesel targets set by the CPs (according to the NREAPs of
Kosovo*, Moldova, Serbia and Ukraine) a static back-casting calculation is carried out to define the
land use requirements. More specifically, the following steps are followed:
•
•
•
Biodiesel and bioethanol demand data are converted to demand for biofuel feedstock;
rapeseed, sunflower seed and soybeans for biodiesel and maize, sugar beet and wheat for
bioethanol, as the most common feedstock for biofuel production.
Applying average yield ratios for the years 2005-2015 (extracted from FAO Statistics) amount
of land (Ha) needed for each feedstock is calculated.
Above calculations consider different feedstock percentages for biodiesel and bioethanol
and we looked at 3 different ratio combinations. At the end we averaged the results to
define the average land use requirement for each CP.
Results
Table 28 Average land needed to produce the necessary feedstock for biofuels in each CP in 2020 (Ha)
Feedstock
Kosovo* Moldova Serbia
Ukraine
TOTAL
Rapeseed
5093
8139
34509
15006
62748
Sunflower seed
11970
7978
37005
17353
74306
Soybeans
840
1048
4989
2413
9289
Maize
3752
4714
5883
72068
86418
Sugar beet
0
2001
2522
44685
49208
Wheat
5876
6998
8861
148045
169780
TOTAL
27.531
30.878
93.771 299.569
451.749
2%
3%
1%
Total as share of arable and fallow land 9%
1%
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ANNEX IV: ASSESSMENT OF PLANNED (AND CURRENT) POLICY
INITIATIVES (PPI (AND CPI))
Information on Planned Policy Initiatives (PPI) and Current Policy Initiatives (CPI) was collected from
CP’s NREAPs and Progress Reports. Since CPs reported on planned improvements in a nonhomogenous manner a comprehensive reassessment of the originally provided information was
needed. As a first step, measures were differentiated between current and planned measures. Next,
reported country-specific measures were grouped into:
•
•
The assessment of non-cost barriers
The assessment of financial support measures
Assessment for the mitigation of non-cost barrier
Non-cost barriers affect the market penetration of new technologies. Technology diffusion is
described in Figure 65. The curve describes penetration of the market by a new technology. At first
diffusion for a new technology is very slow, increasing constantly till saturation effects enter so that
the curve converges towards 100%. The shape of this curve is influenced by the non-cost barrier
situation of the corresponding market. Barriers can be grouped into following categories (Resch,
2005):
•
•
•
•
•
•
Industry barriers: Growth rate of industry
Market barriers: Growth rate of industry
Administrative barriers: high bureaucracy
Resource availability
Social barriers: Social acceptance of additional RES-E generation
Technical barriers: Technical feasibility
If barriers in the respective markets are strong, the shape of the S-curve correlates more with the
blue-dashed graph beneath the blue graph Figure 65. If non-cost barriers are mitigated by national
authorities, the diffusion of new technologies will fasten and the shape of the S-curve will lie above
the blue graph in Figure 65.
Figure 65. S-curve: Market penetration of new technologies (Resch, 2005).
In a first step all measures were qualified regarding to which energy sector(s) are covered. In a
second step all measures for the CP’s were interpreted by their mode of action. On the one hand
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measures can mitigate non-cost barriers of new technologies, and on the other facilitate a support
mechanism in the form of financial aid to make the investment in new technologies more lucrative.
Table 29 gives an overview of the measures which contribute to the mitigation of non-cost barriers.
The column “Quality of mitigation” indicates an evaluation of the impact of the individual
measurements. The positive changes in per cent compared to the CPI scenario per technology
category and country are the result of the added up values from the quality of mitigation of all
measures. All mitigation measures are qualified from 1 to 3, which equal from 0% to 37.5%. If for
example a measure of a CP’s NREAP or Progress Report affects all energy sectors with a quality
degree of 1, all energy sectors in Table 30 show a positive change mitigating non-cost barriers
compared to the CPI scenario of 12.5 %. This step is repeated for all mitigation measures of all CP’s
NREAPs and Progress Reports to add up all positive changes for each country and energy sector in
Table 30.
Policy measures for biofuels have been evaluated in a different context. Although most of
Contracting Parties have made progress by establishing a legal framework for biofuels in line with
Directive 2003/30/EC, which was repealed by the RES Directive 2009/28/EC, the progress in
introducing mandatory blending targets for biofuels in road transport is still very limited.
In Albania is established a binding biofuels target of 5% by volume in 2010 and 10% by volume from
2015 onwards, imposed on ‘wholesale companies in possession of “trade license” for oil byproducts.’ However, despite the binding targets set out in the biofuels law, and tax exemptions for
domestically produced biofuels and raw materials, current supply of biofuels within Albania is very
low. There are several reasons for this, but the absence of any measures to enforce the blending
obligation (i.e. such as sanctions on suppliers who do not fulfil their obligation) is a key factor.
Due to above mentioned reasons, the measurements for the mitigation of non-cost barriers have
not been evaluated with the different method.
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AL
AL
AL
AL
AL
AL
AL
AL
AL
AL
RES
technologies
covered
Investors
RES-E
Obligatory and priority connection of producers
of electricity from renewable sources to the grid
Energy generated(ktoe)
Payment only of the direct costs of connection to
the grid
Penalty payments in the event of curtailment of
production due to the network operator’s fault
(take or pay clauses)
Installed capacity (MW/year)
Investors
RES-E
Energy generated (ktoe)
Investors
RES-E
Licensing procedures for producers of electricity
from renewable sources up to 15 MW installed
capacity
Energy generated (ktoe)
Guarantees of origin for all non-priority RES (all
RES expect SHPPs)
Obligations for persons placing on the market
petroleum-derived liquid fuels for transport
purposes to offer fuels for diesel and petrol
engines blended with biofuels in the percentage
terms laid down in the existing Biofuel Law
Energy generated (ktoe)
Investors
RES-E
Biofuel production and use
(ktoe)
Investors, traders, and
public administration
RES-T
biofuels
The authority responsible for supervising the
quality of pure biofuels
Testing equipment for pure biofuels provided to
the Institute for Metrology for technical
surveillance
Use of biofuels for transport
Producers
Quality of
mitigation
(1-3)
Targeted group and or
activity
Transport
Biofuels
Expected results
Heating and
cooling
Name and reference of the measure
Electricity
CC
not specified or
EE measure
Table 29: Overview of respected measurements for the mitigation of non-cost barriers
yes
1
yes
1
yes
0,5
yes
1
yes
0,5
Source
ProgRep
No specific
time limit
ProgRep
No specific
time limit
15 years
ProgRep
SHPP
Original date
indication of
Source
ProgRep
No specific
time limit
ProgRep
No specific
time limit
In force from
2009
ProgRep
yes
Distributors and end
users
Distributors, end users
and public
RES-T
biofuels
RES-T
biofuels
Adoption of policies and measures for increasing Energy generated from SWHS
the use of solar energy in buildings to install solar
water heating system
Newly built or existing
ones, public or private
buildings
RES-H SWHS
Installation of solar water heating systems by
taking into account in the certificate for energy
performance of the building issued according to
the provisions of the Law on energy efficiency.
Newly built or existing
ones, public or private
buildings
RES-H SWHS
Use of biofuels for transport
Energy generated from SWHS
yes
ProgRep
January 2013
ProgRep
January 2013
ProgRep
January 2013
ProgRep
January 2014
yes
yes
yes
1
1
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and Use of Renewable Energy in the Energy Community – Final Report
AL
All domestic and imported solar water heating
systems shall meet minimum technical
requirements
Energy generated from SWHS
Certificate of Origin Rule for the establishment of
a system of certificates of origin for electricity
produced from renewable energy sources, from
waste and co-generation in combination with
heat in a single generating unit
Transparency of electricity
generation from RES
Public awareness raising campaign on energy
efficiency and renewable energy sources
Public inform ation,
stimulation of interest on use
of RES
General public
Study on development of energy production
from Biofuels
Create of database on use of
Biofuels and attract of
investment
Public Institutions,
planers, and investors
RES-T
biofuels
KO
Map of Wind Energy
Create of wind energy atlas
RES-E Wind
KO
Study about Security of Electricity Supply in
Kosovo
Partially include Renewable
energy sources grid extension
measures and Technical
requirements to wind power
plants
Public Institutions,
planers,and investors
Energy companies,
Investors
KO
KO
KO
ME
ME
ME
ME
Newly built or existing
ones, public or private
buildings
RES-H SWHS
Producers of energy
and energy users
RES-E & RESH
yes
yes
yes
yes
yes
Investors - Privileged
producers
RES-E
Exemption of charges for imbalances by the
system operator for privileged producers
51.4 % of electricity from RES
in gross final electricity
consumption in 2020
Investors - Privileged
producers
RES-E
Compulsory minimal share of electricity from
renewable energy sources in the total electricity
supply that shall be procured by each supplier of
electricity
51.4 % of electricity from RES
in gross final electricity
consumption in 2020
Suppliers of electricity
RES-E
Guarantees of origin
Evidencing the origin of
energy generated from RES
RES and cogeneratio n
producers
RES-E
From 2010 - on
going
ProgRep
From 2009 - on
going
ProgRep
2012-
ProgRep
ProgRep
From 2009 up
to 2014
2013-
ProgRep
2010-
ProgRep
2010-
ProgRep
2010-
ProgRep
2010-
yes
yes
yes
51.4 % of electricity from RES
in gross final electricity
consumption in 2020
ProgRep
yes
0,5
RES-E
Priority in delivery of total electricity generated
in power plants of privileged producers into the
transmission or distribution system
January 2014
1
RES & EE
yes
ProgRep
1
1
yes
1
yes
1
yes
1
yes
1
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and Use of Renewable Energy in the Energy Community – Final Report
ME
ME
SR
SR
SR
UA
UA
UA
Obligation for new buildings in certain climate
zones to cover a quota of their energy needs for
domestic hot water with renewable sources
(solar thermal systems)
Increased use of RES in
buildings
Investors; HVAC
designers
RES-H
Policy and support schemes for promoting use of
renewable energy sources in transport (including
obligations of placing biofuels on the market)
10,2 % RES in transport in
2020
State
authorities;Investors;
Fuel distributors
RES-T
Measure “Guarantee of Origin of Electricity
Produced from Renewable Energy Sources”
Energy Law (“Official Gazette of the Republic of
Serbia”, No. 57/11, 80/11 – correction, 93/12
and 124/12)
increase in the production of
electricity from RES
energy entities
RES-E
Measure “Promotion of Biofuel Production and
Consumption” Energy Law (“Official Gazette of
the Republic of Serbia”, No. 57/11, 80/11 –
correction, 93/12 and 124/12)
increase in biofuel production
and consumption
increase in biofuel
production and
consumption
RES-T
biofuels
Measure “Improvement of the Ministry of Mining
and Energy Website” URL:
http://www.mre.gov.rs/energetska-efikasnostobnovljivi-izvori.php
to increase information
availability; to clarify
administrative procedures in
the RES field; to increase
transparency in the Ministry’s
work;
energy entities, natural
persons
RES
Approving the Rules of connecting electric
installations to electric power networks (NERC
Resolution of 17 January 2013, No. 32).
Regulating the issue of
connecting renewable energy
facilities to electric networks.
Investors, renewable
energy sector entities,
electric power
transmission
organizations.
RES-E
Approving the Procedure of financing the
services of connection of electric installations to
electric power networks (NERC Resolution of 21
November 2013, No. 1467).
Regulating the issue of
financing the services of
connecting electric
installations to electric power
networks.
Investors, power
industry facilities.
RES-E
Approving the Methodology for calculating the
fee for connecting electric installations to electric
power networks (NERC Resolution of 12 February
2013, No.115).
Regulating the issue of
calculating the fee for
connecting electric power
facilities.
Power transmission
organizations, power
industry entities.
yes
ProgRep
2013-
ProgRep
2015-
ProgRep
2014-
ProgRep
2015-
ProgRep
2014-
ProgRep
Enacted: 28
February 2013.
Validity period:
Unlimited.
ProgRep
Enacted: 10
December
2013. Validity
period:
Unlimited.
ProgRep
Enacted: 19
March 2013.
Validity period:
Unlimited.
3
yes
yes
1
yes
yes
yes
yes
yes
yes
1
1
1
RES-E
yes
1
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and Use of Renewable Energy in the Energy Community – Final Report
FYR of
Amendments to the Law on Urban and Spatial
Macedonia Planning
Expanding the scope of use of
the infrastructure project as
new type of urban plan in the
Law on Spatial and Urban
Planning. One of the most
complicated and timeconsuming procedures within
the RE investment process
shortened and facilitated
Investors in certain RE
technologies (SHPP),
planners, architects,
public administration
Introducing possibility for
applying for construction
permit before solving all the
land titles. Construction of the
power plants not prevented
by partially unsolved property
issues.
Investors RE, Public
administration
FYR of
New Law on Spatial and Urban Planning
Macedonia
Further simplify the
administrative procedures and
shorten the timeframe of the
investment process
Investors in certain RE
technologies (SHPP),
planners, architects,
public administration
RES-E & RESH
FYR of
Law on biofuels
Macedonia
Clear rules for biofuels
Energy sector
stakeholders
connected with
biofuels
RES-T
biofuels
FYR of
National Biofuel Action Plan
Macedonia
Setting the annual share of
biofuels to be attained in the
total fuels for transport
quantities
Refineries and
distribution companies
of oil derivatives
RES-T
biofuels
FYR of
Grid rules
Macedonia
Procedure for connection of
the producer is more
transparent, simplified,
shortened, and technical
criteria are defined with
greater precision thus
removing possibilities for
ambiguity and different
interpretation
RES Electricity
Producers
RES-E
FYR of
Amendments to the Law on Construction
Macedonia
RES-E & RESH
yes
yes
2013
ProgRep
2013
0,25
RES-E & RESH
yes
ProgRep
yes
1
ProgRep
yes
yes
0,5
ProgRep
2015
ProgRep
2015
ProgRep
2014
yes
yes
yes
1
158
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and Use of Renewable Energy in the Energy Community – Final Report
FYR of
Guidelines for investors in RE
Macedonia
MO
MO
MO
MO
MO
MO
Simple and up to date
information on all legal
aspects related to
investments in RE for the
potential investors.
Investors in RE
technologies, public
administration
RES
Energy Strategy of the Republic of Moldova till
2030 (GD no.102 of 05.02.2013)
Creation of framework and
stable conditions for RES
development
Energy stakeholders
RES
Law on heating and promotion of cogeneration
(Law no.92 of 29.05.2014)
Creation of framework for RES
development – heating and
cooling
RES producers –
heating and cooling
TSO DSO Heating
suppliers
RES-H
Law on Energy Performance of Buildings (EPB)
(Law no.128 of 11.07.2014)
Framework for improving the
energy performance of
buildings, including promoting
decentralized energy supply
(electricity, heating and
cooling) on RES (particularly
based on solar energy
generation)
Ministry of Regional
Development and
Constructions EEA End
users Public
administration
Buildings owners
RES
Creation of framework for RES
promotion and prioritary
dispatch
RES producers TSO DSO RES-E
Electricity suppliers
Framework for improving the
energy performance of
buildings, including promoting
decentralized energy supply
(electricity, heating and
cooling) on RES (particularly
based on solar energy
generation)
Ministry of Regional
Development and
Constructions EEA End
users Public
administration
Buildings owners
RES
Dissemination of information
RES producers Biofuels
producers Local public
authorities RES
investors End users
RES
Draft law on electricity
Secondary legislation in EPB field
One-stop shop to support investors in renewable
energy
yes
yes
yes
yes
yes
yes
yes
yes
ProgRep
2013-2020
ProgRep
2014
ProgRep
2014
ProgRep
2015
ProgRep
2015
ProgRep
2013-2020
1
0,5
yes
1
yes
yes
Second half of
2015
0,25
yes
yes
ProgRep
1
yes
yes
1
yes
1
159
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and Use of Renewable Energy in the Energy Community – Final Report
MO
MO
Training courses for local public authorities,
regional development agencies and energy
managers
Institutional capacities
development
Development of a study regarding the wind and
solar potential
Wind Atlas Solar Atlas
Local public authorities
Regional development
agencies Energy
managers
RES
Power engineering
institute/ASM
Technical University of
Moldova EEA Local and
foreign consultants
RES
yes
yes
yes
ProgRep
2014-2020
ProgRep
2015
0,5
yes
0,5
Table 30: Summary of planned measures as of CP’s NREAPs and Progress Reports for the mitigation of non-cost barriers per energy sector. The numbers in the table signify percentages to
what extent non-cost barriers are removed. For a more detailed description see paragraph above this table.
Hydrogen
Biofuel - Import
Biomass to Liquid (BtL)
Bioethanol
Bioethanol Plus
38
?
0
0
13
0
13
0
Bio fuel
0 38
?
0 0
0 0
13 13
0 38
13 13
0 0
?
Biodiesel
0 0
0 0
13 13
0 0
13 13
0 0
Heat pumps
0
?
RES-T fußnote
0
?
Solar thermal heating
0 0 0 0 0 0 0 0
0 0 0 0 0 0 0 0
13 13 13 13 13 13 13 13
0 0 0 0 0 0 0 0
13 13 13 13 13 13 13 13
0 0 0 0 0 0 0 0
Pellets
0
?
Log wood
Wood chips
?
Biomass small scale
0
0
?
Sewage gas
?
Non-Grid connected heat
0
0
?
Landfill gas
0
?
Geothermal heat
Agricultural residues
?
Biogenic fraction of waste
Forestry residues
0
0
13
0
13
0
0
0
?
Agricultural products
0
?
0
0
0
0
0
0
Forestry products
0
0
0
0
0
0
Biogas
0
0
0
0
0
0
0
?
Biomass
0
0
0
0
0
0
RES-H
0
0
0
0
0
0
0
?
?
Grid connect heat
0
0
0
0
0
0
0
0
?
Sewage gas - CHP
0
0
0
0
0
0
0
?
Landfill gas - CHP
0
?
Geothermal - CHP
0
0
0
0
0
0
Agricultural residues - CHP
?
Biogenic fraction of waste - CHP
0
0
?
0
0
0
0
0
0
Forestry residues - CHP
0
?
Agricultural products - CHP
Biomass
50
?
33
38
50
50
25
38
Forestry products - CHP
50
?
33
38
50
50
25
38
RES-C
50
?
25
38
50
50
25
38
Biogas - CHP
50
?
25
38
50
50
25
38
Wind offshore
50
?
25
38
50
50
25
38
Wind
50
?
25
38
50
50
25
38
Wind onshore
Tidal
50
?
25
38
50
50
25
38
Wave
50
?
25
38
50
50
25
38
PV-central
50
?
25
38
50
50
25
38
Solar thermal
50
?
25
38
50
50
25
38
Solar
Sewage gas
50
?
25
38
50
50
25
38
PV-decentral
Landfill gas
50
?
25
38
50
50
25
38
Large scale hydro power
50
?
25
38
50
50
25
38
Hydro power
50
?
25
38
50
50
25
38
Small scale hydro power
Geothermal electricity
50
?
25
38
50
50
25
38
Agricultural residues
50
?
25
38
50
50
25
38
Biogenic fraction of waste
Forestry residues
50
?
25
38
50
50
25
38
Agricultural products
Biomass
50
?
25
38
50
50
25
38
Forestry products
RES-E
Biogas
Albania
Bosnia and Herzegovina
Kosovo
Macedonia
Moldova
Montenegro
Serbia
Ukraine
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Table 31 depicts all measures from the CP’s NREAPs and Progress Reports which represent financial support mechanisms for specific technologies and
support strategies. The table explains as well which RES technology is covered by the different support mechanisms and for which time period they are
scheduled.
For financial support measures that lack sufficient information as needed for subsequent model-implementation, adequate assumptions on the detailed
implementation of those envisaged measures have been made. In this context, the assumption was taken that CPs apply support in similar magnitude as
currently implemented on average at EU level.
Country
Measure first
reported in
Table 31: Existing and planned financial measures as of the CP’s NREAPs and Progress Reports.
AL
NREAP
AL
NREAP
AL
NREAP
AL
NREAP
AL
NREAP
AL
NREAP
AL
NREAP
FYR of
Macedonia
FYR of
Macedonia
FYR of
Macedonia
Name and reference of the measure
RES
technologies
covered
Financial support strategy
Progress Report
- Start date of
measure
End date of
measure
Feed-in tariffs for electricity produced from renewable sources (
FIT)
Long-term power purchase agreements with regard to electricity
produced from SHPPs
Obligatory purchase of electricity produced for HPPs of lower 15
MW installed capacity
Zero rate of excise duty for pure biodiesel and reduced rate of
excise duty for biofuel blends of a specified percentage
Energy Efficiency and Renewable Energy Credit Line (‘EERECL’). This
will be fixed after the approval of Energy Efficiency Fund
Energy Efficiency Facility of the European Reconstruction and
Development Bank and as well as European Investment Bank
Any person producing or importing solar thermal systems shall be
exempted from the customs duties and VAT for those solar water
heaters.
RES-E for SHPP
FIT
01.01.2012
n.a.
SHPP
PPA
01.01.2012
n.a.
SHPP
PPA
01.01.2012
n.a.
RES-T biofuels
Tax incentives
01.01.2013
n.a.
EE
Credit line
01.01.2013
n.a.
EE
Credit line
01.01.2010
31.12.2015
RES-H SWHS
Tax incentives
01.01.2013
n.a.
NREAP
National Program for Energy Efficiency in Public Buildings (NPEEPB)
EE
Financing fund
01.01.2014
n.a.
NREAP
Decree on Feed-in-tariffs
RES-E
FIT
17.04.2013
n.a.
NREAP
Establishment of Macedonian EE Fund
EE
Access to financing
n.a.
n.a.
Excluded
measures
Planned
measures
x
x
x
x
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KO
NREAP
Support scheme for electricity generated from RES (wind, biomass, RES
hydro); Rule on the Support of Electricity for which a Certificate of
Origin has been Issued and Procedures of Admission to the Support
Scheme
FIT
01.01.2011
n.a.
KO
NREAP
Support scheme for electricity generated from small (building
integrated photovoltaic BIPV) solar systems; Decision on feed-in
tariffs for solar PV energy
RES-E PV
decentralised
FIT
01.01.2014
n.a.
Promotion of the use of renewable energy for heating/cooling
(investment grants / capacity payment)
FIT bonus for the use of heat from renewable CHP
Excise tax exemption for biofuels
Soft loans program for the financing of renewable energy projects
RES-H
Investment grants & capacity
payments
FIT
Tax incentives
soft loans
01.01.2014
n.a.
01.01.2016
n.a.
01.01.2015
n.a.
n.a.
31.12.2020
Tender regulation for electricity generation from RES
Implement fiscal incentives, such as tax exemptions, soft loans,
etc. for small-scale RES generation facilities
EBRD – MoSEFF II credit line
EBRD – MoREFF credit line
Energy Efficiency Fund
Law on Incentives in Agriculture and Rural Development ("Official
Gazette of the RoS", No. 10/13)
RES-E
RES-E
Tender
Tax exemptions
Soft loans
Credit line & grants
Credit line & grants
loans
– defining the kind of incentive,
manner of using the incentive,
register of incentives in
agriculture and rural
development, as well as
conditions for exercising rights to
incentives in agriculture and rural
development
n.a.
01.01.2014
n.a.
31.12.2020
01.01.2012
01.01.2012
01.01.2013
01.01.2013
n.a.
n.a.
31.12.2020
n.a.
KO
NREAP
KO
KO
KO
NREAP
NREAP
NREAP
MO
MO
NREAP
NREAP
MO
MO
MO
SR
NREAP
NREAP
NREAP
NREAP
SR
NREAP
Decree on incentive measures for privileged power producers
("Official Gazette of the RoS", No. 8/13)
RES-H
RES-T biofuels
RES
RES
RES
EE
RES
RES-E
x
- specifies the categories of
01.01.2013
privileged power producers,
prescribes incentive measures,
conditions for their obtaining,
method of determining of the
incentive period, rights and
obligations arising from these
measures for the privileged power
producers a
x
x
x
x
x
x
31.12.2015
x
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SR
NREAP
SR
NREAP
SR
NREAP
SR
NREAP
ME
ProgRep2014
ME
ProgRep2014
ME
ProgRep2014
ME
ProgRep2014
Decree on the method of calculation and allocation of funds
collected for the purpose of incentive remunerations for privileged
power producers ("Official Gazette of the RoS", No. 8/13)
- specifies the method of
calculation, charging i.e. payment
and collecting of funds related to
incentive remunerations for
Privileged Power Producers as
well as the method of allocation
of funds collected on that basis
01.01.2013
01.01.2013
n.a.
RES-T biofuels
FIT – the amount of special feedin tariff in 2013 is set
not specified
01.01.2013
n.a.
RES-H
not specified
01.01.2013
n.a.
RES-E
FIT
01.01.2010
n.a.
Policy and support schemes for promoting use of renewable energy RES-H
sources in heating and cooling
"Programmes of support for using RES in households and other
RES-H
sectors” Interest-free credit line for installation of solar-thermal
systems for households (MONTESOL program) Interest-free credit
line for installation of heating systems on modern biomass fuels
(pellets, briquettes) for households (ENERGY WOOD program)
Project related to installation of photovoltaic solar systems in
summer pasture lands (SOLARNI KATUNI program)
Not specified
01.01.2015
n.a.
Interest free credit line
01.01.2011
n.a.
Program of subsidies in some municipalities for the installation of
solar systems in new buildings by reducing utility costs (fees for
utility lands)
RES-H
Reducing utility costs
01.01.2009
n.a.
Decree on the amount of special feed-in tariff in 2013. ("Official
Gazette of the RoS", No. 8/13)
Rulebook on incentives for growing raw materials and production
of biofuel
Decree /Recommendation on Incentives for the production of heat
from RES
Feed-in tariffs for electricity produced in power plants using
renewable energy sources and power plants for high efficiency
cogeneration (plants of privileged producers)
RES-E
RES-E
n.a.
x
x
x
SR
ProgRep2014
Мeasure “Promotion of Electricity Production through Incentive
Purchase Prices” Energy Law (“Official Gazette of the Republic of
Serbia”, No. 57/11, 80/11 – correction, 93/12 and 124/12)
RES-E
FIT
01.01.2009
n.a.
SR
ProgRep2014
Regulation on Incentive Measures for Biofuel Production
RES-T biofuels
not specified
n.a.
n.a.
x
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Assessment of Renewable Energy Action Plan Implementation and Progress in the Promotion
and Use of Renewable Energy in the Energy Community – Final Report
UA
ProgRep2014
Adoption of the Law of Ukraine "On Amending the Law of Ukraine
RES
'On Electric Power Industry' Regarding Stimulation of Generation of
Electric Energy from Alternative Sources of Energy": - setting a
"green" tariff for biomass of animal origin, waste, and biogas; differentiation of "green" tariff for micro-, mini- and small
hydropower plants;
- setting a "green" tariff for individual power station construction
stages;
- reducing the "green" tariff for solar power plants;
- setting a "green" tariff for solar power plants in private
households.
FIT
01.04.2014
n.a.
FYR of
Macedonia
ProgRep2014
Support schemes for installation of solar panels
RES-E
Financial incentives,
Investment subsidies. (nonrefundable financial incentives,
loans)
01.01.2007
n.a.
FYR of
Macedonia
MO
ProgRep2014
Credit lines for promotion of the RES and EE
RES & EE
Credit line
ProgRep2014
RES-E
FIT
01.01.2015
n.a.
MO
ProgRep2014
Policy and Support schemes for promoting use of RES in electricity
production
Policy and support schemes for promoting use of RES in transport
RES-T
FIT
01.01.2015
n.a.
MO
ProgRep2014
Policy and support schemes for promoting use of RES in heatingcooling
RES-H
FIT
01.01.2015
n.a.
n.a.
x
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and Use of Renewable Energy in the Energy Community – Final Report
ANNEX V: BACKGROUND DATA ON ENERGY DEMAND
DEVELOPMENTS
This Annex provides an overview of the gross final energy consumption (GFEC) data used in section
3.1. for the assessment of past progress and in section 3.2. for the model-based assessment of
future progress. Thus, demand data served as a denominator to express the overall RES shares per
CP in the specific years. For the modelling task four different assumptions were made regarding the
future development of the GFEC. First, the two scenarios (i.e. reference and efficiency) of the CPs
NREAPs were used. Since these scenarios were derived and published some years ago, these two
scenarios had to be aligned with the recent energy demand developments. Moreover, since data on
solid biomass in the heating sector of CPs was corrected (in accordance with the ECS approach), this
modifications has also to be included in the overall demand data or in the energy balance of a CP.
These two steps, the recent energy consumption development and inclusion of the solid biomass
correction are represented by the dark blue graph in the following figures on a CP basis. The dark
blue graph always stands for the modified efficiency trajectory of the GFEC. The revised reference
trajectory will not be included in the following figures, but would have the same incline as the
original reference GFEC scenario.
Albania
4.000
NREAP reference trajectory
NREAP efficiency trajectory
Historic development (ESTAT)
Modified efficiency trajectory
Historic development modified (ESTAT, ECS)
Development as of Progress Report
3.500
3.000
2.500
2.000
1.500
1.000
500
2020
2019
2018
2017
2016
2015
2014
2013
2012
2011
2010
2009
2008
2007
2006
0
2005
Gross final energy consumption [ktoe]
Figure 66 compares the historic development of the GFEC by using EUROSTAT data with the planned
trajectory for the GFEC of the draft NREAP of Albania. Until 2010 they were nearly concurrent, but
since 2011 a small gap between the actual and the planned development aroused. In 2012 the actual
demand was 9% below the planned trajectory.
Figure 66: Gross final energy consumption according to the NREAP scenarios of Albania compared to the historic
development up to 2013 and the Progress Report. (ECS, 2015; EUROSTAT, 2015; draft NREAP and Progress
Report)
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Bosnia and Herzegovina
Historic development (ESTAT)
NREAP efficiency trajectory
Modified efficiency trajectory
Historic development modified (ESTAT, ECS)
6000
5000
4000
3000
2000
1000
2020
2019
2018
2017
2016
2015
2014
2013
2012
2011
2010
2009
2008
2007
2006
0
2005
Gross final energy consumption [ktoe]
The in Figure 67 presented data for Bosnia and Herzegovina is preliminary as the official NREAP has
not been published yet. As the solid biomass use of Bosnia and Herzegovina was corrected by 606
ktoe, this volume is also added to the modified GFEC. The recent energy demand development in
Bosnia and Herzegovina was negative between 2011 and 2012. This fact is also included in the
update demand trajectories.
Figure 67: Gross final energy consumption according to the NREAP scenarios of BIH(FBiH) and BIH(RS) compared to the
historic development up to 2013. (ECS, 2015; EUROSTAT, 2015; NREAP of BIH(FBiH) and BIH(RS))
Kosovo*
Historic development (IEA)
Development as of Progress Report
Historic development modified (IEA, ECS)
2020
2019
2018
2017
2016
2015
2014
2013
2012
2011
2010
2009
2008
2007
2006
2.000
1.800
1.600
1.400
1.200
1.000
800
600
400
200
0
2005
Gross final energy consumption in ktoe
NREAP reference trajectory
NREAP efficiency trajectory
Modified efficiency trajectory
Figure 68: Gross final energy consumption according to the NREAP scenarios of Kosovo* compared to the historic
development up to 2013 and the Progress Report. (ECS, 2015; IEA, 2015; NREAP and Progress Report)
Figure 68 compares the actual development of the GFEC in Kosovo with the planned trajectory of
the NREAP. While in 2010 the actual GFEC was still slightly above the planned consumption (+1.1%)
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this situation changed until 2013, when the actual consumption was more than 9% below the
efficiency trajectory. It will be necessary to track the future development to evaluate if this gap stays
permanently.
FYR of Macedonia
NREAP reference trajectory
NREAP efficiency trajectory
Modified efficiency trajectory
Historic development (ESTAT)
Development as of Progress Report
Historic development modified (ESTAT, ECS)
3.000
2.500
2.000
1.500
1.000
500
2020
2019
2018
2017
2016
2015
2014
2013
2012
2011
2010
2009
2008
2007
2006
0
2005
Gross final energy consumption [ktoe]
In the graph for FYR of Macedonia it can be seen that the historical development of the GFEC is
mostly in line with the planned trajectory. After a 4% increase from 2010 to 2011, in 2012 the GFEC
went back to the level of 2010 and decreased even further in 2013. Therefore, in 2013 the actual
GFEC is nearly 8% below the efficiency trajectory of the draft NREAP.
Figure 69: Gross final energy consumption according to the draft NREAP scenarios of FYR of Macedonia compared to the
historic development up to 2013 and the Progress Report. (ECS, 2015; EUROSTAT, 2015; draft NREAP and
Progress Report)
Moldova
In Figure 70 it can be seen that historic development of the actual GFEC of Moldova is constantly
above the planned trajectory. In 2012 the actual GFEC was 5.2% above the energy efficiency
trajectory and 9.8% above the reference trajectory. AS a result the modified efficiency trajectory
shows a GFEC which lies 150 ktoe above the original.
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NREAP reference trajectory
NREAP efficiency trajectory
Modified efficiency trajectory
Historic development (IEA)
Development as of Progress Report
Historic development modified (IEA, ECS)
3.000
2.500
2.000
1.500
1.000
500
2020
2019
2018
2017
2016
2015
2014
2013
2012
2011
2010
2009
2008
2007
2006
0
2005
Gross final energy consumption [ktoe]
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Figure 70: Gross final energy consumption according to the NREAP scenarios of Moldova compared to the historic
development up to 2013 and the Progress Report. (ECS, 2015; IEA, 2015; NREAP and Progress Report)
Montenegro
NREAP reference trajectory
NREAP efficiency trajectory
Modified efficiency trajectory
Historic development (ESTAT)
Development as of Progress Report
Historic development modified (ESTAT, ECS)
1.200
1.000
800
600
400
200
2020
2019
2018
2017
2016
2015
2014
2013
2012
2011
2010
2009
2008
2007
2006
0
2005
Gross final energy consumption [ktoe]
According to the EUROSTAT data Montenegro managed to have a constant decrease in GFEC since
2008, which results in a total reduction of 21% between 2008 and 2012 (Figure 71). It is important to
mention here that there are significant differences between the historic data and the data in the
Progress Report and NREAP of Montenegro.
Figure 71: Gross final energy consumption according to the NREAP scenarios of Montenegro compared to the historic
development up to 2013 and the Progress Report. (ECS, 2015; EUROSTAT, 2015; NREAP and Progress Report)
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NREAP reference trajectory
NREAP efficiency trajectory
Modified efficiency trajectory
Historic development (ESTAT)
Development as of Progress Report
Historic development modified (ESTAT, ECS)
12.000
10.000
8.000
6.000
4.000
2.000
2020
2019
2018
2017
2016
2015
2014
2013
2012
2011
2010
2009
2008
2007
2006
0
2005
Gross final energy consumption [ktoe]
Serbia
Figure 72: Gross final energy consumption according to the NREAP scenarios Serbia compared to the historic
development up to 2013 and the Progress Report. (ECS, 2015; EUROSTAT, 2015; NREAP and Progress Report)
Figure 72 shows that until 2011, the actual GFEC developed very similar to the planned trajectory of
the NREAP but on average 2% below the trajectory. In 2012 that gap widened, resulting in 11%
difference between the actual and the planned GFEC.
Ukraine
2020
2019
2018
2017
2016
2015
2014
2013
2012
Historic development (IEA)
Development as of Progress Report
Historic development modified (IEA, ECS)
2011
2010
2009
2008
2007
100.000
90.000
80.000
70.000
60.000
50.000
40.000
30.000
20.000
10.000
0
2006
NREAP reference trajectory
NREAP efficiency trajectory
Modified efficiency trajectory
2005
Gross final energy consumption [ktoe]
According to Figure 73 the actual GFEC increased in the years 2010 and 2011, but decreased ever
since that. It can be assumed that this development will be prolonged due to the conflict in the
Eastern Ukraine. In 2013 the actual GFEC was 3.5% below the NREAP trajectory.
Figure 73: Gross final energy consumption according to the NREAP scenarios of Ukraine compared to the historic
development up to 2013 and the Progress Report. (ECS, 2015; IEA, 2015; NREAP and Progress Report)
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ANNEX VI: Consistency of the NREAPs with other national energy
strategies
Summary
The following document summarises comparisons of published forecasts of gross final energy
consumption (GFEC) and energy from renewable sources in the National Renewable Energy Action
Plans (NREAPs) and other documents, usually from national energy strategies. In all countries, we
have presented the efficiency scenarios from the NREAPs. For some countries there are no data for
comparison (e.g. Moldova).
The various documents have different vintages with the NREAP usually being the most modern. Our
working hypothesis is that the more recent the data source, the lower are the predictions of the
development of renewable energy and of energy consumption. Some of the data sources were
published before European debt crisis (2010). These data sources may overestimate the GFEC.
In general, the other sources of information do not give as much detail on the types of renewable
energy as do the NREAPs. For example, the other data sources often give estimates for hydro
generation without distinguishing between small and large scale (as do the NREAPs).
PLEASE NOTE THAT VALUES USED IN THIS REPORT WERE PARTLY DERIVED FROM THE ORIGINAL DATA AND
DOES THUS NOT ALWAYS REPRESENT VALUES EXPLICITLY GIVEN IN THE SOURCES. THIS SERVED TO MAKE DATA
COMPARABLE. MODIFICATIONS MADE INCLUDE FOR INSTANCE THE CONVERSION FROM TFEC TO GFEC OR THE
INTEGRATION OF DIFFERENT DATA CATEGORIES AS WELL AS THE CALCULATION OF ABSOLUTE VALUES BASED
ON GIVEN SHARES. FURTHER, WHERE STATED, GRAPHS PARTLY CONTAIN MERGED DATASETS FROM
DIFFERENT SOURCES.
Albania
Data sources
•
•
•
•
Draft Albanian Renewable Energy Action Plan, 2012 (NREAP)
National Energy Efficiency Action Plan 2010-2018, 2009 (NEEAP)
TSO electricity demand, cited in: Ose, HT. 2009. Optimal use of the hydro resources in
Albania (TSO/OSE)
Energy Community Secretariat, (ECS)
Data
GFE consumption values and estimates are available from two sources, the draft NREAP and NEEAP.
The sources match at the starting point of the draft NREAP values (2009) and the end of the NEEAP
values (2017 and 2018). In the most recent estimate, draft NREAP (2012), the forecasted growth in
GFEC from 2009 to 2020 is 13,322 GWh – or roughly 4.4% per year.
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Figure 74: GFEC/ GFEC Electricity projections for Albania
For the electricity consumption, the draft NREAP (2012) shows a significantly lower projection as
compared to TSO demand data of 2009 (cited in Ose, 2009). The NREAP shows values that are about
1,500 GWh lower in 2015 and over 2,000 GWh lower in 2020 than TSO values. However, the NEEAP
for which the electricity share in total consumption is only given for 2008 matches well with the
NREAP.
For the other categories, there is no data from another source in enough detail to corroborate the
NREAP data.
Kosovo*
Data sources
•
•
•
•
•
•
National Renewable Energy Action Plan 2011 – 2020, 2012 (NREAP)
2nd National Energy Efficiency Action Plan of Kosovo*, 2013 (NEEAP)
Administrative instruction Nr. 01/2013 on renewable targets (AdInstr)
Energy Strategy Kosovo* 2013-2022, 2013 (EnStrat)
Annual Energy Balance Of Republic Of Kosovo* For The Year 2014 (EBal)
Energy Community Secretariat, (ECS)
Data
GFEC estimates are available from three sources, NREAP, NEEAP and the Energy Balance. Where no
gross data was available, a conversion from net/total (TFEC) to gross values was done for electricity
assuming TFEC being 89.5% of GFEC. The NREAP values are on average 1,600 GWh (about 10%)
higher than the NEEAP values. The two values run almost parallel to each other. The NEEAP,
however, refers to different reports, some of which get closer to, but do not reach the NREAP data.
The different sources use different categories, i.e. sectors; primary energy sources; or transport,
heating and cooling and electricity. However, all sources seem to take into account the latter three
categories.
For electricity, the picture is comparable. Only additional data from the Energy Strategy (EnStrat) is
above NREAP values, except for the peak in 2011. Also here, TFEC values were converted to GFEC.
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The two total RES-H estimates are the same. The RES-E estimates from the NREAP are lower than
the values in the earlier AdInstr document towards 2020 that put a much larger focus on small
hydro. For RES total, for 2009, data from the EBal report was used, from 2010 on NEEAP values are
shown. Similar to RES-E that were based on the AdInstr document, the RES total projections of the
NEEAP are higher than the NREAP data towards 2020. They thus show a more optimistic perspective
on RES-E expansion. This picture is comparable for the RES share but the NREAP values constantly
represent the lowest values. For this share, absolute heat and transport values stem from the
NEEAP, while absolute electricity values were available from the AdInstr document. Shares were
calculated based on NEEAP TFEC values converted to GFEC except for 2009 where only the EBal
document contained a TFEC value.
The last figure shown above compares the NREAP RES share till 2020, with the AdInstr and in
addition included a scenario where the AdInstr is implemented but the large HPP Zhur is not being
built. The figure shows that even if Zhur is not built 28% RES share will be met.
Figure 75: GFEC/ GFEC Electricity projections for Kosovo*
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Figure 76: RES Detail projections for Kosovo*
Serbia
Data sources
•
•
•
National Renewable Energy Action Plan of the Republic Of Serbia, 2013 (NREAP)
Energy Development Strategy of Serbia to 2025 with Projections until 2030, (EnStrat)
Energy Community Secretariat, (ECS)
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Data
Of the above documents, only the NREAP contains specific information about the GFEC for
electricity. Therefore, only the overall GFEC is shown in comparison between the NREAP and the
Energy Strategy. The GFEC estimates (energy efficiency scenarios) for both sources of data are very
similar. Also, both documents give information about gross final energy consumption for transport,
where data given in the Energy Development Strategy show lower values between 2015 and 2020,
as the NREAP does.
Figure 77: GFEC/ GFEC Transport projections for Serbia
Figure 78: RES Detail projections for Serbia
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The two RES-H estimates are the same. However, one can see that there are slight differences in the
details on the sources of the RES-H. The EnStrat has more solid biomass than does the NREAP. The
RES-E from the two documents is also in total very similar. The NREAP distinguishes between the
types of hydro production and has electricity generated from biogas, solid biomass and more wind
energy than does the EnStrat.
Montenegro
Data sources
•
•
•
National Renewable Energy Action Plan to 2020 Montenegro, 2014 (NREAP)
Energy Development Strategy of Montenegro by 2030, May 2014 (EDS2030)
Energy Community Secretariat, (ECS)
Data
GFEC values of the above documents (NREAP and EDS2030) differ significantly. The NREAP has a
slightly higher estimate of GFEC in 2020 than the EDS2030 has for both scenarios, the reference
(REF) as well as the lower energy efficiency (EE) case.
Figure 79: GFEC projections for Montenegro
For the GFEC of both scenarios (REF and EE) given in the Energy Strategy, assumptions regarding the
operation of the large aluminum smelter (KAP) have been made (in order to compare the NREAP
with the Energy Strategy). The reference as well as the energy efficiency case of the EDS2030
strategy (in the graphs below stated as EDS2030 REF and EDS2030 EE) assume that KAP operates at
50% capacity and consumes 84 MW. Sensitivity cases in the contrast to these base scenarios assume
1) that KAP reaches full operation of 168 MW by 2020 and 2) that KAP is closed in 2015. For both
cases results are shown in the figures below.
Although also in the NREAP full operation of KAP is already assumed by 2020, values for NREAP and
the EDS2030 sensitivity case where KAP goes from 50% to 100% in 2020, differ. This is based on
different assumptions on the KAP maximum capacity, where in the NREAP the KAP maximum
capacity is stated to 220 MW and in the EDS2030 to 168 MW. Within the NREAP the plan for the
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period up to 2020 is additionally also to increase production of the Steel Plant up to a load of 35
MW.
Figure 80: KAP sensitivity analysis – GFEC projections for Montenegro
For RES-E Detail projections of Montenegro, the NREAP has been compared to the reference
scenario of the EDS2030 strategy only as detailed information on RES is only available for the REF
scenario and not for the EE scenario.
RES-E estimates are quite similar for the NREAP and the EDS2030 strategy. Slight differences can be
found only regarding solid biomass and hydro large-scale estimates for 2020, where in the NREAP
slightly lower values are assumed. There are however significant differences between the NREAP
and EDS2030 estimates of RES-H. While on average both projections show a comparable increase
from 2015 on, a much higher increase is assumed in the strategy by 2015, leading to a more than
twice as high projection in 2020 as the NREAP (except for heat pumps, values are given in the EDS
2030 only for 2010, 2015, and 2020 leading to close to linear increases in between). Higher EDS2030
assumptions are mainly due to higher solid biomass and heat pumps estimates compared to NREAP
data. Regarding RES-T, in earlier years EDS2030 estimates are lower than NREAP values, however in
2020, RES-T in the EDS2030 strategy is estimated to exceed the RES-T 2020 NREAP estimate. In total
RES assumptions in the EDS2020 strategy are importantly higher than NREAP estimates
(51%/5700 GWh versus 36%/4180 GWh).
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Figure 81: RES Detail projections for Montenegro
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FYR of Macedonia
Data sources:
•
•
•
•
•
Draft National Renewable Energy Action Plan to 2020 FYR of Macedonia
Strategy for Energy Development in the Republic of Macedonia until 2030, 2010 (RES
strategy)
Third National Communication to the UNFCC, 2013 (3rdNat)
Draft EnStrat 2015 (based on Third National Communication)
Energy Community Secretariat, (ECS)
Data
Of the above documents, the RES strategy as well as the NREAP consider different scenarios. The RES
strategy distinguishes between three scenarios, whereas only two of them are considered in this
analysis. The RES strategy S2 scenario assumes an increase in electricity consumption of 3% and the
construction of a lignite thermal power plant. The RES strategy S3 scenario assumes an equivalent
increase in consumption but includes nuclear option. Also, the RES strategy S3 scenario, with a
comparable low energy demand forecast, was used as the basis scenario for the NREAP and lead to
21% RES in 2020.
Within the NREAP, besides the 21% RES scenario, also two other scenarios have been considered:
one leading to 25% RES in 2020 and called “2020 S3 optimistic scenario 2013”, the other leading to
28% RES in 2020 and called “2020 S3 special efforts scenario”. The first of these two scenarios is
presenting values recalculated based on the most recent input data and changes in the energy
consumption development in the period 2009-2011. The second assumes further reduction in price
of the equipment for various RES technologies (solar panels, biogas/biomass plants, etc.) as well as
more stringent operational rules in the electricity sector which may relax position of the system
operators. The most recent of the above documents, the third national communication to the
UNFCC, assumes the lowest gross final energy consumption (strongly deviating from expected values
of other documents), whereas the RES strategy S2 scenario predicts the highest. Except from the
3rdNat Communication, values predicted for GFEC from different scenarios are quite similar.
The graph next do gross final energy consumptions shows the particular portion of RES (in %) in
gross final energy consumption assumed by each category. This data however is not available for the
3rdNat Communication, as only RES electricity but not RES transport and heat is considered in this
strategy.
Figure 82: GFEC/ % RES in GFEC projections for FYR of Macedonia
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Figure 83: RES Detail projections for FYR of Macedonia
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Regarding RES-E, values are generally lower for RES strategy scenarios as for NREAP 25% and NRAP
28% scenarios. In 2020 however the lowest RES-E value is expected by the draft new Energy Strategy
, thus as much lower hydro and wind is expected to be achieved compared to other scenarios. Also
the NREAP 21% scenario (equal to the RES strategy S3 scenario) is considering less hydro expansion
in comparison to other scenarios. This scenarios result however in a higher total RES-E value than for
the Draft EnStrat 2015 (based on the 3rdNat Communication). This is based on the higher expected
expansion of other RES technologies. There are no differences between NREAP 25% as well as
NREAP 28% concerning forecasted development of the electricity generation from hydro wind and
PV, however in NREAP 28% scenario more biomass/biogas is expected to be expanded.
A similar trend is shown regarding RES-H, where RES strategy values are in general also constantly
lower than NREAP 25% and NREP 28% values. NREAP 25% and NREAP 28% in comparison to other
scenarios assume higher geothermal, solid biomass and solar thermal heating and hot water values
than other scenarios.
Also RES transport and RES total shows the same structure than RES-E and RES-H as highest values
are expected in the NREAP 28% and NREAP 25% scenario.
Moldova
Data sources:
•
•
•
NATIONAL RENEWABLE ENERGY ACTION PLAN OF THE REPUBLIC OF MOLDOVA FOR 20132020, 2013 (NREAP)
Energy Strategy of the Republic of Moldova until 2030 (ES)
Energy Community Secretariat, (ECS)
Data
For the overall GFEC data, only electricity data are available in both used documents. The base case
of the ES is slightly above the NREAP values and largely parallel. Interestingly, overall GFE remains
almost constant between 2011 and 2020 in the NREAP, while electricity values show an important
increase.
Figure 84: GFEC/ GFEC Electricity projections for Moldova
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For all other categories values are only available in the NREAP. Most remarkable is a very steep
increase of renewable energy from 2016 on as well as a decrease of transport values.
Ukraine
Data sources:
•
•
•
Report on the Results of Stimulation and Use of Energy from Renewable Sources, 2014
(NREAP)
Energy strategy of Ukraine on 2030, 2013 (ES2030)
Energy Community Secretariat, (ECS)
Data
GFEC as well as GFEC electricity assumptions are generally lower within the NREAP as the ES2030
strategy scenarios. GFEC electricity however is in the last two years of estimation (2019 and 2020)
expected to increase considerably, thus passing ES2030 (pes) assumptions and reaching values
similar to ES2030 (base) and ES2030 (opt).
Figure 85: GFEC/ GFEC Electricity projections for Ukraine
RES-E consumption NREAP estimates are similar to RES-E consumption estimates in ES2030 (base)
and ES2030 (opt). RES-E consumption in ES2030 (pes) is estimated as being quite lower, as much less
wind expansion compared to other scenarios is expected within this scenario. Generally, within the
NREAP, large hydro expansion is expected as being lower than in all three ES2030 scenarios. Also
wind expansion is expected to be lower as in two of the ES2030 scenarios (base and opt). Instead
within the NREAP, further expansion of other RES technologies is expected, which is not specified in
the ES2030 strategy.
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Figure 86: RES Detail projections for Ukraine
RES-H NREAP values are much higher than all ES2030 strategy scenarios, however further details
about technologies etc. are not specified. Also there is no data for RES transport.
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