Agder Energi
AE
Promote Renewable Energy, especially hydro power, in the common European electricity market.
ID: 516404410590-13
Lobbying Activity
Response to Climate change mitigation and adaptation taxonomy
27 Apr 2020
Agder Energi, would like to express our support for the opinions of Statkraft. They are the following:
This first delegated act concerning climate change mitigation and adaption has extensive consequences for the perception of renewable technologies. Hydropower stands as a unique renewable electricity generating technology with its multifunctional contributions and level of flexibility. The following key issues underline the barriers posed by the TEG report hindering hydropower from contributing with its full potential to climate change mitigation and adaption.
Creating an unequal level playing field:
The criteria put forth to assess climate change mitigation are not technology neutral for renewable energy sources. Only hydropower faces specific criteria regarding land use and life cycle assessments.
Obliviating the only renewable storage option of electricity:
Hydropower is the only large-scale renewable generating option to offer storage of energy (in form of water in reservoirs) which can be transformed into electricity instantaneously. Hydropower storage – in line with other storage technologies - should therefore be automatically eligible under the Taxonomy without any further requirements.
Recognizing hydropower as an enabling activity:
Hydropower plants with reservoirs are enabling adaptation, by being actively used to mitigate floods and droughts, limit damage to assets and economic activities and indirectly enable more intermittent renewable power. We suggest recognizing hydropower as an “Enabling activity” in the technical screening criterias. We strongly object to categorising hydropower as “Transitional activity” as this disregards hydropower’s unique capabilities to provide large-scale and renewable flexibility to power systems.
Narrow approach to sustainability:
While the UN definition of sustainability balances economic, social and environmental perspectives, the proposed approach solely focusses on the environmental dimensions, thus neglecting other important multi-purpose contributions of hydropower to sustainability.
Compromising the subsidiarity principle:
Hydropower is site-specific, adapted to local needs and conditions in a water body. The sustainability of each hydropower plant is assessed through national licensing processes considering regional and local particularities in the context of each member state. Additional criteria at EU level may increase the administrative burden in financing hydropower and lead to a loss of flexible clean energy.
Size is not a guarantee for sustainability:
Possible adverse effects of hydropower are always plant and site specific, and size has never been an appropriate criterion to judge whether a hydropower project is sustainable or not. The recommendation to avoid construction of small hydropower under 10 MW should therefore be abated.
Major remaining methodological uncertainties:
The Taxonomy lacks specifications of how to calculate the power density factor and how to handle challenges related to life-cycle assessments. We therefore suggest including more detailed instructions on how to measure power density, hydropower’s carbon footprint and to verify that this is relevant for hydropower in different European countries:
• Power density factor
The power density must acknowledge the NET effect of carbon emissions by deducting the natural carbon emissions prior to impoundment (as also pointed out by the IPCC). The calculation must be applicable for different hydropower schemes, such as:
o multiple reservoirs
o cascading hydropower plants
o multipurpose reservoirs (irrigation, floods, drinking water, navigation, recreation)
o modernization without changes to the reservoir
• Life-cycle assessments
Further clarification is needed on how to document consecutive reduction of GHG emissions and how to allocate GHG emissions originating from different human activities in multipurpose reservoirs such as carbon inflow from agriculture or sewage.
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