ENERCOOP SCIC SA
ENERCOOP
- fournir de l'énergie 100 % verte et 100 % coopérative - développer les énergies renouvelables - délivrer des services énergétiques (maîtrise de la consommation d'énergie, efficacité énergétique, autoconsommation,...)
ID: 598705329006-61
Lobbying Activity
Meeting with Marina Mesure (Member of the European Parliament)
10 Feb 2023 · Energie
2 Apr 2021
Revision of the General Block Exemption Regulation - Enercoop’s Feedback to the roadmap
Presentation of Enercoop
Enercoop is the only 100% green cooperative supplier in France structured in a network of 10 local cooperatives. Enercoop welcomes the revision of the GBER to align it with the European Green Deal and the Industrial Strategy. It is an opportunity to fully take into account the new legislation regarding energy communities.
General overview and feedback based on our experience
It is undeniable that the GBER, together with the other State aid instruments such as EEAG, have allowed renewable energy projects to be integrated into the market. Nevertheless, several mechanisms are currently holding back the development of citizen renewable energy projects led by energy communities.
Firstly, competitive bidding procedure should not be the rule for energy communities because it is not adapted to their specificities, recognized by the EU legislation in the directives 2018/2001 and 2019/944. Their unique characteristics (non commercial purpose, non professional, citizen and local ownership,...) place them in a different legal and factual situation, in particular regarding the equality principle. The trend towards the generalization of competitive tenders for RE support, introduced by the state aid system, has broken the visibility that energy communities enjoyed for the development of RE projects via open window systems.
Secondly, concerning not only energy communities but renewable projects in general, France relies on the European framework to refuse the implementation of regionally differentiated feed-in tariffs for solar energy. Photovoltaic projects are therefore difficult or even unprofitable in the northern half of France without the addition of other public aid.
Recommendations of evolution
In accordance with Article 22(7) REDII, the GBER should enable Member States to design adapted support to energy communities, not according to their size but to their governance. The Commission should therefore consider the following options: (1) increasing the level of thresholds for exempting RECs developing RES projects from bidding procedures or (2) dedicating a special aid regime for energy communities in the GBER. This would be justified by the significant environmental and grid benefits they provide as well as their positive impact on regional and local development opportunities, on social cohesion and social acceptance of the transition.
Last but not least, the European framework should clearly allow Member States to implement regionally differentiated feed-in tariffs for solar energy.
Highlights
It is important to put forward two specific obstacles faced by energy communities in France that undermine their development : accumulation of aids rules (1) and guarantee of origins system (2).
It is crucial to leave the possibility of accumulation of aid, within the limit of an equivalent & reasonable profitability for all. For example (non-exhaustive) : aid aid relating to the fact that the project is carried by an energy community (citizen mobilization, legal studies, etc.), tax incentives for individuals investing in the capital of energy communities, etc.
Last but not least, another obstacle faced by energy communities, and production projects of renewable energy in general, lies in the guarantee of origin (GO) mechanism. Indeed, the European framework allows member States to decide not to issue guarantees of origin to producers that also receive financial support. This approach is strictly applied in France where a producer with public support cannot automatically get the GOs associated with his production. Thus, the traceability cannot be assured. State aid instruments and energy legislation should therefore only leave one option to member States : all producers have access to their GOs, without prejudice to the principle of recital 57 of RED II. GO is a traceability tool, not a support mechanism.
Read full responseMeeting with Phil Hogan (Commissioner)
23 Oct 2017 · Agriculture affairs