France Renouvelables
FEE
France Renouvelables est l’association porte-parole des énergies renouvelables électriques en France.
ID: 661750337837-68
Lobbying Activity
Response to Implementing Act on non-price criteria in renewable energy auctions
21 Feb 2025
France Renouvelables/FR advocates for a clear and implementable policy, aligned with the NZIAs objectives to strengthen the EU solar and wind supply chain, without delaying renewables deployment. The regulation must be fit for purpose and avoiding unnecessary complexity. Most importantly, the implementing act must be clear enough so that all Member States (MS) share the same interpretation of all non-price criteria. The industries simply cannot afford to comply with 27 different sets of rules. FR strongly supports the « Harmonized implementation » approach to insure an efficient deployment of the NZIA criteria and limit bureaucratic burden. Art.4: Companies should reference existing reports instead of creating new ones for each bid. Compliance with the core due diligence elements should be company-wide or at the level of a business-activity, not project-specific. Art.5&16: FR supports cybersecuritys prominence. Cyber plan due diligence should apply company wide Art.6: Its in line with current practices. In France, unlike most EU countries, bid information is typically limited to intention letters due to long development periods. There is 5-6 years between bid and final investment decision, FiD) which is too long for developers to commit on specific supplier and for suppliers to commit on a composition of its manufactured products. This lack of visibility reduce the effectiveness of the prequalification criteria related to the ability to deliver the project fully and on time and the criteria related to contribution to resilience. Financial requirements should be avoid barriers for smaller developers, fostering competition Art.7&16: FR supports strengthening EU supply chain resilience by diversifying industrial supplies but seeks clarification: -How will the 75% of the New-zero technologies (NZT) be calculated - by final product or component? Does this mean the wind turbine as a final product, with the wind turbine fully assembled, integrated with its foundation or floater? Manufacturers don't import complete wind turbines, but rather components which, together, form the wind turbine as a final product. You have to clarify what is meant by the NZT as a final product -Wind farm developers (onshore&offshore) often source from a single turbine manufacturer for a given project. The 75% rule could deter imports and inadvertently require 100% EU sourcing for key components with regards to the application of 1 and 2. Is it your willingness? In addition, FR propose some adjustments: -With this resilience criterion, the EC and the MS will have to ensure that there is sufficient EU industrial supply at the time of the final investment decision to achieve not only the EU and national energy climate objectives but also the desired tariff levels. Several developers are wondering about the indirect consequences that such provisions could have on the price of the energy produced, especially in the event of a shortage of EU supply in the face of strong international demand -Penalties for failure to comply with commitments made during the call for tenders are necessary to maintain healthy competition while preserving the effectiveness of the system. FR proposes to link the amount of penalties to a maximum percentage of the value of the components concerned by the resilience criterion - Reduce delays between award and FiD to effective resilience criterion and doesn't place an excessive risk on developers. Art. 17 should allow exit clauses if supply chain conditions prevent compliance - Clarify the ECs methodology for assessing EU dependency on NZTs and main components. FR supports technology-specific distinctions in resilience criteria. Art.8: MS should be permitted to use existing national assessments where EU life cycle assessment (LCA) methods are unavailable Art.13: FR supports incorporating measures to enhance pollution reduction in project LCAs
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16 Oct 2024 · Echange sur l'industrie des ENR
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