FEDARENE Position Paper – Proposal for the Renewable energy sources Directive

This position paper is based on consultation with the members of FEDARENE and is in response to the proposal for the Renewable energy sources Directive, released on November 30th 2017. It was drafted with the support of EREN (Castilla y León Regional Energy Agency).

Summary of recommendations

Main Objectives

  • To extend the main Directive goal from 27 to 30% RES participation over gross final consumption as a binding target
  • Obligate each MS to establish their own national objectives (detailed in electrical, thermal and transport by RES)

Funds allocation

  • Diversify public support not only in investment but also in communication, Research, Demonstration, Innovation and business competitiveness.
  • Give the possibility to allocate part of the EU funds dedicated to RES support in successful geographical areas as an incentive to MS and regions or to reserve some specific funds for communication as a percentage (0,1%) of energy costs.

Electricity from RES

  • Propose a more equable position in response to accusations related to electricity from RES support schemes.
  • Maintain the same grid accessibility, priority access and dispatching of the previous directive.
  • Flexibility should be allowed related to future changes of support schemes.

Renewable energy communities

  • Allow local and regional bodies to be partners, and differentiate roles between energy consumers, suppliers and other stakeholders.
  • Downsize to 2 MW and voting rights according to the energy participation percentage.

Heating and cooling

  • A revised article 23 is necessary with specific development of public actions that include new measurements (act at local, regional and national levels, make profitable projects, work with stakeholders, etc.), many of them being presented in “EU Strategy on Heating and Cooling”.
  • A more neutral treatment about district heating (DH) is needed. Nevertheless, DH is an opportunity tool for local authorities.

Business and technological development and innovation

  • Propose a new article about business and technological development and innovation that consolidates current European leadership, defining priority lines or fixing a percentage of the funds for these matters.


  • A meticulous analysis of biomass as energy raw material for energy uses is observed, which provokes a restricted series of obligations with unequal results at the territorial level. In order to minimize this situation, the following solutions could be made.
  • Make the requirements of fulfilment more flexible in different MS according their development.
  • Allocate a bigger amount of EU funds to support less developed member states.
  • Extend the fulfilment of requirements to the use use of any of these raw materials.
  • Maintain the production of conventional biofuels making a transition with advanced biofuels.


  • Stating limits to statistical transfers to 15% to encourage MS to develop their own RES markets.
  • Consider passive energy solar systems as renewable ones.
  • Include “market information” in the national reports.
  • Disincentive any kind of in transferences from non-EU countries.

Administrative procedures

  • State reliable public records of RES installations.
  • Administrative charges not only would be transparent and cost effective but it would also be bureaucratically “friendly”.
  • Clarify the responsibility of public administrations in the duration of the whole administrative procedure.
  • Introduce a fixed administrative period for “small projects”, extending their size from 50 kW to 100 kW.

Extend the analysis

  • Expand the concepts analysed further investments or capital costs items.
  • Act with the principle “first minimize energy consumed and then maximize RES contribution…. after a wider cost – benefit analysis”

Regional and local entities

  • Clarify the administrative competence of each support scheme, giving more relevance to regional and local entities in the management of renewable energy projects.

Avoid consolidation of fossil fuel consumption

  • Eliminating concepts involving a support or a consolidation of fossil fuels consumption.

Introduce the concept of energy urbanism and Extend the type of self-consumer to the industry of tertiary sector.

Read the full Position Paper