Europaudvalget 2015-16
EUU Alm.del Bilag 496
Offentligt
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Nr.
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Spørgsmål
SE SEPARAT DOKUMENT
Are you aware of overlaps or inconsistencies among
the existing planning obligations in the same or
different areas of the energy and climate acquis?
Please provide examples.
Which of the current planning obligations could in
your opinion be streamlined[*] into one integrated
plan and why?
Are there any planning obligations that should be kept
separate from the integrated plan?
Are there any planning obligations that could be
repealed?
Which elements/articles of the current planning
obligations in the field of renewable energy do you
consider indispensable and why? If relevant please,
refer to specific
Articles of the Renewable Energy
Directive.
Svar
No answer.
3a
3b
3c
4
With regard to energy efficiency the planning obligations of the National Energy Efficiency Action Plans and Annual
Reports (NEEAP’s) could be integrated into one consolidated national plan on all planning obligations for energy. It
is, however, hard to estimate the efficiency gains from this. If such a consolidated report will contain the same
requirements as the NEEAPS’ requirements, the efficiency gains from this might be smaller.
In general, all planning relevant for the Energy Union should be integrated in order to minimize administrative costs
and integrated planning should also ensure that the Commission can keep track on the Member States’ efforts and
whether the EU is on track to reach the common EU-targets.
No answer.
In general it would be beneficial to streamline the reporting and planning obligations for renewable energy. In this
context, it is important to continue comprehensive planning and monitoring of national policies on renewable energy
deployment which should be integrated into the new national climate and energy plans.
Article 4 in the current Renewable Energy Directive stipulate that each Member State should adopt a national
renewable energy action plan. The national renewable energy action plans shall set out Member States’ national
indicative trajectories for the share of energy from renewable sources consumed in transport, electricity and heating
and cooling, taking into account the effects of other policy measures relating to energy efficiency on final
consumption of energy. The plans should also consider cooperation between local, regional and national authorities,
planned statistical transfers or joint projects, national policies to develop existing biomass resources and mobilise
new biomass resources for different uses.
It is important to continue the existing obligation to provide indicative trajectories for the share of renewable energy
in consumption as part of the national climate and energy plans. The trajectories should still reflect the shares that
are used in transport, electricity, heating and cooling. It should also be considered to include the gas sector – i.e.
biomethane injected into the natural gas system. The national as well as EU policy measures should be described in
the national plan and the effects of the national plans should be evaluated and transformed into projections for
renewable energy deployment. The projections made by Member States with guidance from the Commission will be
crucial for evaluating the level of ambition in the national plans and whether the binding EU target of 27 % share of
renewable energy consumption in 2030 is likely to be met.
The national plans should continue to include measures of regional cooperation and regional coordination should
play a more important role in the national plans for 2030.
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Which elements/articles of the current planning
obligations in the field of energy efficiency do you
consider indispensable and why? Please, if relevant,
refer to specific Articles of the
Energy Efficiency
Directive
and
Energy Performance of Buildings
Directive.
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7
8
Which elements/articles of the current planning in the
field of low-carbon development strategies do you
consider indispensable and why?
Which elements/articles of the current planning
obligations in the field of infrastructure development
(like for example TEN-E) do you consider
indispensable and why?
Which elements/articles of other existing planning
obligations in the field of energy, including on security
of supply, infrastructure and market integration do you
consider indispensable and why?
In general, all the planning obligations are important. Article 3 in the energy efficiency directive (EED) on the energy
efficiency target is a central element of the Member States energy efficiency planning. Furthermore, article 7 on the
energy efficiency obligation schemes is an important planning tool for the member states, as this article can create the
greatest amount of savings in the EED. With regard to the Energy Performance of Buildings Directive, no
obligations appear indispensable. The only planning obligation “National plans for nearly zero energy buildings” has
already been carried out.
In general it would be beneficial to streamline the reporting and planning obligations for energy efficiency in the
heating and cooling sectors with other planning and reporting EU-obligations in order to illustrate synergies between
different subsectors of the energy sector In this context. It should be noted that - according to the recent published
EU heating and cooling strategy - the potentials for synergies are considerable if energy services for heating and
cooling purposes are integrated and further coordinated with electricity supply.
No answer.
The reporting obligations set out in Art. 5 (4)-(6) of the TEN-E Regulation appear necessary for the monitoring of
the progress of the development of projects of common interest. However, in order to reap any tangible benefits
from the reporting, it would seem necessary to follow up with other initiatives such as active discussions in the
regional groups on how difficulties and delays can be prevented/mitigated.
Commission regulation (EU) No 543/2013 article 11.1
In order to be able to move power from where it is available to where it is most needed and adjust portfolios
accordingly, the market should be provided with information about planned and offered cross-border transfer
capacities. According to Commission regulation (EU) No 543/2013 article 11.1 the TSO is obliged to report to
ENTSO-E on the forecasted and offered capacity (MW) per direction between bidding zones in case of coordinated
net transmission capacity based capacity allocation to ENTSO-E. This is an important indicator since it can show the
availability on the interconnections and give an indication of where there might be bottlenecks or trade restrictions.
Commission regulation (EU) No 543/2013 article 13
As a result of the rapid deployment of intermittent generation sources away from consumption centres, transmission
infrastructure has increasingly gotten congested in large parts of Europe. To relieve congestions TSOs have
increasingly intervened in market operations instructing market participants to change their generation or trading
commitments. In order to enable the market to understand where and why congestion management measures have
become necessary, TSOs need to provide timely, detailed and reasoned information about their actions. Useful
indicators include the obligations for the TSOs to report to ENTSO-E on the following:
Information relating to congestion management measures:
A.
information relating to dispatching per market time unit, specifying:
•
the action taken (that is to say production increase or decrease, load increase or decrease),
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•
•
•
B.
•
•
•
•
the identification, location and type of network elements concerned by the action,
the reason for the action,
capacity affected by the action taken (MW);
information relating to countertrading per market time unit, specifying:
the action taken (that is to say cross-zonal exchange increase or decrease),
the bidding zones concerned,
the reason for the action,
change in cross-zonal exchange (MW);
C.
the costs incurred in a given month from actions referred to in points (a) and (b) and from any other
remedial action.
Regulation (EC) No 714/2009
Lastly, the Regulation (EC) No 714/2009 provides conditions for cross-border access to the network. National
energy regulators monitor the TSOs income on congestions. This is an important indicator as (EC) No. 714/2009
stipulates that income from congestion should be invested in ensuring the availability of the allocated capacity or in
maintaining or increasing interconnection capacities through network investments, in particular in new
interconnectors. Monitoring income from congestion provides an indication of how the interconnector is utilised
and whether capacity should be increased.
No clear picture exists on the administrative burden of the current planning and reporting obligations, but as a
matter of principle, a lower administrative burden is always a priority.
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10
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Can you provide qualitative or quantitative evidence
on the administrative burden on Member States and
other stakeholders resulting from planning obligations
at EU level?
SE SEPARAT DOKUMENT
SE SEPARAT DOKUMENT
Are you aware of overlaps or inconsistencies among
the existing reporting obligations in the same or
different areas of the energy acquis? Please provide
examples.
Energy Data is generally reported to EUROSTAT at the same time as the same data are used for the reportings
under the Renewable Energy Directive, the Energy Efficiency Directive (article 24 (1)), etc. It should be considered
whether the Commission, on the basis of the EUROSTAT reportings, could make the necessary calculations, instead
of receiving the same data from Members States under different directives.
Another example is the effect on CO2 emissions of deployment of Renewable Energy which is being reported every
two years, in December, under the Renewable Energy directive. At the same time, every second year in March an
obligation under the MMR requires member states to report ex-post and ex-ante estimated GHG reduction effects
of implemented policies and measures. This is an area where a streamlining of reporting could be considered.
With regard to NEEAPs (EED) it will make sense to include all of the building area policies into this one report and
streamline these with the Energy performance of Buildings Directive (EPBD) reporting obligations.
3
13a
a) Which of the current reporting obligations could in
your opinion be streamlined[*] into one integrated
 EUU, Alm.del - 2015-16 - Bilag 496: Notat samt høringssvar vedrørende strømlining af planlægning og rapportering som en del af forvaltningssystemet for Energiunionen
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report and why?
13b
13c
14
Are there reporting obligations that should be kept
separate from the integrated report?
Are there reporting obligations that could be repealed?
Which elements/articles of the current reporting
obligations in the field of renewable energy do you
consider indispensable and why? Please, if relevant,
refer to specific articles of the Renewable Energy
Directive.
Today the EPBD requires annual reporting which has overlaps with the NEEAPs: The reporting obligation under
EPBD, Article 10 (“draw up a list of proposed measures and instruments including those of a financial nature, other
than those required by the EPBD, which promote the objectives of the Directive” Much of the same information is
provided in NEEAPs. Accordingly the reporting obligation should be transferred completely to the EED (NEEAP)
(currently optional).
No answer.
Not necessarily. It is of great importance that Member States are obliged to report on their obligations in order to
allow the Commission to keep track of the efforts in the Member States as well as on whether the EU is on track
towards reaching the common EU energy and climate targets.
The most indispensable reporting obligation is the quantification of the progress made by Member States with
regards to the national deployment of renewable energy in the energy and transport sector. The progress should be
evaluated every two years with regards to the efficiency of existing policies and the progress made towards a national
indicative renewable 2020 trajectory.
The Commission should provide a template for the reporting and specify how the gross final consumption of
electricity, transport, heating and cooling from renewable energy sources should be calculated by the Member States.
This will be crucial in order to keep track of the collective progress made by the Member States towards the binding
EU target of at least 27 % renewable energy consumption in 2030.
The monitoring of bioenergy sustainability should be continued and strengthened as part of a new comprehensive
EU bioenergy policy that covers both solid biomass, biofuels and biogas for electricity, heating, cooling and
transport.
In Article 24.1 of the Energy Efficiency Directive and annex XIV part I, a rather large number of annual reports are
required, including annual statistics for electricity and heat generation from CHP-plants and industrial waste plans. In
Annex XIV, part 2, national energy efficiency action plans shall be prepared every three years, including assessments
of progress achieved in implementing the comprehensive assessments according to Article 14.1 in EED.
Future reporting should be streamlined and have a well-defined purpose, e.g. according to monitoring of European
wide progress for achieving EU targets in 2030. Annual reporting of statistical information should be limited taking
into account that such reporting to a large extend already is reported to EuroStat by MS.
No answer.
The reporting obligations set out in Art. 5 (4)-(6) of the TEN-E Regulation appear necessary for the monitoring of
the progress of the development of projects of common interest.
However, in order to reap any tangible benefits from the reporting, it would seem necessary to follow up with other
initiatives such as active discussions in the regional groups on how difficulties and delays can be prevented/mitigated.
4
15
Which elements/articles of the current reporting
obligations in the field of energy efficiency do you
consider indispensable and why? Please, if relevant,
refer to specific articles of the Energy Efficiency
Directive, the Energy Performance of Buildings
Directive and the legislation on products
16
17
Which elements/articles of the current reporting in the
field of low-carbon development strategies do you
consider indispensable and why?
Which elements/articles of the current reporting
obligations in the field of infrastructure development
(like for example TEN-E) do you consider
indispensable and why?
 EUU, Alm.del - 2015-16 - Bilag 496: Notat samt høringssvar vedrørende strømlining af planlægning og rapportering som en del af forvaltningssystemet for Energiunionen
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Which other reporting obligations in the field of
energy, including on security of supply infrastructure
and market integration, do you consider indispensable
and why?
1) Wholesale price convergence: Today the national energy regulators report on the wholesale price convergence to
ACER. The convergence of wholesale electricity prices can be regarded as an indicator of market integration and the
free flow of electricity between price zones. Price difference indicates bottlenecks, but the optimal level of market
integration does not necessarily require full price convergence. It is a simple indicator that can show the degree of
market coupling. However, it is difficult to set a target for actual convergence, since an optimal level of market
integration does not necessarily require full price convergence.
2) Share of electricity traded on the day-ahead and intraday market measured in relation to gross consumption and
production of electricity. Today, the national energy regulators collect this information. It will be a useful indicator in
a European governance system for transparency, competition and market coupling.
3) Bottlenecks related to three types of issues: Market integration (between price zones), generation connection,
security of supply. Today ENTSO-E reports this information in their TYNDP reports. The information is
important as it identifies where new interconnections need to be built or reinforced on a European level.
Furthermore, the information is illustrative in order to show where more regional cooperation would be beneficial.
4) Probabilistic approach for power adequacy assessments
Power adequacy could be an important indicator on security of supply. The power system adequacy should be based
on a probabilistic approach as this provides a more accurate picture of the probability of having sufficient power to
satisfy consumption. A probabilistic model ensures that the intermittent nature of wind and solar based production,
small-scale hydro, small and large power plants, combined heat and power, demand side response, transmission lines
as well as interconnectors are represented in the calculation in a manner that more accurately reflects their
contribution to capacity adequacy. A probabilistic method would also make it easier to analyse the potential for more
shared security of supply across borders. And finally, a probabilistic approach would provide more correct decisions
on new investments to improve security of supply.
The European governance system should define a set of common indicators to evaluate system adequacy based on a
probabilistic approach. This will enable a more accurate comparison of system adequacy across Member States. The
indicators should reflect the potential capacity shortage after all market instruments (spot, intraday, balancing market)
has been applied. The indicators could be Loss of Load Probability (LOLP) and Expected Unserved Energy (EUE).
Investments in R&I is the most indispensable element. Reporting on R&I funding is done on an annual basis to the
IEA and has been done so consistently since 2002. The IEA database is to a wide extent useful however there are no
mechanisms to ensure that countries report to the IEA.
Information on funding programmes could be a useful additional indicator.
19
Which elements of the current reporting obligations in
the field of energy research and innovation do you
consider indispensable (investments in R&I, R&I
funding programmes and projects and direct funding
to institutions) and which information is publicly
available or reported to other organisations? How can
this reporting be made more consistent between
Member States and more updated so that it can
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support more transnational cooperation in this field?
Can you provide qualitative or quantitative evidence
on the administrative burden imposed by existing
reporting obligations on both Member States and other
stakeholders?
SE SEPARAT DOKUMENT
Do you agree that a comprehensive new legislative act
covering both planning and reporting obligations of
policy areas related to the Energy Union including the
2030 Energy and Climate framework would ensure
consistency and reduce unnecessary administrative
burden?
Do you think that non-legislative approaches (e.g.
guidance to Member States) can assure effective and
efficient streamlining of planning and reporting
obligations and would provide the necessary certainty
for investors?
SE SEPARAT DOKUMENT
In your view, what should be the nature of the
initiative to best streamline the planning and reporting
obligations in the framework of the governance of the
Energy Union?
If other, please elaborate
No clear picture exists on the administrative burden of the current planning and reporting obligations, but as a
matter of principle, a lower administrative burden is always a priority.
21
22
Yes: X
No:
No opinion:
23
Yes:
No: X
No opinion:
24-
26
27
-
-
-
Non-binding guidance for both planning and reporting obligations covering all Energy Union dimensions [ ]
Regulating planning and reporting obligations in sectorial legislation as currently the case: [ ]
Regulating both planning and reporting obligations by a new comprehensive legislative act covering all Energy Union
dimensions:
[X]
28
Please elaborate on the reasons justifying your choice
in the previous question:
Denmark supports a streamlining of the current planning and reporting obligations with the aim of creating a
common framework for measuring progress towards common energy and climate objectives. Such a common
framework should cover the five dimensions of the Energy Union: supply security, a fully Integrated internal energy
market, energy efficiency, climate action and research & innovation.
The purpose of a new framework should be multiple: to facilitate a better overview of progress towards the five
dimensions, to ensure that Member States comply with obligations, and to bring down administrative costs. A
number of the existing planning and reporting obligations are mandatory for Member States and to the extent these
are replaced by other obligations as part of the national plans, these should be mandatory too.
Variation with regard to the mandatory nature of planning and reporting could be allowed. E.g. measures that are not
mandatory to report on today should not necessarily become mandatory as part of the national plans.
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SE SEPARAT DOKUMENT
 EUU, Alm.del - 2015-16 - Bilag 496: Notat samt høringssvar vedrørende strømlining af planlægning og rapportering som en del af forvaltningssystemet for Energiunionen
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30a
Building further on your replies to the sections devoted
to the existing planning and reporting obligations
(questions 1-21), which of the areas/articles subject to
current planning obligations should be included in the
integrated National Energy and Climate Plans? Please
explain.
Building further on your replies to the sections devoted
to the existing planning and reporting obligations
(questions 1-21), which of the areas/articles subject to
current reporting obligations should also be included
in the integrated National Energy and Climate Plans?
Please explain.
Are there current planning obligations that should
continue to be treated separately?
What political process would be necessary to ensure
the stability of the National Energy and Climate Plans
(e.g. approval by national governments, cross-party
approval, approval by national parliaments, or national
legislative acts)?
What, in your opinion, would be the main factors that
could justify an update of the National Energy and
Climate Plans in the period from 2021 to 2030 (e.g.
energy market developments, economic changes,
evolving EU legislation, or collective progress made
towards the Energy Union objectives)?
SE SEPARAT DOKUMENT
This has been addressed in previous answers.
30b
This has been addressed in previous answers.
30c
31
No answer.
The political process will to a large extent depend on the final design and content of the national plans. With
reference to question 31, 33 and 34 it is likely that national administration and the Commission will play a big part in
the administration of planning and reporting.
Regular updates of the National Energy and Climate Plans are required at given intervals, due to technology
development, changes in prices, and other circumstances.
32
33-
37
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