Energi- Forsynings- og Klimaudvalget 2017-18
EFK Alm.del Bilag 197
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Public consultation on the Establishment of the Innovation Fund
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Public Consultation on the Establishment of the Innovation Fund
The EU emissions trading system (ETS) after 2020 (https://ec.europa.eu/clima/policies/ets/revision_en) foresees the
establishment of the Innovation Fund to accelerate the commercialisation of low-carbon technologies. 400 million allowances will be
reserved from 2021 onwards for this purpose. In addition, a further 50 million of unallocated allowances from 2013-2020 will be
added, together with, as early as 2019; any possible un-used or remaining funds from the NER 300 Programme
(https://ec.europa.eu/clima/policies/lowcarbon/ner300_en). Further 50 million allowances could be added to the fund post 2025, if
these are not used for free allocation to industry.
Contact
Caroline-
[email protected]
(mailto:Caroline-
[email protected]
)
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The Fund will support innovation in low-carbon technologies, processes and products in industrial sectors listed in Annex I of the
EU ETS Directive. The Fund should stimulate the construction and operation of projects that aim at the environmentally safe
capture, use of CO2 (CCU) and its geological storage (CCS), as well as innovative renewable energy and energy storage
technologies in the territory of the European Union. Technologies receiving support should not be commercially available yet, but
shall be sufficiently mature to be ready for demonstration at pre-commercial scale.
Last saved on
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Furthermore, the ETS Directive sets a number of key features of the Innovation Fund:
1. Up to 60% of the relevant costs of projects may be supported,
2. Project selection will be done based on objective and transparent criteria, including, among others, the potential for emission
reductions, potential for wide application or significant lowering of transitioning costs towards a low-carbon economy in the
concerned sectors,
3. Technologies to be supported are not yet commercially available, but represent breakthrough solutions or are sufficiently
mature to be ready for demonstration at pre-commercial scale,
4. Up to 40% of the Innovation Fund's support for eligible projects (that is up to 24% of projects' relevant costs) may be pre-
financed (may not depend on achieved reduction of greenhouse gas (GHG) emissions) provided that pre-determined project
milestones are met,
5. Projects in all Member States, including small-scale projects, are eligible to apply.
During the first half of 2017, the European Commission hosted a series of stakeholder consultations with representatives from
energy-intensive industries, the energy and finance sectors. The resulting summary report
(https://ec.europa.eu/clima/events/articles/0115_en) points to over 80 potential technologies, including cross-cutting innovations,
such as CCUS, green hydrogen or energy storage.
This public consultation will gather the views of the wider public on additional, more detailed, design elements of the
Innovation Fund, as an input to the Impact Assessment accompanying the Commission's proposal for a delegated act.
The questionnaire is divided into 6 sections. Section 1 relates to the identification of the respondent and is obligatory for all
respondents. The following multiple choice questions in Sections 2-5 relate to key elements identified in the Inception Impact
Assessment (https://ec.europa.eu/info/law/better-regulation/initiatives/ares-2017-3157624_en) for the Establishment of the
Innovation Fund. An open question at the end of each Section allows complementing any of the previous answers. Section 6 allows
providing additional comments and uploading supporting documents.
A short summary of the key design elements and the related problems identified is provided at the beginning of each section.
General information about respondent
* 1. In what capacity are you completing this questionnaire?
In your professional capacity or on behalf of an organisation
* 2. Please indicate your First name :
Text of 3 to 200 characters will be accepted
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* 4. Please indicate the name of your company, organisation, or institution (if your organisation is registered in the
Transparency Register, please give your Register ID number) :
Text of 3 to 200 characters will be accepted
Danish Ministry of Energy, Utilities and Climate
If your organisation is not registered, you can register now (http://ec.europa.eu/transparencyregister/public/ri/registering.do?
locale=en#en). Please note that contributions from respondents who choose not to register will be processed as a separate
category 'non-registered organisations/business'.
5. Contact email address:
The information you provide here is for administrative purposes only and will not be published
@
* 6. For individuals, please indicate your country of residence, for professionals, please indicate your main country of
operations/headquarters :
* 7. Please indicate the type of organisation (please select the option that fits the best) :
Private enterprise
Professional consultancy, law firm, self-employed consultant
Trade, business or professional association
Non-governmental organisation, platform or network
Research and academia
Social partners
National, regional or local authority (mixed)
Other
* 8. Please indicate the size of your company, organisation or institution :
a) Micro or small enterprise (10-49 persons employed)
b) Medium-sized enterprise (50-249 persons employed)
c) Large enterprise (250 or more persons employed)
* 9. To which category of stakeholders does your organisation belong?
a) Potentially directly benefiting from the initiative (energy intensive industries, in particular steel, iron, aluminium, copper,
oil refining, chemicals & bio-based industries and pulp & paper, cement, lime, glass & ceramics, renewable energy
generation and storage, and industries/power plants utilising CCS/CCU
b)Indirectly benefiting from the Initiative (EU/National Industry associations, Environmental NGOs, National/Regional
authorities and EU institutions; European Investment Bank/international or national financial institutions; Member States)
c) Other
* 10. Please indicate your preference for the publication of your response on the Commission's website:
(Please note
that regardless of the option chosen, your contribution may be subject to a request for access to documents under Regulation
1049/2001 (http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32001R1049) on public access to European Parliament,
Council and Commission documents. In this case the request will be assessed against the conditions set out in the Regulation
and in accordance with applicable data protection rules (http://ec.europa.eu/justice/data-protection/).)
Under the name given:
I consent to publication of all information in my contribution and I declare that none of it is subject to copyright restrictions
that prevent publication
Anonymously:
I consent to publication of all information in my contribution and I declare that none of it is subject to copyright restrictions
that prevent publication
Eligibility criteria
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will support deployment of innovative renewable
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energy technologies and industrial break-through innovation
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Annex 1 to the ETS Directive, concretely: ferrous metals, non-ferrous metals, cement and lime, glass and ceramics, chemicals, oil
refining, pulp and paper, including potential application of environmentally safe CCU technologies in these industries, that would
substantially contribute to climate change mitigation. The renewable energy sectors to be covered comprise innovative production
from: wind, ocean, geothermal, biomass and solar sources. In addition, energy storage and CCS are also eligible.
The Innovation fund will be designed to help innovative projects to cross the "valley of death" and reach commercial viability.
Eligible projects should contribute substantially to climate change mitigation through a significant reduction of GHG emissions.
11. Which are the five most important highly innovative technologies in your view that will be key to decarbonise the
industry and power sectors in the EU and therefore need to be demonstrated over the coming decade?
Text of 3 to 1000 characters will be accepted
-New and more cost effective technologies within off-shore wind - ex. foundations.
- Power-to-X and carbon mobilization technologies to integrate large amounts of wind and
solar electricity into the overall energy system - e.g. Power-to-Gas and Power-to-Liquid
(Electro Fuels).
- Energy storage technologies.
- Smart Energy concepts to balance energy production and end use at all levels.
- Energy efficiency solutions for buildings and industry.
Please specify for your own sector (as indicated in the introduction above). Cross-sector technologies can also be included, if
relevant.:
Text of 3 to 200 characters will be accepted
N/A
12. To apply to the Innovation Fund funding, should eligible technologies be defined?
a) Yes: Based on a pre-defined detailed list of eligible technologies per sector (as described in the introduction above),
with a possibility of regular update (e.g. every 5 years);
b) No: Eligible technologies should not be pre-defined allowing for competition between projects and across sectors
c) Other
13. To ensure that the Innovation Fund would support innovative but realistic projects (i.e. those that would effectively
materialize and reach market maturity), should its eligibility criteria set deadlines for reaching specified milestones?
Yes
No
*
If yes, should these deadlines related to
:
a) Investment process (such as a signature of Financial Close documents)
b) Construction steps (such as commissioning of the construction)
c) other
14.The revised ETS Directive agreement stipulates that small-scale projects can also be supported. To better define
the scale of small-scale projects eligible for support of the Innovation Fund, should eligibility criteria set a minimum
size for small-scale projects?
a)Yes
b) No
*
If yes, what would be the appropriate minimum size (in terms of total capital expenditure in EUR) in your area of expertise, which
would allow funding of small-scale projects at EU-level? :
Text of 3 to 200 characters will be accepted
N/A
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please provide additional comment(s) in more detail, focusing on elements related to eligibility criteria
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not mentioned in the answers above.
Text of 3 to 500 characters will be accepted
The Fund should select a bottom-up approach for applications and not restrict projects
based on a predetermined list of Technologies, as innovation is technology neutral within
determined low-carbon pathways or higher-level technology corridors. A Pick-the-Winner
approach should be avoided in order to select the best projects.
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Type of support
The ETS Directive states that the Innovation Fund can provide support of up to 60% of the relevant costs of selected projects, out
of which up to 40% may be pre-financed, provided that pre-determined milestones are attained. The majority of the Innovation Fund
support (at least 60%) should be provided on the basis of verified (achieved) reduction of greenhouse gas (GHG) emissions, once
projects are operational.
The Directive leaves room for modulation of maximum support rate (up to 60% of relevant costs) according to the project's
technology risks, providing various forms of financial support such as grants, loans or equity, but also for covering specific type of
costs (such as project development assistance along with the capital expenditure). This section therefore aims at collecting your
views on the type of support the Innovation Fund should offer.
16. Should the maximum funding rate (i.e. up to 60% of relevant costs covered by the Innovation Fund as stipulated
above) be:
a) Variable depending on the stage of technology development (and related technology risks)
b) Variable, based on a different approach, please specify
c) The same for all eligible projects
17. Which form(s) of support should the Innovation Fund provide?
17.1 Which form of support do you consider most appropriate in relation to the stage of development? Please rank from 1-5 (5 being most
appropriate).
Pilot production and demonstration (TRL* 6-7)
Investment subsidies (grants)
Risk guarantees
Loans
Equity
Other (specify)
Initial market introduction (TRL 8) Market expansion (TRL9)
5
3
4
2
1
5
3
4
2
1
5
3
4
2
1
*TRL means Technology Readiness Level
http://ec.europa.eu/research/participants/data/ref/h2020/other/wp/2016_2017/annexes/h2020-wp1617-annex-g-trl_en.pdf
17.2 Should eligible projects have a possibility to combine the above forms of support during the projects' lifecycle? Please specify and provide
more detailed explanation for your answer above.
Text of 3 to 500 characters will be accepted
For lower TRL levels grants are considered to be far the most suitable financial
instrument, as they provide the strongest incentive to promote private investments.
17.3 Should the Innovation Fund also provide specific project development assistance? If so, please rank the relevance, according to your
assessment, of pre-feasibility studies, cost-benefit analyses and related work-streams, human capacity building and others (4 being most
important):
Technical pre-feasibility studies
Financial analysis and plans
Capacity building
Others
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the Innovation Fund support may be
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pre-financed, provided that pre-determined milestones are
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a) According to the investment process (i.e. project launch, financial close, commissioning, operation);
b) Linked to specific construction phases (i.e. first procurement for plant parts signed, physical construction finalised,
operation);
c) Other
19. What are in your view the most important lessons learned from the monetisation of NER300 allowances / key aspects
to be considered when deciding about the modalities, in particular the timing, of monetising the allowances available for
the Innovation Fund?
Text of 3 to 1000 characters will be accepted
Monetisation should be balanced in order to ensure that the market balance is not
disturbed. Additionally, monetisation should consider the timing of project selection, as
this would likely not happen at the very beginning of the Fund's operation.
20. If you wish, please provide additional comment(s) in more detail focusing on elements related to the type of support
criteria not mentioned in the answers above.
Text of 3 to 1000 characters will be accepted
We find that a support scheme based on grants (non repayable support) will be the
strongest instrument to promote the scope of the Fund. Hence we recommend that the
grant option should be integrated to the greatest possible extent in a mixed set-up of
different financial instruments to be effective under the Fund.
Application and Selection procedure
According to the ETS Directive on the selection procedure, "Projects shall be selected on the basis of objective and transparent
criteria." In addition, projects should deliver material GHG emissions reductions, well below the ETS benchmarks (where
applicable), and have potential for wide application and lowering the costs of transitioning towards a low carbon economy for the
sectors covered.
21. How should the application process be organized?
a) on a first-come, first-served basis
b) through regular calls, at pre-defined dates
c) other
22. How many stages should the application process have?
a) a single-stage application process, requiring applicants to submit the full project documentation by a given deadline
b) two-stage process consisting of expression of interest (based on a less than 10 page concept note) followed by the
screening of pre-selected applications (based on complete project proposals)
c) Other
23. What should be the optimal mix of project selection criteria, taking into account the key requirements set by the ETS
directive? Please rank in the order of importance (0 being least important).
Ranking (0 - 6)
Innovativeness
2
Comments (if non put N/A)
N/A
N/A
N/A
Decarbonisation potential / contribution to emission reductions
6
Expected performance (i.e. Cost per unit of performance)
3
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1
4
0
N/A
N/A
N/A
Scalability/ potential for widespread application
Other, please specify
24. Should there be a mechanism to ensure a balanced portfolio of projects?
a) yes, with regard to sectors
b) yes, with regard to technologies
c) yes, with regard to sectors and technologies
d) No
*
If yes, please provide suggestions on how this should be done.
Text of 3 to 200 characters will be accepted
N/A
25. If you wish, please provide additional comment(s) in more detail focusing on elements related to the selection
procedure not mentioned in the answers above.
Text of 3 to 500 characters will be accepted
There should be a balanced portfolio of projects across both early innovation and more
mature technologies.
Relation to the Other Funding Instruments
26. In your view, how should the Innovation Fund complement other funding mechanisms at the EU and national level?
Such mechanisms are the for example EU Framework programme for research and innovation (Horizon 2020), European Structural
and Investment Funds (e.g. ERDF) or Research fund for coal and steel).
Please specify.
1000 character(s) maximum
[EFKM´s departement repræsenterer DK i Horizon 2020-sammenhæng - her kan
departementet således også bidrage - ligeledes har departementet adgang til oplysninger
om ERDF fra andet ressortministerium]
The Fund should bridge the gap between the precommercial stage af technologies that
will be the result of national R&D programmes and the market by supporting larger scale
investments. This is the key funding gap.
27. In your view, could the Innovation Fund avoid overlaps with other funding instruments and if so, how this should be
done?
1000 character(s) maximum
The relationship of the Fund with complementary EU funds such as the H2020, the
InnovFin, CEF and more should be clear so that the use of applicant and reviewer time is
optimised.
28. In your view, how unnecessary administrative burden for applicants could be avoided? Please specify.
1000 character(s) maximum
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concept presentation and stage 2 a far more detailed project and financial description that
allows an in-depth technical and business due diligence.
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29. If you wish, please provide additional comment(s) in more detail focusing on elements related to financing synergies
not mentioned in the answers above.
1000 character(s) maximum
N/A
Final comments
30. If you wish to add further information, comments or suggestions - within the scope of this questionnaire - please feel
free to do so here:
1000 character(s) maximum
N/A
In addition, you could also upload a document proving further information, comments or suggestions.
Please note that the uploaded document will be published alongside your response to the questionnaire which is the essential input to this open public consultation. The document is an optional
complement and serves as additional background reading to better understand your position
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