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<A name=1></a> <br>
<b> </b><br>
Foundation 2° - Response to EC consultation <br>
„A 2030 framework for climate and energy policies“ <br>
<b> </b><br>
<b> </b><br>
<b> <br>Response to the European Commission’s consultation on <br>a 2030 framework for climate and energy policies <br></b> <br><b> <br> <br> <br> <br> <br> <br>Stiftung 2 Grad / Foundation 2 Degrees <br></b>German CEOs for climate protection <br>Linienstraße 139/140
 <br>Aufgang B, 5. OG
 <br>10115 Berlin <br>Transparency Register ID number 539593110251-28 <br> <br><b> <br> <br> <br> <br> </b><br>
<b> </b><br>
<br> <br> <br> <br> <br> <br> <br>Through the Foundation 2°, German CEOs show their long-term commitment to <br>climate protection. We welcome the green paper on a 2030 energy and climate policy <br>framework, as it opens a debate on the transition to a low-carbon economy. Targets <br>for 2030 are necessary – but a vision beyond that date already needs to be sketched <br>if we are to achieve the EU’s ambition to cut its greenhouse gas emissions by 80-<br>95% by 2050. Without such a cut, avoiding an average global warming of over 2° <br>would no longer realistically be within reach. <br> <br> <br> <br><b> <br> <br> <br> <br> <br> <br> </b><br>
<br>
<hr>
<A name=2></a> <br>
<b> </b><br>
Foundation 2° - Response to EC consultation <br>
„A 2030 framework for climate and energy policies“ <br>
<b> </b><br>
<b> </b><br>
<b>Which lessons from the 2020 framework and the present state of the EU energy <br>system are most important when designing policies for 2030? <br></b> <br>The 2020 framework set three key targets: reducing GHG emissions by 20% <br>compared to 1990 levels; boosting the share of renewable energy sources to 20% of <br>the overall EU energy mix, and cutting overall energy consumption by 20% in <br>comparison with 2005 projections - all this by 2020. These targets should serve to cut <br>the EU’s GHG emissions as part of an international effort to tackle climate change, <br>secure energy supply and support growth, competitiveness and jobs. <br> <br>As the Commission starts working on a climate and energy framework for 2020-2030, <br>the 8 years lapsed since the adoption of the 2020 package allow us to draw lessons. <br> <br>
- Long-term predictability is crucial for investments <br>
Large investment decisions are made with decades in mind for the calculations of <br>returns. Such heavy investment decisions, e.g. in infrastructure, will only be met <br>today if there is sufficient trust in the stability of the policy framework – which calls for <br>consistency over time. In addition, such decisions can have an impact on the climate <br>well beyond 2030, for instance when it comes to the building sector. A stable policy <br>framework is central to foster a positive investment climate. More bluntly said, as <br>long as the policy framework is uncertain, investment simply doesn’t materialise. <br><b>We call on the EU to look beyond 2030 and set itself binding climate and <br>energy targets for 2040 and 2050 to that end. <br></b> <br>
- Market-based mechanisms are the most cost-efficient way to organise the <br>
EU’s climate and energy framework, but are disserved by blind adherence to a <br>non-intervention principle. <br>
The EU’s flagship climate policy, the ETS, has succeeded in cutting GHG emissions <br>to date – but it has failed to incentivise the transition to a low-carbon economy. <br>Worse, the current surplus of almost 2 billion allowances on the market has caused <br>their price to plummet to around 10% of the level predicted when the policy was <br>designed. This price level is so low that it encourages investments locking us in a <br>high-carbon economy. For instance, building coal-fired power plants currently makes <br>more sense than switching to gas. <br> <br>The Foundation 2° supports the use of market-based mechanisms to organise <br>climate protection, as they leave the private sector much more freedom than <br>regulation and are a cost-efficient way of incentivising climate-friendly solutions. <b>But <br>we are extremely concerned that non-intervention is depriving the ETS of any <br>sense and driving us fast towards a point where national government impose <br>national frameworks</b>. Letting the only market-based climate policy instrument fail <br>sets a dangerous precedent of showing that only regulation can achieve goals in this <br>field. The costs of complying with a patchwork of climate policies will bear no relation <br>to that of saving the ETS. Before free-market principles can be applied, functioning <br>markets are needed. <br><b> <br>We call on the European institutions and national governments to address the <br>surplus of allowances on the market in order to allow it to fulfil its double <br>function – cutting GHG emissions and incentivising a transition to a low-<br>carbon economy. </b><br>
<br>
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<A name=3></a> <br>
<b> </b><br>
Foundation 2° - Response to EC consultation <br>
„A 2030 framework for climate and energy policies“ <br>
<b> </b><br>
<b> </b><br>
<br>
- Binding targets are more effective than indicative ones <br>
The Commission’s own assessment of the three headlines 2020 targets is that the <br>GHG reduction target will be surpassed; that the renewables energy target may still <br>be met; but that the energy efficiency one, which was initially given no constraining <br>legislative framework and had to wait until 2012 to see a binding legal instrument to <br>organise it, will be missed. <br> <br>
- Conditional targets are not effective. <br>
Implementing an ambitious climate and energy policy cannot sustainably happen in a <br>vacuum. Although the EU’s historic responsibility for climate change means it must <br>also carry more of the efforts to tackle it, it is currently only responsible for 8 to 10% <br>of the world’s GHG emissions. Therefore, its efforts to tackle climate change need to <br>convince and inspire others to also move towards a low-carbon economy. Coalitions <br>are needed at international level to tackle climate change. EU efforts alone simply <br>cannot have enough of an impact on climate change. <br> <br>What has unequivocally failed to convince others is conditionality in climate targets. <br>The EU’s pledge to cut its emissions by 30% by 2020 if other major economies made <br>similar efforts did not convince others to step up their efforts. <br> <br>What has inspired others, however, are green technologies and sustainable jobs; <br>similarly, innovative climate policy frameworks such as emissions trading are now <br>also being replicated beyond EU borders. Climate and energy frameworks which <br>incentivise low-carbon technologies and reward sustainable solutions and energy <br>efficiency, are a surer way of adressing climate change than conditional <br>commitments. <br><b> <br>We call on the EU to unconditionally commit to a high level of ambition. <br></b> <br><b>Targets <br></b>Which targets for 2030 would be most effective in driving the objectives of climate <br>and energy policy? <br>Past experience shows that binding and unconditional targets are the most effective <br>at delivering results. <br> <br>The Foundation 2° supports the three pillars of the EU climate and energy package. <br>We believe that streamlined energy consumption, sustainable energy production and <br>lower GHG emissions are all necessary to limit average global warming to 2°, a <br>threshhold over which adaptation costs would create untold human misery, <br>undermine political stability and cripple the economy. <br> <br>We call for policymakers to endorse the following targets – and make <b>them binding, <br>unconditional and domestic</b>: <br> <br>
- <b>a 45-55% reduction of GHG emissions in comparison with 1990 by 2030; </b><br>
<b>and 65-75% by 2040. </b>These are necessary to maintain the possibility of <br>achieving the higher end of the EU’s 80-95% decarbonisation target range by <br>2050 – without which the 2° limit is likely to be overtaken, as explained by the <br>IEA and the World Bank. The Foundation 2° believes that a tightened up ETS <br>
<br>
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<A name=4></a> <br>
<b> </b><br>
Foundation 2° - Response to EC consultation <br>
„A 2030 framework for climate and energy policies“ <br>
<b> </b><br>
<b> </b><br>
will be the most cost-effective way of achieving these reductions, and calls on <br>the Commission to urgently propose a structural reform addressing the surplus <br>of allowances. <br>
80<br>
70<br>
60<br>
50<br>
40<br>
30<br>
20<br>
10<br>
0<br>
2020<br>
2030<br>
2040<br>
2050<br>
Lower ambition course<br>
Higher ambition course<br>
Commission<br>
<br>
<br>
- <b>a binding and ambitious target for the share of RES in the EU energy mix </b><br>
<b>by 2030</b> is needed to ensure that the current take-up of RES continues. <br>Targets (declined into national targets reflecting the different capacities of <br>various member states) are also needed for 2040 and 2050. <br>Cutting renewables subsidies in Spain has led to a complete collapse of the <br>market there, despite the obvious potential of e.g. photovoltaic. To avoid a <br>similar effect across the EU, long-term political commitment to sustainable <br>heat and power production needs to be reaffirmed beyond 2020. <br>The benefits of boosting sustainable and domestic energy production in times <br>of growing imports dependency and rising energy prices cannot be overstated <br>for security of supply and economic development as well as to fight climate <br>change. <br>
- <b>a minimum 30% target in energy efficiency</b> to take into account the short <br>
timeframe between the implementation of the energy efficiency directive and <br>the adoption of the 2030 framework. Significantly more ambitious figures are <br>needed for 2040 and 2050. The Foundation 2° prefers binding targets to <br>binding measures that restrain entrepreneurs’ freedom. <br> <br>
Flexibility is needed to accomodate economic and technological developments, so <br>that setting 2030, 2040 and 2050 targets may appear cumbersome and risksy. <br>However, the current lack of predictability of the EU’s overarching goals in energy <br>and climate policy urgently needs to be addressed, as it hinders and delays <br>necessary investment. <br> <br>We look forward to continuing our dialogue with policymakers to define the <br>instruments necessary to achieve the objectives set out above. <br> <br>
<br>
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<A name=5></a> <br>
<b> </b><br>
Foundation 2° - Response to EC consultation <br>
„A 2030 framework for climate and energy policies“ <br>
<b> </b><br>
<b> </b><br>
<br><b> <br> <br> <br>Contact details: <br></b>Sophie Heitz <br>Climate Policy Officer <br>Stiftung 2 grad/ Foundation 2 degrees <br>sophie.heitz@2grad.org <br>+49 (0)30 2021 4320 <br>www.stiftung2grad.org <br> <br>
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<A name=1></a>3M (Europe) <br>Hermeslaan 7 <br>B – 1831 Diegem (Brussels) <br>Belgium <br>Contact: Maxime Bureau <br>mbureau@mmm.com <br>ID in TR: 91425447458-88 <br>
<b> </b><br>
<b>3M Response to the EC Public Consultation </b><br>
<b>on a 2030 framework for climate and energy policies </b><br>
<b> </b><br>
General <br>
3M is a global technology company with nearly 20,000 people in Europe as well as more than 50 <br>manufacturing sites and 18 research &amp; development centers in this key region for the company. 3M has <br>a diversified portfolio of innovative solutions in healthcare, energy, water, transportation, security and <br>communications. In particular, 3M develops sustainable alternatives in the areas of power generation, <br>transmission and distribution, e-Mobility, energy storage, smart buildings, and ICT. <br>
In discussing the future EU climate and energy policy, 3M believes it is critical that its objectives are <br>clearly identified and well understood. Binding targets, e.g. for energy efficiency and renewable <br>energies, as well as instruments such as the EU Emissions Trading Scheme (EU ETS) closely aligned with <br>other climate policies should be the key components of any post-2020 Climate and Energy framework. <br>
A long-term and predictable policy environment is key for companies to be successful in Europe and will <br>restore confidence in the region. In order to achieve the EU’s emission reduction objectives and to <br>stimulate low carbon investments, there should be continuous targeted support and public funding <br>focused on research and development (R&amp;D) of low-carbon technologies. In this respect 3M would like <br>to see more coherence between EU level objectives and national support schemes, as well as better <br>implementation of EU legislation at national levels. <br>
Last but not least, there should be a global approach to reducing greenhouse gas (GHG) emissions. In <br>this respect the EU should strengthen its efforts to convince other major countries to commit to <br>ambitious GHG reduction targets. To this end 3M supports the on-going United Nations Framework <br>Convention on Climate Change (UNFCCC) negotiations aimed at reaching an international agreement by <br>2015 and will engage with stakeholders at the upcoming COP-19 meeting in Warsaw this November. <br> <br>
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<A name=2></a>3M (Europe) <br>Hermeslaan 7 <br>B – 1831 Diegem (Brussels) <br>Belgium <br>Contact: Maxime Bureau <br>mbureau@mmm.com <br>ID in TR: 91425447458-88 <br>
<br>
<i>Which lessons from the 2020 framework and the present state of the EU energy system are most <br>important when designing policies for 2030? </i><br>
<i>Energy Efficiency </i><br>
The EU is not capturing the vast potential for energy savings and efficiency in many sectors, particularly <br>in the buildings sector and on the supply-side that include power generation, transmission and <br>distribution. 3M believes the economic potential of energy savings and efficiency in EU Member states <br>should be a bigger political priority and more should be done to ensure its implementation through <br>national allocation plans. This would create local jobs, savings in public budgets and reduce energy <br>import dependency. <br>
The EU needs to properly calculate the long-term risk and missed opportunities from not focusing on <br>energy efficiency. Progress towards 20% target has been limited, due to low prioritization by Member <br>states. This is especially seen in the building sector, which accounts for 41% of Europe's energy <br>consumption. Studies indicate that the deep renovation of Europe's existing building stock can bring up <br>to a 32% saving of the total primary energy used in Europe and there are many already existing <br>sustainable solutions, such as window films, which can significantly increase the energy performance of <br>buildings through solar heat absorption and reduced heat loss. 3M would like to encourage the EU and <br>Member states to recognize that the environmental effects of cooling can be at least as significant as <br>those of heating and should be included in guidelines related to energy saving to help targets to be met. <br>
<i>Renewable Energy (RES) </i><br>
The 2020 climate and energy framework, including its binding renewable energy targets, has provided <br>the energy sector with the necessary stability and predictability. The EU should continue those policies, <br>which have proven to be successful in ensuring the market deployment of RES technologies and large-<br>scale cost decrease. In order to expand the use of wind and solar power in the grid, it is essential to <br>increase the current capacity of electricity storage facilities and develop systems to deal with excess <br>power created due to weather conditions, but not needed immediately. <br>
To increase the amount of renewable energy power used in the network, it must be effectively <br>transmitted and distributed. The expansion of small distribution systems is essential and regional <br>utilities need to invest in new power plants, photovoltaic energy sources and wind turbines to integrate <br>these into the network. It is essential to ensure the further development of energy infrastructure, along <br>with more consistency and coherence between EU level objectives and national support schemes. <br>
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<A name=3></a>3M (Europe) <br>Hermeslaan 7 <br>B – 1831 Diegem (Brussels) <br>Belgium <br>Contact: Maxime Bureau <br>mbureau@mmm.com <br>ID in TR: 91425447458-88 <br> <br>
Apart from the construction of new power lines or retrofitting of existing ones, Smart Grids are needed <br>to provide the missing link enabling the intelligent networking of producers and consumers. These <br>modern power networks will bring reliable renewable energy to customers. Consumption in households <br>and businesses can then be adapted to optimize the most convenient times and network loads. Keys are <br>to ensure reliable production of electricity, enhance the existing utility grid, improve the efficiency of <br>the power network, make homes and businesses more energy efficient and reduce emissions. <br>
Targets <br>
EU level targets are essential, as they send a broad strategic message and encourage investors to take <br>advantage of the single market’s economies of scale. To be most effective, targets must be set for a long <br>timeframe, be simple, clear and binding in order to be implemented. Consistent with the long-term 2050 <br>objectives of the 80-95 % CO2 reduction target, <b>3M supports an ambitious economy-wide GHG <br>reduction target for 2030</b>, together with energy efficiency and RES being recognized as key policies to <br>be promoted. Apart from extensive CO2 reduction levels, the EU should also focus on phasing-out other <br>highly potent GHG emissions, such as F-gases, for example. <br>
<b>Future climate and energy policies should continue on the basis of a three-target approach</b>. However, <br>in order to avoid any potential discrepancies between them, as well as to encourage synergies, the EU <br>should ensure that all three targets are set at the right level of ambition and opt for in-built safety <br>measures, in order to ensure their coherence. <br>
EU targets could be broken down at national level to provide Member states with some flexibility on the <br>strategy to reach the set targets and ensure their legal responsibility. There should also be more <br>coordination between the EU and Member states vis-a-vis implementation. Lack of coordination at EU <br>and Member state level have in some cases led to support schemes which have not been cost-efficient, <br>raised the financial burden on consumers and affected competitiveness. <br>
Specific efforts should be made with respect to the transport sector, still a growing source of GHGs. In <br>the White paper on Transport published in 2011 the Commission called for a reduction of at least 60% of <br>GHGs in the Transport sector by 2050 (20% by 2030). In order to build a competitive and clean transport <br>system for the next decade, the climate and energy framework should include also aspects of <br>electrification of the transport (especially automotive) sector and promote further environmentally-<br>friendly and efficient solutions in reaching the GHG (CO2 reduction) target. <br>
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<A name=4></a>3M (Europe) <br>Hermeslaan 7 <br>B – 1831 Diegem (Brussels) <br>Belgium <br>Contact: Maxime Bureau <br>mbureau@mmm.com <br>ID in TR: 91425447458-88 <br> <br>
Instruments <br>
The EU Emissions Trading System (ETS) is the flagship policy in the EU’s climate and energy framework <br>which is now being imitated by other international players (e.g. China, Australia). In order for it to <br>remain the key instrument of ensuring emission reductions at the lowest cost to the economy, it should <br>be revised in light with the post-2020 EU policy objectives. Structural reform measures are needed for <br>the EU ETS to be able to take into account unforeseen (economic) developments and to attract further <br>low carbon investments. <br>
At the same time, the EU should also allow for the continuation of other innovative financial <br>instruments and ensure a strong coordination between EU level instruments (such as EU ETS) and <br>national support schemes (such as feed-in tariffs). Any instruments should be brought in line with the <br>overall CO2 reduction target.<b> </b><br>
EU climate and energy policy in the future should be addressed in conjunction with EU industrial policy <br>and should recognize and support both current and future opportunities for industry to provide low <br>carbon technologies and solutions. To keep its front-runner advantage in developing low carbon <br>technologies on a commercial scale, a real industrial policy would strengthen further local investments. <br>Such a policy should be based on: <br>
o Implementing a transparent and efficient European energy market that provides an <br>
attractive investment climate; <br>
o Ensuring investment security through a stable and favorable policy framework with long-<br>
term 2030 binding targets; <br>
o Setting high standards through qualitative public procurement processes (rules) to leverage <br>
already existing sustainable technologies; <br>
o Simplifying sustainable support schemes, streamlining administrative procedures and <br>
implementing efficient grid connections; <br>
o Using the new energy infrastructure package - notably the Connecting Europe Facility (CEF) <br>
as well as the structural funds to support the realization of the climate and energy targets. <br>
<br>An ambitious Climate and Energy framework for 2030 should be a key driver for R&amp;D and innovation. By <br>2030, Europe needs to have developed, demonstrated and deployed a wide range of low carbon and <br>energy efficient technologies. Programs should not only target research but also demonstration in order <br>to shorten the time to commercialization for the most promising technologies. Main areas of action <br>should also focus on the cost and energy efficiency aspects by promoting the retrofitting solutions, <br>which can upgrade the already existing networks, technologies and products - for example in energy <br>transmission as well as buildings. Financial instruments should be adapted to the 2030 objectives and <br>support the deployment of innovative energy projects. <br>
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Identification number of Alstom in the Transparency Register: 43284012043-03 <br>
June 2013, 13th <br>
<br>
<br>
Alstom’s response to the European Commission’s consultation on the green paper on 2030 framework for <br>
climate and energy policies <br>
<br>
<br>
Alstom is a global equipment and services supplier to the power generation, power transmission and rail transport sectors. <br>Through its innovative technologies, the Group contributes to improving energy efficiency, reducing CO2 emissions and <br>developing renewable sources of energy, in line with the objectives of the EU energy and climate package for 2020 and the <br>White Paper on Transport (2011). <br>
Alstom believes that binding targets, e.g. for renewable energies, and a strong EU Emissions Trading Scheme closely <br>
aligned with other climate policies should be the key components of the 2030 Climate and Energy framework. A robust and <br>
predictable carbon price, together with targeted support to non-yet mature low carbon technologies and public funding <br>
continuously focused on Research, Development and Demonstration (R&amp;DD) of low-carbon technologies and their <br>
deployment, will contribute to achieve the EU’s emissions reduction objectives at the lowest cost and to stimulate low <br>
carbon investments. <br>
Alstom calls for EU to agree 2030 objectives and targets as soon as possible and in any case before the UNFCCC <br>
international climate negotiations to be held in 2015 in Paris (COP 21). This timeliness will ensure the indispensable <br>
visibility needed to trigger the necessary long-term investments in infrastructure (power generation, electricity generation <br>
and transport). <br>
Failure to agree before 2015 will seriously threaten the EU’s negotiation position. Any delay in setting a clear framework <br>
and defining the EU’s energy and climate objectives for the next decade will have negative implications for jobs and growth <br>
and will increase the cost of decarbonisation. Prolonged policy uncertainty will also block investments, It will also <br>
undermine progress towards energy security and our common climate goals, and risks distorting the internal market as <br>
governments might revert to introducing alternative national measures to deliver their own energy and climate policies. <br>
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Therefore, Alstom supports the following “package” to be agreed on as the new 2030 Climate and Energy policy <br>
framework: <br>
<br>
1. An overall economy-wide greenhouse gas (GHG) emissions reduction target of at least <br>
40% (compared to 1990). <br>
2. A tight EU ETS cap reducing emission levels by 2.5% pa (instead of the current to 1.74% trajectory) <br>
ensuring trade-inducing scarcity in the market and reflecting the expected deployment of low-carbon <br>
energy. <br>
3. A renewables target of 35% of total energy consumption, translated into national targets. <br>
4. An EU-wide target for tonnes of CO2 avoided as a result of CCS. <br>
5. A target for the reduction of total CO2 emissions across the transport sector of 20% (compared to <br>
2008). <br>
In addition, Alstom supports a 2030 target or equivalent action on energy efficiency provided it covers the <br>
supply as well as demand side. <br>
<br>
*** <br>
1.<b> </b>Which lessons from the 2020 framework and the present state of the EU energy system are most important <br>
when designing policies for 2030? <br>
<br>
<br>
Legislative certainty is the backbone of long term investment. <br>
Member States should be encouraged to create stable policies leading to the successful implementation of the agreed <br>climate and energy package for 2020 and beyond. <br> <br>
<br>
Binding targets achieve the best result. <br>
With binding national targets, growth in renewable energy (RES) has increased. In 2011, the RES share in the final energy <br>consumption of the EU was 13.0% compared to 8.5% in 2005. To achieve their national targets, Member States have put in <br>place specific support schemes (Feed in Tariffs, Renewable Obligation Certificates), which have further driven the <br>development of RES. <br> <br>In contrast, the absence of binding targets for Carbon Capture and Storage is certainly one of the key reasons for EU <br>seriously lagging behind today on the deployment of this technology, despite the Commission acknowledging the vital role <br>of CCS in each of its 5 scenario developed in the “Roadmap for a low carbon economy in 2050”. <br> <br>The energy efficiency target (20% savings in EU's primary energy consumption compared to projections made in 2007) was <br>not made binding when the Climate and Energy package was agreed on in 2008. According to the Commission1, the <br>Energy Efficiency Directive, only adopted in October 2012 and currently being transposed in national legislation, is <br>expected to allow the EU to approximately reach up to 17% of the 20% energy efficiency for 2020. Other assessments say <br>this number could even be lowered to 13%. The lack of progress on energy efficiency shows the necessity of setting targets <br>which are binding to ensure the successful implementation of Climate and Energy policies. <br>
<br>1 Energy challenges and policy - Commission contribution to the European Council of 22 May 2013 <br>
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The CO2 price on its own is not enough to drive the technology transformation we need <br>
Whilst a robust CO2 price will support low-carbon investments in the long term, other support is needed to get pre-<br>commercial technologies through the “valley of death” and onto the market. CO2 price is avoided costs, not revenue. <br>Crucially, investors need positive incentives and long term visibility in their revenue stream. This is the obstacle which <br>particularly prevents investments in CCS. The Electricity Market Reform in the UK, and the implementation of Contract for <br>Difference/ Feed in Tariffs provide investors with the needed visibility on the price of electricity, and therefore clarity on <br>their return on investment. <br> <br>
<br>
Interaction between the EU Emission Trading Scheme and other climate policies is key <br>
Obviously, the economic crisis and other international energy developments such as shale gas in the U.S. had not been <br>
anticipated in 2008, when the current climate and energy package was agreed. The effects of these developments strongly <br>
impacted the carbon price set via the EU ETS. The EU ETS was not designed to cope with significant changes on the <br>
demand side, which is certainly one of its main weaknesses. This needs to be corrected when implementing structural <br>
measures to strengthen the EU ETS beyond the backloading. The setting of a new ETS cap, based on the increase of the <br>
annual linear reduction from 1.74% today to 2.5% as soon as possible and in any case before the end of phase 3, will also <br>
have to take into account the expected continuous progress in RES deployment, improvements in Energy Efficiency and the <br>
development of other low carbon technologies, such as CCS. <br>
<br>
Interaction with other energy policies, such as the energy market liberalisation and the energy infrastructure <br>
package, is also key. <br>
For instance, scale up of renewables implies the development of electricity transmission infrastructure and support for <br>
generation adequacy mechanisms as well as R&amp;D support for energy storage to accommodate greater intermittency of <br>
supply and reduced load factors. This goes hand in hand with the completion of the Internal Energy Market, but also <br>
beyond the frontiers of the EU. Efficient cross-border interconnections are critical for energy security. <br>
*** <br>
2.<b> </b>Targets <br>
<br>
• An overall economy-wide greenhouse gas (GHG) emissions reduction target of at least 40% (compared to 1990). <br> <br>
Consistent with the long-term 2050 objectives of the EU (80-95% reduction for GHG and 91-98% for the Power sector), <br>
Alstom supports an economy-wide GHG reduction target of at least 40% in 2030. The International Energy Agency even <br>
shows that a 48% reduction is needed EU-wide if the world is to remain in the limits of the 450ppm scenario. Hence, any <br>
target below or equal to 40% in 2030 is not enough and in any case needs to be complemented with other Co2 reduction <br>
efforts outside the power sector. <br>
• A binding renewables target of 35% of total energy consumption, translated into national targets <br> <br>
As developed above, the set-up of a binding target for RES 2020 has proven efficient to support the development of RES at <br>
the level of Member States. So far, on-shore and off-shore wind and solar PV have particularly benefited from this policy. <br>
Since 2008, Research and Development have driven innovation in “new” renewable sources of energy such as marine <br>
energy (tidal, wave but also off-shore floating wind…) which will be contributing to the energy generation before 2030. In <br>
order to accelerate their deployment and benefit from their great potential in terms of emission avoidance and energy <br>
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supply security (tidal energy for instance is very predictable as tides are known), a new binding target for RES should be <br>
set for 2030. <br>
Alstom believes that a share at 35% in total electricity consumption, translated into national target, is realistically <br>
achievable. <br>
<br>
• An EU-wide binding target for tonnes of CO2 avoided as a result of CCS <br>Despite the ambition of the EU to have 12 large scale CCS demonstration projects in the EU in 2015, no one has been able <br>
to take Final Investment Decision (FID) so far. The lack of progress on CCS in the EU, and the rapid progress made in this <br>
area elsewhere in the world (USA, Canada, and China) shows urgent action is needed. <br>
CCS is a key component of a cost effective decarbonisation of the power sector (both coal and gas power plants) and the <br>
industry sector. According to IEA (Energy Technology Perspective, 2012), “delaying or abandoning CCS as a mitigation <br>
option in electricity generation will increase the investment required in electricity generation by 40% or more (2DS <br>
scenario) and may place untenable demands on other emissions reduction options” <br>
Alstom therefore supports, at the EU level, a binding CCS target in terms of CO2 avoided to cover both the power and <br>
industry sectors. This CCS target set up should be supported by the design of an EU CCS Roadmap, which will assess the <br>
opportunities of deploying CCS at Member State level, while easing the implementation of the target. <br>
This objective could be translated in Member States, at their discretion, through a system of national Obligation <br>
Certificates, on the pattern used in the UK for Renewables (ROC - Renewable Obligation Certificates), or through Feed in <br>
Tariffs and / or Contract for Difference. The implementation of this CCS target in Member States imply CCS is treated a <br>
level playing field with the other low carbon technologies (equal treatment vis-à-vis feed in tariffs). <br>
Visibility of the expected revenue stream is the key element to unlock investments in CCS while the carbon price on the EU <br>
ETS is still not high enough. <br>
• A 20% target for the reduction of total CO2 emissions across the transport sector <br> <br>
In the White paper on Transport published in 20112, the European Commission adopted a roadmap of 40 concrete <br>
initiatives for the next decade to build a competitive and clean transport system. According to the Commission, specific <br>
efforts should be made in the Transport sector, “still a growing source of GHGs”. Base on this statement, the Commission <br>
called for a reduction of at least 60% of GHGs in the Transport sector by 2050 (compared to 1990), and 20% by 2030 <br>
compared to 2008 level. <br>
Therefore, in line with the Commission, Alstom supports that the 2030 milestone set in White paper on Transport <br>
(reduction of 20% in CO2 emissions compared to 1990 level) shall be made a binding target. <br>
In addition, Alstom will support any 2030 targets or action on energy efficiency provided it covers the supply as well <br>
as demand side. <br>
<br>
*** <br>
<br>
<br>
<br>
<br>2 http://ec.europa.eu/transport/themes/strategies/2011_white_paper_en.htm <br> <br>
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3.<b> </b>Instruments <br>
<br>
• A tight EU ETS that delivers supply/demand balance in the carbon market, ensure scarcity and reflect the expected <br>
deployment of low-carbon energy <br>
<br>
Alstom believes that the EU Emissions Trading Scheme is one of the main tools to achieve the EU’s emissions reduction <br>
objectives at the lowest cost and to stimulate investment in low carbon technologies through an appropriate carbon price <br>
signal. <br>
A functioning ETS needs a significantly higher linear factor than the current one (1.74% starting in 2013) and an <br>
adjustment mechanism to ensure supply/demand balance. And crucially, the ETS cap needs to reflect the expected <br>
progress of other climate and energy policies, such as Renewables and Energy Efficiency. <br>
Therefore, Alstom supports an ETS cap for 2030 based on an increased annual linear reduction factor of CO2 emissions <br>
reduction from 1.74% to 2.5%. This new cap for 2030 should be set as soon as possible and in any case before end 2014 <br>
in order to provide the required long term visibility to investors. <br>
As part of the structural measures needed to strengthen the EU ETS, Alstom support the permanent set-aside of the <br>
backloaded allowances and encourages also the implementation of a Permanent Adjustment Mechanism (PAM). A <br>
volume adjustment mechanism would ensure the efficient functioning of the ETS on the long term and the scarcity needed <br>
to unlock and support investment in low carbon technologies. This PAM does not modify the cap once set, but acts as a <br>
shock absorber (when the Demand is below Supply, a reserve is built, when Demand exceeds Supply, reserved allowances <br>
are put back on the market). Please refer to Alstom’s response to the European Commission’s Consultation on Structural <br>
Measures to the ETS. <br>
• Continuous support to R&amp;DD <br> <br>
An ambitious Climate and Energy framework for 2030 should be a key driver for R&amp;DD and innovation. By 2030, Europe <br>
needs to have developed, demonstrated and deployed a wide range of low carbon and energy efficient technologies. <br>
Programmes should not only target research but also demonstration in order to shorten the time to commercialisation for <br>
the most promising technologies. <br>
Main areas of action should include flexible gas turbines, power plants efficiency, CCUS, energy storage and renewable <br>
technologies. <br>
<br>
There is a clear link between the volume of technology deployed and cost reduction. Thus, technology costs will be reduced <br>
much faster if deployment is supported, instead of isolated and limited R&amp;D projects. Public funding and as well as <br>
incentivised private investments will therefore be critical. Additional sources of financing earmarked to RD&amp;D should be <br>
found, both at the EU and at the Member States’ level. <br>
<br>
Financial instruments should be adapted to the 2030 objectives. Instruments such as the NER300 and other financing <br>
tools (loans, guarantees, project bonds) should be developed to support the deployment of innovative energy projects. <br>
Today, the EU ETS Directive only recommends that at least 50 % of the revenues from the EU ETS should be used for <br>
climate action. Alstom would support this threshold to be increased to 100% and be made binding, so as the revenues <br>
coming from the auctioning of allowances would be yearly earmarked to national RD&amp;D program to encourage research in <br>
low carbon and energy efficient technologies, or gathered in a “Technology Fund for Cleaner Energy” and allocated after <br>
competitive process (NER 300 - like). <br>
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<br>
• A strengthened Internal Energy Market <br>
<br>
<br>
Alstom promote capacity mechanisms that support peak, dependable and flexible power capacity, both from generation <br>
and storage, and that give priority to speed of dispatch. A functioning Internal Energy Market can only become a reality <br>
through the extension of the transmission and distribution infrastructure and cross-border interconnections. Bottlenecks in <br>
the EU’s transmission grids must be tackled as a matter of priority and with financial support via EU funding tools. <br>
Energy storage can become a major game changer for the energy debate. Currently, 99% of energy storage is delivered by <br>
pumped storage. Further R&amp;D e.g. on variable speed pumped storage can help to improve network stability and integration <br>
of renewables. Again a cross-border perspective needs to be adopted by the involved actors in order to be cost-efficient. <br>
Here, EU coordination and support would really be an added value. <br>
Increasing grid and cross-border interconnection will also be imperative to improving supply security and efficient use of <br>
energy in the EU. It will also help to deal with the intermittency and peak (as the peak time is different from country to <br>
country) by coupling cross-border balancing. <br>
In this context, the EU Electricity Market Liberalisation legislation has an important role and needs to be applied in such a <br>
way that supports investment in 3rd party projects (those being run by non-TSO actors) in cross-border transmission and <br>
supply markets. <br>
<br>
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