With the new European Commission’s introduction of the European Green Deal, and the increase in the ambition of the 2030 and 2050 CO2 targets for the EU, a review of the underlying legislation is underway to examine whether it needs to be strengthened.
RECS International has developed a response to the open consultation on the review of the RED-2 based on the following points:
- Moving to compliance markets in Europe. Minimum shares or quotas for either the supply or procurement of renewables, with GOs as the accounting instrument, have had proven success in increasing demand for renewable energy – a key aim of RECS International.
- Full Disclosure: Ensuring that all consumers know the source of the energy they buy will create a level playing field for all energy carriers and should encourage more consumers to buy renewables.
- Accounts for all users: Member States should allow market actors and end-users of all types to open GO trading accounts and/or cancellation accounts in all national markets. Also, Customer-specific cancellations should be possible in all registries, independent of whether the electricity supplier, agent or any other account holder do the cancellation.
- Ensure issuance for supported generation: All generation should be eligible to receive GOs. This change is required to facilitate a full-disclosure system and does not need to change the underlying principles of national systems.
- Time-stamping: RECS International supports the aim of some renewable energy consumers to have more granular information on GOs, particularly regarding the precise time at which the underlying unit of energy was produced.
- Specifying info for small installations: RED-2 allows installations of less than 50kW to provide simplified information on their GOs. The exact nature of this data should be determined in the revised article to provide clarity and certainty to market participants and system operators and to facilitate a full disclosure system.
For more information on this consultation response please contact Adam White, RECS International’s Director (firstname.lastname@example.org).