The Institute for Impact Assessment and Scientific Evaluation of Policy and Legislation
EU renewable energy policy undermined by lack of transparency and unsubstantiated assumptions
June 19th 2017
The Impact Assessment Institute (IAI) has scrutinised in detail the Impact Assessments accompanying the European Commission legislative proposal for a directive on the use of energy from renewable sources. The lack of availability for scrutiny of the models used to calculate macroeconomic parameters, indirect land use change and effects of alternative fuel policies is very serious, undermining the legitimacy of the results.
Renewable energy cost figures, used to calculate the projected renewable energy share in 2030, do not reflect actual (lower) values quoted in the Impact Assessment, requiring a full recalculation. The analysis of options for meeting the 2030 target is undermined by the fundamental conflict between the “binding” EU target and the lack of binding national targets.
The Impact Assessment analyses in detail the effects of biomass feedstocks but the criteria in the legislative proposal are not sufficient to ensure avoidance of substantial short and medium term biogenic emissions. The policy to cap food-based biofuels for transport was assumed without supporting analysis and does not differentiate between actual GHG performance of biofuels (including indirect land use change).
The models underlying EU energy and climate policy should be made publicly available and be fully peer-reviewed to provide confidence to stakeholders in the resulting policy provisions. The IAI also recommends accurately accounting for the actual greenhouse gas emissions from renewable energy sources, enabling the “renewable” portion of each type to be applied to policy.