IAI study on the Renewable Energy Inception Impact Assessment
June 30th 2016
The Impact Assessment Institute has scrutinised the European Commission’s Inception Impact Assessment (IIA) on a new Renewable Energy Directive and bioenergy sustainability policy for 2030 (AP 2016/ENER/025). The Institute finds that the IIA does not fully follow the Commission’s Better Regulation Guidelines and does not provide the intended “comprehensive basis for stakeholders to provide feedback, information and opinions”.
A key finding is that the IIA was compiled and published before the completion of the REFIT evaluation of the existing policy, planned for late 2016. The Commission did not explain sufficiently why it did not complete the evaluation before starting the legislative process. Additionally, the IIA does not provide sufficient explanation on the most relevant findings and background data that it identifies as the evidence base for ongoing policy making.
In many instances, rhetorical statements are made about the benefits of renewable energy, before relevant evidence has been presented in support. Balanced rhetoric, with acknowledgement of all material benefits and trade-offs, is necessary in order to provide a consistent platform for analysis and to support robust conclusions.
Additionally, the IIA refers frequently to the results of the Impact Assessment on Climate & Energy Policy to 2030 as the background to many of the analytical conclusions. The IAI’s own study on that Impact Assessment concluded that the lack of transparency in its data and modelling severely impair its legitimacy as a basis for developing policy and legislation.
The IIA has an important role in setting the scene and creating a platform for analysis and stakeholder consultation. Due to the concerns identified above, the Institute recommends a careful review of the identified issues, to ensure that the discrepancies are not adopted and amplified in the future Impact Assessment and legislative proposal.