Among other things, the package will detail:

- how to split the overall 20% target for renewable energy by 2020 among member states;
- the rules for the preparation of National Action Plans;
- a proposal for a directive for renewable energies to replace the current renewable electricity and biofuels directives; and 
- a possible link between targets for CO2 reduction and renewables.

The Commission has suggested the publication date as 5 December, just a few days before the ministerial segment of the UN Climate Change Conference begins in Bali, Indonesia. This will enable the EU to claim the climate ‘high ground’ at Bali, as well as preventing EU member states from using the ministerial conference as a last-minute lobbying venue over the sharing formulae being used by the Commission to divide up the 20% target.

Target allocation

The key question of how to distribute the overall 20% target into 27 national targets has yet to be answered, with the Commission continuing its deliberations. Increasing the share of renewables in the EU, from around 7% today to 20% in 2020, means an increase of 13 percentage points over 13 years. One simple option would be for each country to increase its share of renewables by 13 percentage points, as proposed by EWEA at the Portuguese EU Presidency’s seminar on renewables this July. Such an approach would make the process more transparent and avoid long negotiations. The other option is to distribute the 20% target using a model based on available potential in each member state.

However, the key issue is not which approach should be applied, but that agreement on the national targets should be reached as quickly as possible. Regardless of the model selected, European citizens, politicians, media and organisations will have a clear indication of their government's ambitions if they add 13 percentage points to the current level of renewables in their country, and then compare that figure with their government's proposal for the share of renewable energy in 2020.

The absence of an indication of how much will come from electricity and heating and cooling (for biofuels there is a minimum target of 10% of fuel consumption) also makes the task of allocating the 20% target much more difficult, and brings significant uncertainty to investors and other key players involved in planning the necessary infrastructure. This is why EWEA and the other renewable energy associations have consistently asked for sector-specific targets in the three energy areas.

Other issues that will have to be tackled relate to:

- the possibility of harmonising the support mechanism for renewable energy;
- whether a country can achieve part of the target through the excess renewable
- production of other member states (via some sort of trading mechanism);
- whether paying for installations in third-world countries should count towards national targets; and
- a possible link between the ETS and the renewables directive.

Harmonisation debate

EWEA believes that harmonisation of the support mechanisms should not become a key topic during the discussions, given that the electricity markets in Europe remain extremely heterogeneous in all other respects.

In our view, the creation of a truly integrated and competitive market must come first; this can only be done through more transparent access rules, the removal of dominant positions and increasing interconnection capacity.

Harmonisation of support schemes for renewables is meaningless, when there is a lack of harmonisation in other areas of the energy sector, and this would in fact dismantle some of the efficient support systems that currently exist in Europe.

To date, these schemes have ensured a positive growth rate for renewables at low cost. Whilst the CO2 target (20% by 2020 or 30% if other industrialised nations take a similar approach) and the renewables target (20% by 2020) will need to be compatible, the ETS and renewables debates should not be mixed up.

Renewables are clearly environmentally friendly and thus reduce greenhouse gas emissions, but they also play other important roles that cannot be captured by the ETS Directive.

These include:

- their contribution to security of supply and employment;
- reduced import dependence;
- reducing fuel price uncertainty; and
- other environmental and health advantages, such as zero emissions of NOx and SO2 in power production.

These different roles have to be taken into account by specific legislation, so that they serve the purposes for which they have been created. Policy makers should therefore not see the renewables goal solely as a way to achieve the CO2 target.

Meanwhile, the European Parliament has adopted its response to the European Commission’s Renewable Energy Road Map and the Heads of State March agreement of the 20% target. On 25 September, it adopted, with overwhelming majority, a report on renewables by MEP Britta Thomsen calling for a significant strengthening of the existing legal framework.

The commision's proposal can be found here
EWEA Press release