Accepted Manuscript Renewable energy pioneers are threatened by EU policy reform
Jeremy M. Hills, Evanthie Michalena PII:
S0960-1481(17)30128-3
DOI:
10.1016/j.renene.2017.02.042
Reference:
RENE 8549
To appear in:
Renewable Energy
Received Date:
13 December 2015
Revised Date:
01 January 2017
Accepted Date:
16 February 2017
Please cite this article as: Jeremy M. Hills, Evanthie Michalena, Renewable energy pioneers are threatened by EU policy reform, Renewable Energy (2017), doi: 10.1016/j.renene.2017.02.042
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ACCEPTED MANUSCRIPT
Renewable energy “pioneers” are threatened by a reduction in EU market manipulation
Research highlights
Policy-push and market-pull drivers have been used to promote EU renewable energy penetration. RE actors perceive that there is a need for EU policy reform. The EU suggests a new policy framework towards a pan-European RE target, new energy governance system and innovation initiatives; those new suggestions seem to bring over a balance between push and pull factors, however reflect the differentiated capacity of Member States. The degree of market intervention, rather than the balance of push and pull factors, is the distinguishing factor between types of actors. Reduction of market manipulation may threaten the continued involvement of pioneering actor types.
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ACCEPTED MANUSCRIPT Renewable energy pioneers are threatened by EU policy reform Jeremy M. Hillsab and Evanthie Michalenab1 a
Institute of Marine Resources, Faculty of Science, Technology & Environment, Private Bag, Laucala Campus, Suva, Fiji.
b
Sustainability Research Centre, University of the Sunshine Coast, Maroochydore DC Qld 4558 Australia.
Corresponding author (Present address: Alkiviadou 186-188, 18536, Piraeus, Greece. e-mail:
[email protected] ) 1
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Abstract
ACCEPTED MANUSCRIPT
The European Commission is reforming renewable energy (RE) policy to promote European competitiveness and RE penetration but also to phase-out financial subsidies for mature RE technologies. Optimising policy can be framed in the balance of Market Pull (MP) and Policy Push (PP) factors. The role of this paper is to determine the diversity of perceptions of energy actors, how that diversity relates to the balance of MP and PP and how this is likely to influence the ongoing policy reform process. A European survey was implemented and a total of 108 responses were received. A majority of actors (>75%) thought that there was a need for new EU RE policy. Four robust clusters of actors were identified. Further analysis demonstrated that the balance of MP and PP factors were not important in distinguishing between these clusters. The analysis concluded that levels of market intervention are the primary axis of difference according to energy actors’ opinions. These results have consequences for intended policy shifts in the EU RE sector, as the reduction of market intervention could mean that some of the “RE pioneers” may leave the sector which would impact on further RE penetration and EU competitiveness. Keywords EU policy reform, renewable energy actors, market intervention, policy push, market pull Table of abbreviations CHP COM COP21 EC EFSI EIPP EU-ETS EU FiTs MP MS PP RE SET
Combined Heat and Power / Cogeneration (EU) Communication United Nations Climate Change Conference, November 2015, Paris, France. European Commission European Fund for Strategic Investments European Investment Project Portal European Emission Trading Scheme European Union Feed-in-tariffs Market Pull Member States Policy Push Renewable Energy Strategic Energy Technology (Plan)
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1. Introduction
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1.1 Developments in EU renewable energy policy During the last two decades, the EC (European Commission) commitment towards RE (Renewable Energy) market penetration required significant economic and political interventions from Member States. In the Green Paper of 2013 [1], the COM (2014) 15 final [2] and in the SET plan [3], the EC identified a range of critical challenges related to climate and energy to be dealt with by 2030. More recently, at COP21, the Paris Agreement was supported by EU targets: at least 40% greenhouse gas emissions reduction and RE feeding of at least 27% by 2030 [4]. The European Emission Trading Scheme (EU-ETS) is the cornerstone of a political and regulatory framework for EU emissions targets; the EU ETS being the largest carbon market in the world [5]. According to EU market industrial players “the European Commission must develop an integrated and coherent sustainable industrial strategy and should set up a policy platform to that aim”[6]. The most important challenges for the decarbonisation of the EU are the on-going economic crisis and associated budgetary problems of Member States (MS) and the difficulty mobilising funds for long-term business investments. Those challenges operate within a regional backdrop of high levels of public debt, clusters of unemployment and austerity policies [7] which are challenging the continuing promulgation of the EC and allied European institutions. Within the energy sector there is an increasing dependency across European Member States (MS) on energy imports (higher than 50%) from non EU-countries [8]. This dependency is not harmonious with recent geo-political tensions in the wider-region and growing concerns over energy security. To deal efficiently with energy concerns in a cost efficient way in the shifting geopolitical context, the EU seems now to be taking a range of steps such as supporting the use of fossil fuels and encouraging RE generation only in selected MS. The EC proposed a new governance system [9] and the “Winter Package” in 2016 [10]. The “Winter Package” aims for a pan-European target of 27% RE by 2030, however it leaves it entirely to Member States to ensure that their contributions add up to the EU target; what happens if they do not is not sufficiently defined. This new approach of the pan-European target could be interpreted as an admission of EU failure to further incentivise reform in MS public and private sectors in a way to achieve more progressive goals set by contemporary EU policy. Especially after the EU commitment during COP21 in Paris, with upscaling of EC interest in RE, from low carbon electricity supply, to broader challenges such as climate change response, energy security and global economic competitiveness (see in particular SET Plan [3] and “Mission Innovation” initiative [11]). The powerful EC rhetoric of driving green innovation through liberalized energy markets over the last two decades [12], largely at the expense of the end-consumer, seems to have dissipated; although the energy transition is still very much in progress and further achievement is predicated on market manipulation and ongoing financial incentives. When it comes to RE monitoring, the EU now sets higher targets, but intends to reduce the support provided to MS to deliver them. This is because the new Proposal for Energy Governance asks for a “REFIT” (Fitness Check) process, suggesting “significant reduction of administrative burden on Member States” [9 (p.6)] and “avoidance of new administrative burdens and additional cost” [9(p.8)]. However, there is an oxymoron here as the Proposal itself contains 87-pages of new legislative content to be respected by MS. In fact the process suggested by the Proposal is accompanied by several annexes and explanation documents on how this [process] will be followed (impact assessment, new types of monitoring reports to be filled in etc.). Additional phasing in of EU Staff is even predicted as “necessary” in the Proposal [9 (p.9)]. This is expected to burden even more the MS since some of them might not have the resources to follow-up such complicated documents and procedures and consequent requirements in terms of budget and resources at national or EU level. This differential in MS capacities is already reflected in the European MS leadership of recent policy instruments such as the SET Plan [13] and Mission Innovation [11]. Concerns on the new EU energy governance scheme are also noted by the European Environmental Bureau as “not compensating for the lack of national binding targets after 2020” [14]. 3
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ACCEPTED MANUSCRIPT Answers to the above challenges which shape the RE sector become more critical in the new politico-economic and geopolitical contexts which now face the EU. These concerns were coherently expressed by the EC in 2014 [15]: • Who is financing the energy transition? • Will the market approach survive the transition? • What is the right balance between competitiveness, affordability and sustainability? 1.2 The push and pull factors in policy design The main policy instruments for the promotion of technologies are often classified by authors and political think-tanks into two broad categories: market-pull (often also referred as demand-pull) and policypush approaches (which include “supply-push” and the more specific “technology push”)[16] [17] [18]. Policy-push (hereafter, PP) and market-pull (MP) arre both considered as important drivers in spurring innovation in environmental technologies. In the PP approach, the audience tends to be less engaged as it is addressed in a blind and generic manner. On the other hand, MP generally involves a higher level of engagement because the audience becomes aware and seeks out the opportunities in that area. Still, MP can fail if the wrong audience is targeted, or the trust of customers is betrayed. The use of the MP approach has been investigated by the EC as an instrument “for promoting innovation in environmental characteristics” [ 19]. Authors have focused on the differentiated impact of those instruments on the diverse types of activities, such as those related to the introduction of incremental or radical innovations [20], suggesting that MP policies may benefit mature technologies to a larger extent than less mature technologies [21]. The practical application of the MP and PP approach tends to be in terms of determining optimal policy choice through identification of the relative strengths of MP and PP policy instruments, for example, Albrecht et al., 2015 [22] suggested differences in RE outcomes in relation to relative strength of MP and PP (Table 1). These authors suggested that in order for efficient technologies to be promoted, both PP and MP should be used, while an over-heavy MP approach would tend to promote use of more inefficient technologies. Manipulation of the relative importance of MP and PP can thus be considered as an approach for achieving optimum policy outcomes in the RE sector. Table 1: The effect of PP and MP on renewable energy diffusion and technology efficiency (based on Albrecht et al., 2015; Table 1 [22])
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Low
High
Low
Limited diffusion of inefficient technologies
Limited diffusion of efficient technologies
High
Market –Pull
Policy-push
Strong diffusion of inefficient technologies
Strong diffusion of efficient technologies
125 126 127 128 129 130 131 132
1.3 Push-pull in the case of RE penetration Policy structures governing energy development can significantly foster, or hamper, the diffusion of RE infrastructures [23]. Policy instruments can be viewed through the lenses of MP and PP instruments (e.g. [16], [17] [18], [24]). Both PP and MP are considered essential for an optimal, cost-efficient RE mainstream commercialization and deployment, not only at an EU level, but also at a global level [25]. The policy question then is how to obtain the best balance between the two policy approaches [25]. 4
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ACCEPTED MANUSCRIPT Policy-push (PP) instruments in the RE sector include R&D grants, special technologically-based financing incentives and institutional guidelines or protocols. To uptake RE and to drive forward the sustainable energy approach, the EU has used several institutional guidelines and reinforcements, starting with the Directive 2001/77/EC [26] as the first EU Directive on Renewable Energy which contain PP policy levers. The EU (having as main goals customers affordability and sustainability) has also encouraged “push” techniques at a national level, such as the improvement in public procurement protocols, a reduction in permit/licensing delays, the elimination of public opposition through transparency and the early involvement of general public in RE dialogue. The “push” approach, therefore, has demonstrated a broader remit than just technology and PP, thus the authors use the term policy-push to define push-related interventions more broadly than just technology. Almost one year after the 2001/77/EC Directive, elements of a MP strategy started to emerge. The EC used MP tools, such as conferences to raise awareness (for example, Sustainable Energy Week organized annually in Brussels), the funding of the construction of national / regional grids / energy networks (together with storage infrastructure) and the creation of conditions for the co-existence of Carbon Capture and Storage and CHP (Combined Heat and Power / Cogeneration) together with RE. For building energy efficiency, MP initiatives included the encouragement of business models for the optimal use of decentralized energy technologies and storage systems so as to ensure market attractiveness of demand-side management technologies. To successfully implement a MP strategy, the EU had to work with RE developers and member states, for example working on the initiation and promulgation of subsidies. Maybe the most pervasive MP instruments used by the EC to encourage uptake of RE technologies have been the lobbying of RE developers and the backing-up of national systems on the implementation of financial incentives, such as carbon pricing, cap-and-trade systems, renewable portfolio standards and deployment incentives (green certificates, feed-in tariffs). 1.4 Relationship between push-pull and energy actors The dynamics of RE policy is also reflected in the associated stakeholder base as “multiple communities exist, overlap and are constantly changing” [27]. Rather than considering the balance of pushpull in European RE policy optimisation, the focus of the work presented here is on the perceptions of actors involved in the EU RE market. With a history of dialogue and engagement with RE stakeholders by the EC and also periodic strengthening of the rights of individuals and organisations to have active participation in decision making (e.g. the Aarhus Convention of 1998 [28] or EC Communications which promote public participation [29]), the perception of actors involved in the RE sector becomes increasingly important in the policy reform processes. The importance of such inclusion is still salient with the need for more transparent and participatory processes by the EC being included in the 2016 proposal for a new EU energy governance [9, p.8]. According to Genius et al., 2013 [30], policy makers should consider policy options with a correct understanding of risk preferences, especially when those options affect input and technology choices. The linkage of stakeholder perceptions to policy reform process may be a key factor to ensure ownership and advancement of policies. Within the RE sector, involved actors may potentially aggregate around a certain “desired” balance or singular meme of MP and PP making policy consultation straightforward, or alternatively, there may be significant differences between stakeholders with certain groups favouring MPdominated policies and others PP-dominated approaches. In addition, if differences in stakeholders are apparent then these differences may also be manifested in their views on the certainty in the future RE market and their predilection to invest in further RE penetration within the challenging EU context. The differential perceptions of the actors involved in RE can be used to help identify the current RE landscape through different lenses and to determine how PP and MP relate to the ongoing EC RE policy reform process. 5
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The work presented here is anACCEPTED investigation ofMANUSCRIPT the EU RE policy background and how policy reform can be strengthened by consideration of actor diversity. The focus is on RE actors who are driving the low carbon energy transition; in this work we term these actors “RE pioneers”. The aims of this study are to (i) group actors based on perceptions of issues associated with the EU RE market and to (ii) determine if groups of actors are distinguishable in terms of their perceptions towards the balance of PP and MP policy instruments. Furthermore, in light of the shifts in EU RE policy the study aims to (iii) assess how new EU RE policy developments are likely to affect or impact upon the actor groups, and (iv) suggest how policy reform of the energy transition towards a competitive and low carbon future can be effectively directed.
2. Methodology 2.1 The target sample of European energy stakeholders The intention of the work is to cover RE perceptions of European professional energy actors. The term “professional” is used to mean that some of more part of their job is involved with energy systems; in this sense they can be considered as “experts”. The target of the sampling was not energy consumers (i.e. the whole population of the EU) or non-professional groups involved in energy-related activities (for example, local pressure groups). Within energy professionals, our target sampling was from private sector, government administrations, research bodies, international institutions and non-governmental bodies with a professional cadre (e.g. NGOs, CBOs). In order to cover potential gaps of non-response from certain member countries, EU experts who are working in the energy sector were surveyed as well, so as their voice cover the whole of the EU. Developing suitable numbers of agreeable contacts was done in rough proportion to the proportion of MS national RE generation, with higher numbers of agreeable contacts in countries with greater proportion of EU RE generation. However, such a sampling balance was unsettled due to differential response rates between MS. Due to the trans-EU nature of the work it was only possible to carry it out through digital means. The sample was drawn from profiles of energy experts in LinkedIn. The choice of LinkedIn was because we deliberately wanted the actors to express their voice in an objective way and not through EU surveys of which the objectivity is questioned. The energy experts surveyed were included among existing contacts of one of the authors; this added to the process a direct engagement and subsequent enrolment in the study. Once a new LinkedIn energy professional was found, following establishment of an initial contact on LinkedIn, a request was made for completion of an energy questionnaire. If a positive answer was provided through LinkedIn, then the questionnaire link was provided to them. In statistical terms the sample of LinkedIn contacts would be random within the sample frame of European professional expert energy actors who have a presence on LinkedIn.The contact development and subsequent questionnaire was implemented during a 4-month period from January 2013 to May 2013 this was targeted to be just prior to the production of a range of new EU policy initiatives and so providing a clear and view of contemporary EU 20-20-20 policy. 2.2 The questionnaire design The questionnaire was provided as a link sent through LinkedIn intra-mail which opened the questionnaire on the SurveyMonkey platform. A test run of this process was carried out with two known energy experts to test the technical operation and to make improvements in clarity of the questions; those data were excluded from the study results. The actual questionnaire was designed to collect a range of information on EU RE policy based on the perceptions of the targeted actors. Due to the need for brevity in the questions to reduce respondent fatigue, some jargon or well-expounded energy concepts were used which was concomitant with the expert nature of the target respondents. 6
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ACCEPTED It was necessary for the questionnaire to focusMANUSCRIPT on the key issues in the RE sector and there is a myriad of possible RE issues negating the option of using just open text-based answers. Therefore, the most representative key issues were identified from a previous published literature meta-analysis of EU RE issues. Michalena and Hills, 2012 [31] have identified and ranked the most important 54 RE issues among energy stakeholders. The questionnaire was constrained to questions on the 17 most frequently cited of the 54 EU RE implementation issues (Table 2). The figure of 17 was a pre-set estimate based on the likely number of respondents from pre-determined LinkedIn agreeable respondents, the time it would take to answer the questions and the tractability of dealing with these multiple factors in the multivariate analysis. Table 2: The 17 most frequently cited RE implementation issues from a meta-analysis of European literature which were used in the questionnaire [31].
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Code
European RE implementation issue
SS5
Local strategies are required to meet with RE industry but need to be based on knowledge, training on REP development and academic monitoring. GG2 EU policy drives national-level renewable energy penetration and European competiveness, but lacks clarity. EE2 Investment in RE and relevant infrastructures is costly (very high initial costs and long payback periods). TT2 Energy saving is needed but will restrict the need for investing in renewable energy. SS3 Local opposition and conflict against REP implementation varies across actors due to many reasons. EE6 Subsidies, incentives and funding must be appropriate and carefully designed to support REP implementation. EE8 RE competitiveness depends on conventional fuels prices volatility and internalization of externalities. GG12 Institutional changes and market-based mechanisms lead to sustainable energy systems. SS7 Companies experiment in a range of ways where REP implementation is concerned. VV7 Among the important criteria for the assessment of REP implementation are environmental criteria (i.e. reduction of CO2 emissions). GG6 Long-term renewable energy system monitoring is necessary. GG7 Dispersed RE decision making at multiple levels is difficult to manage. SS4 Social systems, networks and partnerships are important for RE diffusion and REP implementation, encompassing a wide range of actors. Quality criteria for the implementation of participatory exercises are still under development. TT4 There is a need for wide range of RE demonstration projects. GG3 Landscape management is important for REP implementation and requires coordination of many sectors. GG5 Although economic performance and environmental protection are co-joined goals, environmental performance lacking in discussions (unbalanced linkage between economic and environmental performance). EE5 RE new markets and RE market uptake require facilitating characteristics such as segmentation and managers. 251 252 253 254 255 256
On clicking the SurveyMonkey link respondents were provided with a short-preamble which identified the aims, the expected time involvement of 10 minutes and a confirmation that the results were to be used only for research purposes and not in any commercial way. The following questions were then included in the questionnaire:
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ACCEPTED MANUSCRIPT 1. Respondent profile: Respondents were asked which MS do their answers mainly concern (the EU27 at the time of the survey as Croatia had not joined by then) or provided an alternative option for all of EU coverage (for those working in international bodies). In addition, respondents were asked to note the type of organisation that they mainly worked (see below for categories). 2. Respondents were asked “Do you think that EU design of RE policy is necessary?” Categorical answers “Yes”, “No”, “Not sure”, “Only for urban centres”, “Only for rural areas”, “Only for remote areas” (no respondents selected any of the last 3 answers and these were dropped from the subsequent analysis). 3. Respondents were asked to score the importance of each of the 17 RE implementation issues (Table 2) on a Likert scale from “0” (non-significant) to “6” (highly significant). The 17 issues were randomised in the questionnaire presented to respondents and not ranked in order of frequency as presented in Michalena & Hills, 2012 [31]. 4. Respondents were asked then asked about their degree of certainty for the 17 issues in the following way which included a definition and clarification; “Your estimation on the certainty of the future state of each RE issue. If you think that an issue has a very high degree of certainty about how it will be in the future then you should score it with a “6”. If you are highly uncertain how the issue will be expressed or what magnitude the effect will be in the future then you should score it a “0”. More positive scores indicate a higher degree of certainty”. 2.2 Questionnaire responses and representativeness The questionnaire response rate from connected and agreeable LinkedIn contacts was 32%. A total of 108 contacts completed the questionnaire and these form the data set analysed in the work presented here. The most frequent responses were from private sector institutions (39%) followed by research (31%) and International / European Institutions (19%) (Table 3). Responses were provided from 24 of the 27 Member States (Table 4). No responses from agreeable LinkedIn contacts were obtained from Austria, Hungry and Latvia; who represent about 7.2% of the 2013 EU RE production although some inclusion may be predicated on the 23% who represented EU-wide bodies. Table 3: The distribution of the sample actors in relation to type of institution
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Respondent Institution Government level (national and sub-national governmental organizations) International / European institutions Local Society (Associations, NGOs, CBOs, Think Tanks) Private energy sector (Developers, Financial Institutions ...) Research 288 289
Number of respondents 10 20 2 42 34
Table 4: The number of respondents from each Member State covered by the survey, or in work across the whole of the EU.
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Member State Belgium Cyprus Czech Republic Denmark Estonia Finland
Number of respondents 3 3 2 2 3 1
Member State Luxembourg Malta Netherlands Poland Portugal Romania 8
Number of respondents 2 2 3 2 3 2
France Germany Greece Ireland Italy Lithuania 291 292 293 294 295 296 297 298 299 300 301 302 303 304 305 306 307 308 309 310 311 312 313 314 315 316 317 318 319 320 321 322
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ACCEPTED MANUSCRIPT 9 Slovakia 4 11 7 8 2
Slovenia Spain Sweden United Kingdom The whole EU
1 2 4 1 6 25
Overall, questionnaire response rates from agreeable LinkedIn contact was acceptable. The questionnaire was successful in capturing the range of MS and organisations active in the EU RE energy sector. However, the inadequate response means that representativeness for a particular MS or by institution type is limited. Thus the following analysis looks at the dataset as whole sample representing “EU energy professionals” rather than breaking it down into constituent MS or organisational types. 2.4 Statistical and mathematical analysis The statistical and mathematical approach used standard techniques; multivariate analysis was required due to the structure of the data collected, with multiple perceptions from multiple respondents. The multivariate techniques utilised were classification (specifically, K-means clustering) to create groupings of individual respondents ordination (Principal Components Analysis) to help visual interpretation of hyperdimensional data in a small number of axes and discrimination (Linear Discriminate Analysis) to validate the robustness of the clusters and to determine the weight of the various discriminating variables. More detail is provided with each analysis in the following section. All analyses were carried out using Minitab (v17). 2. Results 3.1 The need for policy reform The respondents were asked if there was a need for new EU policy. Over 75% of the 108 actors responded with a “Yes” answer (Figure 1) with less than 10% providing a “No” answer. These results suggest that, based on the perception of the target expert actors, there is definitely a need for EU policy reform. This is probably because EU stakeholders have not seen, up to now, such results so as to make them think that there is no further need for RE EU policy. The necessity of public support and policy frameworks has been researched from several other authors. For example, Creutzig et al., 2014 [7] call for “an increase in public expenditure [to support RE] to compensate for the slump in private investments and to provide economic stimulus”. Figure 1: The perception of the energy actors in relation to the need for new EU renewable energy policy (n = 108, “No data” for when no response was provided)
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ACCEPTED MANUSCRIPT Therefore, the crucial question becomes “what kind of policy do the stakeholders want?” 3.2 Developing a typology of actors RE perceptions This section reports on the analysis of views and perceptions of actors as probed by the questionnaire. The questionnaire assessed the range of views across the actor sample and the subsequent analyses determine if there are different groups, alliances or “types” of actors as defined by these perceptions. Understanding the actor diversity and what “types” of actors exist can be useful when dealing with consultation for new policy developments as well as in this case assessing the effectiveness of policy reform process; accommodating such diversity is an ongoing issue in many policy reform and policy optimisation processes in many sectors. In fact, as far as the authors are aware, this it is the first time that such a classification of EU RE policy actor perspectives is presented in the scientific literature. The only study with a substantive assessment of actor diversity was in 2004 in a research which targeted how consumers receive RE information and make decisions and how the analysis based on behavioural theory could help in policy development and/or the lifting of barriers related to renewable energy [32]. The analysis presented here differs in that the sample used was not energy consumers but professional energy experts drawn from across the EU. When a sample of actors are presented with a range of multiple choice, Likert scale or ranking questions it is possible that answers appear to be random and independent. However, it is also possible that certain groups of the actors answer the questions in a similar way, thus similar patterns of answers are found across a number of actors, not all answers are independent and an inherent hyper-dimensional structure is found in these data which reflects a “type” of actors. An actor “type” is thus defined by similarity in answers to multiple questions by a sub-population of the respondents. This process requires an analysis of multiple answers by multiple actors and thus necessitates the use of methods of multivariate mathematical techniques which deal with multiple samples (the 108 actors in this case) defined by multiple descriptors (the answers to the selected questions). The following analyses use a variety of statistical and multivariate techniques in order to define groupings and unpack the differences between the perceptions of the actors; utilised methods include classification, ordination and discrimination. 3.3 Clusters of perceptions of RE experts To identify coherent groups within the respondents in terms of their answers to the questions on the significance of RE issues, a classification procedure was carried out. K-means clustering produces a predetermined number of groups from multivariate data based on an iterative procedure to produce the smallest Euclidean distance between each observation and the centroid of the cluster. K-means performs better in terms of reducing overall Euclidean distance by initially informing the iteration based on a small sample of indicative group membership. This was done by summarising the data using Principal Components Analysis (PCA) and then selecting seed points for four groups which were central in the four quadrants of the axes. K-means requires all samples to have a full set of observations, in this case answers to the significance questions for all RE issues; to accommodate this constraint the dataset was reduced to the 90 respondents who responded to all questions in this section. The K-means classification, seeded by the quadrants of the PCA, produced four clusters of respondents. To verify the coherence of these four seeded clusters produced by the K-means clustering, a Linear Discriminant Analysis (LDA) was used. The LDA used the a priori determined cluster membership from the K-means to determine a Linear Discriminant Function (LDF) which then reclassifies each sample back to a cluster. The greater the mismatch between the a priori cluster membership and the reclassified back-tested cluster membership using the LDF, the less the integrity and coherence of the clusters. In this case the LDA correctly reclassified 87 of the 90 samples (or 97% reclassification success) suggesting that the K-means clusters were valid and recognisable groups as opposed to being random or clusters formed as an artefact of the forced grouping methodology. 10
ACCEPTED MANUSCRIPT To help visualise these hyper-dimensional groupings based on their answers on the significance of RE issues, the group membership was plotted on PCA axes which reduce the hyper-dimensionality to a small number of axes which represent the main variation in these data and which can be plotted (Figure 2). It should be noted that the PCA is used to help visualise these data on a two-dimensional and is a proxy for the pattern of these samples in the multidimensional space of the LDF. Figure 2: The outcomes of the K-means clustering of 90 respondents divided into the four emergent clusters visually displayed on the first and second axes of a Principal Components Analysis
Principal Components Axis 2
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4
2
0
-2
-4
-7.5
-5.0
-2.5
0.0
2.5
5.0
Principal Component Axis 1
The LDA also permitted an interpretation of the characteristics of the different clusters based on the respondents significance provided for the RE issues; this allows the overall characteristic of the cluster to be identified. The weighting of each of the issues in the LDF was analysed and high or low weighting attributed to particular clusters was identified and used to characterise the cluster. The particular issues that characterise the group (the significance scores for particular issues which were highly discriminating for that cluster in the LDA), an interpretation of the overall features of that cluster and a representative summary title for that cluster were determined (Table 5). Table 5: The emergent characteristics of the members of the 4 clusters based on the weighting of the RE issues in the Linear Discriminant Function (issues are positive for that cluster unless denoted negative by a “-“ prefix)
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Discriminat ing issues EE6 TT2 -GG6 SS5 EE8 GG12 EE2 -SS4 SS3 GG7 EE5
Summary and features of cluster member perceptions Intense market intervention: Stakeholders appreciate the importance of renewable energy support schemes as well as the need for energy saving schemes even if this limits RE penetration. Long-term energy system monitoring is not required. Sustainable RE market potential: RE market can develop given appropriate exogenous and external factors. Sustainable energy systems can develop with appropriate local strategies, investment climate and competiveness with conventional fuels with marketbased mechanisms. Dynamic but fragmented RE market: Segmentation and fragmentation dynamics of RE sector challenge market penetration and niche development. EU policy 11
Cluster summary name Governancereliance
Market-driven
Dynamics-led
-GG2
GG3 TT4
does not provideACCEPTED clear leadershipMANUSCRIPT to RE sector development and dispersed decision making and local opposition delay market maturation. Geographical and sectoral integration of RE: Interaction and coordination with landscape and other sectors important for wider RE implementation. Examples of a range of RE projects necessary for demonstrative purposes to the sector.
Rationalintegrationists
399 400 401 402 403 404 405 406 407 408 409 410 411 412 413 414
3.4 Differences in policy-push and market-pull in stakeholder clusters The different and robust clusters in stakeholders have been shown to be related to different perceptions of the challenges and issues in RE in the previous section. However, it is not clear to what extent these clusters have similar or different strengths of association with the dimensions of policy-push or market-pull. To do this the issues used to cluster the stakeholder were categorised to have either predominately policy-push (PP) based solutions, predominately market-pull (MP) based solutions or a “neutral” status in which PP or MP solutions were neither dominant or relevant (Table 6). A total of 7 issues were related to PP and 5 to MP solutions. For each stakeholder the mean score of the significance of issues linked to the PP and MP solutions was determined to provide an indicative PP and MP score, with implicit assumptions that PP and MP solutions are independent and all of equal significance and thus score in a linear and additive way. Table 6: The predominant solution type for the identified renewable energy issues. Solution types (MP = market-pull, PP = policy-push and Neutral = neither dominant MP nor PP solution)
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Issue code SS5 GG2 EE2 TT2 SS3 EE6 EE8 GG12 SS7 VV7 GG6 GG7 SS4 TT4 GG3 GG5 EE5 416 417 418 419 420 421
Predominant solution type PP PP MP Neutral PP MP MP MP PP Neutral Neutral PP PP PP Neutral Neutral MP
Two one-way ANOVAs demonstrated that there were differences in both PP and MP scores between the four clusters (PP: df = 3, F = 18.96, P < 0.001; MP: df = 3, F – 23.78, P < 0.001) suggesting that solutions to actor- perceived issues involved different degrees of MP and PP dependent on the cluster they were allocated to.
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MANUSCRIPT The trade-off options betweenACCEPTED PP and MP used in traditional optimal policy setting suggest that stakeholders should demonstrate a somewhat similar trade-off. So for example, when high significance concerns are associated with solutions related to high MP scoring then PP solutions will score lowly, and vice-versa. To illustrate the pattern of trade-off between PP and MP the mean cluster centroids were plotted (Figure 3). However, it was found that there were no apparent trade-offs between PP and MP, although differences in both cluster mean MP and PP was apparent. In fact the ratio of mean cluster PP and MP remained relatively balanced across the fours clusters, varying minimally from 0.97 to 1.11. These results suggest that trade-offs between PP and MP are not apparent but that MP and PP remain relatively balanced although there are significant differences in the degree of a combination of MP and PP solutions required by different clusters. These suggest that clusters are primarily related to the degree of intervention or manipulation of the RE sector rather than trade-offs between PP and MP. Figure 3: The mean cluster policy-push and market-pull score for the four identified clusters of renewable energy stakeholders (with 95% confidence intervals)
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3.5 Differences in certainty between stakeholder clusters Respondents were also asked about the degree of certainty or uncertainty of each issue in relation to what is expected in the future for the RE sector. Questions were structured in a way to identify the respondents perceptions of the future of RE development, or, phrased alternatively, their scenario of the future drivers and constraints of RE. A Total Certainty Index (TCI) was calculated from an unweighted summation of the certainty scores for each of the predetermined issues which was then normalised to vary between 0 and 100. Each respondent was thus designated a TCI score; a higher TCI indicates more certainty in the future. There is not an a priori reason why clusters should have differing level of certainty unless differing perceptions of the combination of factors associated with RE implementation have implicitly differential certainty linked to them. To determine if there was a difference in the degree of perceived certainty between the four groups, a one-way unbalanced ANOVA (Analysis of Variance) was carried out using TCI as the response variable. The ANOVA showed a significant difference in TCI between the groups (F = 5.95, df = 3, P < 0.001). The lowest certainty was in the rational-integrationist group, then the subsidy-reliant group with a similar higher certainty in the market-driven and subsidy-reliant groups (Figure 4). These results suggest that the degree of confidence in the future by respondents was related to the RE grouping in which they were clustered. 13
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ACCEPTED MANUSCRIPT Figure 4: Significant differences between Total certainty Index (TCI) for the four groups of renewable energy actors (black error bars denote Standard Error).
The lowest certainty in the RE future was displayed by the Rationalist-integrationist cluster. This might has been due to concerns that the RE sector will unfavourably increasingly compete in the energy mix, that the future importance of some key policy instruments supporting RE are not determined as yet (e.g. instruments controlling GHG emissions and climate obligations) or, most likely, a combination of factors. The second lowest cluster on the certainty axes is the Governance-reliance group which demonstrates relatively lower certainty, maybe created from economic pressures onto governments which pay the subsidies and the shifting balance with energy efficiency programs. The two clusters with the highest certainty (Dynamics-led and Market-driven) are those most closely related to the RE market transition and maturity where there seems confidence that a RE market can develop with appropriate levels of intervention and control to permit a functional and competitive RE market. 4. Discussion During the last years the study of governance gains more and more currency among scholars, especially when it comes to debates in the field of public policies that deal with decentralised systems [33] [34] [35]. The work presented here attempted to identify the degree of coherence between RE expert actor perceptions and link them to the EU push-pull policy dimensions. This is important as the balance of RE policy instruments can help boost or undermine the new EU plans for further RE penetration to the target 27% RE supply. It also helps in indicating the potential of the SET Plan to be adopted as a main instrument of the EU MP/PP approach towards EU competitiveness through RE. Indeed, a detailed analysis of EU RE expert stakeholders determined differences in perceptions, and drivers. The analysis also determined that most stakeholders want a review of EU RE policy (Figure 1) but stakeholder’s perceptions seem to suggest a different path compared to the contemporary EU policy reform process. The pertinence of the push-pull framework for RE policy analysis and the interface between stakeholder’s perceptions and EU policy reform are considered in more detail in the subsequent sections. 4.1 European RE policy and the push-pull framework The push-pull framework has long been applied in marketing and has also been used to suggest how RE policy can be optimised based on interventions using PP or MP instruments. Work from previous authors has suggested that the differential weighting of PP and MP has connotations on the policy outcomes; 14
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ACCEPTED MANUSCRIPT for example, in the degree of RE penetration and efficiency of technology (see Table 1); with MP policies preferentially benefiting more mature and efficient technologies: Albrecht et al. 2015 [22] parametrised the framework, using a practical but somewhat constrained definition of PP, and showed a differential balance of PP and MP aligned to different RE technologies. The aim of the push-pull framework in Albrecht et al., 2015’s work was to help interpretation of the policy balance between MP and PP drivers, and how changes in that balance could affect RE outcomes. Up to 2016, the mix of policies in European climate and energy policy consist most prominently of the EU Emissions Trading Scheme (ETS) on the EU level and additional policies supporting RE at the level of MS. This renewable energy policy of the European Commission, being additively developed over multiple iterations, has been comprised of both PP and MP tools and has created specific benefits in some sectors. In the case of photovoltaic solar systems for example, lower transaction costs, fairly established implementation mechanisms and fiscal incentives have rendered the PV industry attractive for private sector participation. EU policy instruments such as renewable obligations, feed-in-tariffs (FiTs) and generationbased incentives have also specially aided the transformation towards large scale generation, enabling higher efficiency and lower costs of generation [36]. A “pot of gold” has been created through stable and generous subsidies as one way of incentivising entrepreneurs to take on the myriad of issues and uncertainties which need to be negotiated prior to any actual technology being deployed and producing energy. Albrecht et al. 2015 [22] show that the MP/PP financial ratio is about 10 for PV but up to 200 - 500 for biogas, confirming that MP subsidies are the dominant family of policy instruments selectively manipulating the market across a variety of RE techniques, including mature technologies. The above mentioned interpretations identify the tractability of determining the balance of PP and MP. However, the variation in EU actors in the study presented here is primarily related to the degree of intervention or manipulation of the RE sector rather than differential trade-offs between PP and MP (Figure 3). The EC policy has accepted negative assessments [37] as RE technologies are still relatively high cost technologies with high up-front equipment investment and their return on investment is still not competitive compared to traditional methods of energy generation (such as coal and natural gas) [38]. In fact, RE financing has emerged as a significant barrier for sustaining the momentum gained in recent years [36] and even the momentum on research and development suggested by the SET Plan [3]. The high cost of RE technologies is unsettling end-users who ultimately pay the RE financial market incentives and renders expensive the overall cost of climate protection. As Frondel et al., 2012 [39] and Weimann, 2008 [40] predicted, RE subsidies have lowered public acceptance of renewable energies and reduced the political leeway for climate protection in general. RE technologies also need a long-term decision making process involving planning, licensing, construction and issues associated with local opposition. The capital intensity of RE projects means a high proportion of debt service, making them leveraged investments which are inherently vulnerable to regulatory risks [36]. The analysis in this work determined that most stakeholders want a review of EU RE policy (Figure 1) but stakeholder’s perceptions seem to suggest a different path compared to the contemporary EU policy reform process. The MP approach which addressed the lucrative mentality from the developer’s side did not prove very sustainable in terms of RE deployment when subsidies started to get reduced due to present EU financial pressures. On the other hand, the current financial conditions which have made the EU to reconsider its RE policy [41] are likely to continue to exist, if not get worse, and subsidy reduction is likely to increase as the EC recognises RE cost-efficiency as a significant issue inherent in it competiveness agenda [2]. 4.2 European energy actors and the push-pull framework The analysis presented distinguished four types of actors who seem to demonstrate a gradient from where important perceptions are focussed. Those vary from a singular focus just on the RE sector market to where actors have a more expansive notion of RE as just one component of the wider energy and environmental sector. Moving from a focus on the RE market to a wider appreciation of the role of RE, the 15
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ACCEPTED MANUSCRIPT actor types can be termed Market-driven, Dynamics-led, Governance-reliant and Rational-integrationist (see description in Table 5). Based on the discussion above on push-pull dynamics of the European RE market, it would be no surprise if there was a difference in the preferred balance of MP and PP in the different groups; with the focussed RE market driven groups are more fixed on the subsidies emanating from MP compared to the more integrated energy and sector types. However, what is found here is that the balance between PP and MP is not a distinguishing factor for each group and it is only the overall depth of market intervention which is different (see Figure 3). The conclusions from the analyses presented here agree with the results presented from other studies which have examined the RE success of Danish, German and Spanish regions resulting from strong government intervention at the national level supplemented by region-specific strategies [42]. Allied to this gradient in the degree of market intervention are significant differences in certainty that all four groups perceive for the RE future (Figure 4). The highest certainty in the RE sector future is displayed by the Market-driven and Dynamics-led groups, meaning those who look towards functioning markets in a dynamic way. Market-driven and Dynamics-led groups might feel more confident because the focus of EU RE policy has always been based on stronger MP signals, by an order of magnitude or more than PP signals, providing strong investment incentives and profitable ROI. The less certain groups are the Governance-reliant and Rational-integrationist. These groups may have started to lose confidence maybe due to cuts in subsidies [22]. In addition, there has been a move away from RE technology as a single focused sector more towards its role as part of an integrated package of measures linked to climate change adaptation and mitigation. The 2016 “governance of the Energy Union” requires national climate and energy plans to be presented as “integrated” [43]. The inevitable upshot is that RE comes into competition with other mitigation approaches such as energy-saving through analyses such as Marginal Abatement Cost (MAC) curves, thus certainty in the RE sector per se is challenged. The overall RE actor landscape is thus not strongly framed by perceptions which are defined by the balance of PP and MP factors. This degree of favor towards market intervention is also related to the degree of integration in the wider energy markets and the confidence in the future. To visually summaries these interrelationships a conceptual diagram was developed (Figure 5). Figure 5 : A conceptual summary of the interrelationships between the four clusters of EU RE actors and the perceptions on the degree of market intervention, degree of RE sector integration and level of certainty in the future of the RE sector
4.3 RE actor diversity and RE policy reform? The EC Communication on Climate and Energy 2020-2030 [2] and the EC Communication on the implications of the Paris Agreement [4] define the longer term pathway for RE, some of which reflects shifts in emphasis from previous RE policy iterations. These shifts in policy seem to be concomitant with the perceptions expressed by certain of the actor groups, suggesting that the EU RE policy reform has only been 16
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addressing a proportion of the viewsACCEPTED of expert energyMANUSCRIPT stakeholders in its policy reform process. The main EU shifts interpreted in the Proposal for a new Directive [41], the suggested new EU Governance [9] and the Winter Package [10], and which are likely to differentially affect the different RE stakeholder groups are:
Removal of national RE targets. While one EC Communication states that “The transition to a low carbon, resource-efficient economy demands a fundamental shift in technology, energy, economics, finance and ultimately society as a whole” [4], another EC Communication states that the EU will commit to a 27% pan-European RE generation target, which will not be divided up into Member State obligations as in previous policy iterations. Considering this choice as providing “greater flexibility” in meeting targets in the “most cost-effective manner”. Focus on European competitiveness. The EC policy states that “one of the fundamental objectives of EU energy policy is to ensure that the energy system contributes to the competitiveness of the EU economy”. It notes that the competitiveness of business and affordability of energy for consumers are central to the policy and that high levels of competition in the internal energy market will be pivotal to deliver progress. The SET Plan forges progress in this area. Phasing-out of RE subsidies. Although the EU installs or plans to install tools and financial mechanisms such as the European Fund for Strategic Investments (EFSI), the SET plan and the European Investment Project Portal (EIPP) with a purpose to support energy efficiency and low carbon investments in Europe [4], the EU proposes that subsidies for mature RE technology should be “phased out entirely” in the 2020 – 2030 timeframe. Subsidies for “new and immature technologies with significant potential” however, will still be allowed. Streamlining and bringing together national separate energy and climate planning and reporting strands are proposed for the new EU Governance scheme with a view to develop “a reliable and transparent governance system, without any unnecessary administrative burden”.
These substantial changes to the EU-level RE policy mix upscale the policy away from liberalisation of national RE markets that has been underway since the first Directives in early-2000, to positioning RE as one facet of competitiveness and the response to climate change which can be deployed when and where there are benefits to accrue. These developments match the perception of Rational-internationalists and Governance-reliance groups who are related to more integrated energy sectors and lower-levels of market control. However, the EC policy changes also challenges the status-quo which required high EU financial and political investments to be built [44]. The changes also challenge the “Dynamics-led” and “Marketdriven” actors groups which value high-levels of market intervention and rely on the RE market supported with subsidies and isolation from issues such as competitiveness and integration with other sectors. Moreover, further integration across the spectrum of low carbon responses, not just electricity supply in the RE market, can be expected in the post-mass subsidy era after 2020 as ETS is expected to become a more forceful centralised instrument to bring about the transition to a low carbon economy [4]. It is however anticipated that the structural surplus of ETS will continue well into 2020 weakening its position as a technology neutral, cost-effective and EU-wide driver for low-carbon investment [44]. This means that the direction of policy travel is very much towards an integrated pan-European market, and away from local and national manipulations to meet national RE obligations. Again, these expectations in the structural changes in the lower carbon economy match the profile of the Rational-internationalists and Governance-reliance groups. The level of certainty of the actors groups with the focus on the market was higher than those of the groups more focussed on a more integrated market (Figure 5). There have been or course positive changes in the EC policy direction just after the survey presented here, such as the SET Plan coming at the forefront or the proposal for a new EU Governance Scheme. However, it is not guaranteed that all Member-States can follow a MP policy linked to technological competitiveness or a PP approach linked to increase requirements on assessment and monitoring. There is also an unclear landscape towards how to succeed the EU unique target [44]. Those are likely to significantly affect that level of confidence. In fact, these changes 17
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ACCEPTED MANUSCRIPT may be existential to these types of energy actors, who have been the “pioneers” in the historically manipulated and uncompetitive market but averse to the signs of a maturing and more integrated market. The shifts in EC RE policy towards a pan-European EU target, rather than empowering involved actors in decision making who up to now pioneered the EU RE market, may actually lead to a reformulation of the actors involved in the market and a schism in the RE landscape with unknown consequences for the continuing role of RE in the drive for EU competiveness. The EU might have already have had enough of wasting resources monitoring negative national realities when it comes to RE [45] and the EU focus might be more on the electricity end-users. Which, although societally just, the end-users represent an uncoordinated, diverse and fragmented voice, sometimes not well-informed when it comes to energy efficiency issues [46], therefore incapable to further boost the RE market and strengthen allied mechanisms, especially with the long-term ailments of the ETS in gaining market traction.
4.4 Conclusions for policy reformers By 2013, RE was successfully rolled out over different countries and the EU congratulated itself for this achievement [2]. In the work presented here, a sample of RE stakeholders has been benchmarked exactly at that juncture, while the European Commissioner, Mr. Oettinger was expressing some challenging concerns [15]. The results of the survey provide further insight into those concerns from an involved actor’s point of view: -
Who is financing the energy transition? The RE transition has been historically funded by market interventions incorporated in both market pull and policy push approaches. Ongoing market manipulation with equal terms for all State Members would seem to be vital for the RE-sector specialists to stay investing in the sector. Market intervention is ultimately funded by end-users and cost-effectiveness of market manipulation policies are increasingly questioned, especially when RE system fragility becomes uncovered when such manipulation is reduced.
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Will the [current EU RE] approach survive the transition? EU plans for less of a market pull approach and a pan-European RE target will significantly change the actor portfolio. However, many RE stakeholders are only compelled by continuing and guaranteed intervention; otherwise investing “pioneers” might disappear (as in Figure 5). This means that if RE is to grow, then high levels of market intervention need to be continued so as RE gets competitive with other energy fuels (such as fossil fuels) and attractive as a venue for long-term investment capital. On the other hand, if much support is going to be awarded to RE, then this might have negative consequences for European competitiveness as RE is more expensive. A true transition, is not when a market is manipulated enough to achieve a pre-set generation target, but when zero-market intervention supports the EU competiveness agenda.
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What is the right balance between competitiveness, affordability and sustainability? High and balanced levels of MP and PP have been indicated as enabling factors for strong diffusion of efficient technologies; this is the desired outcome for the EU renewable energy policy as well. However, the balance between market pull and policy push approaches is not a discriminating factor in actors who are driving the energy transition. Instead, the predominant discriminating factor between the different stakeholders’ perceptions is the overall degree of market intervention; this suggests an ongoing conflict between competitiveness and affordability. EU citizens, both as electricity end-users and tax payers funding national and EC administrations, are less able to afford continual subsidisation of the RE sector and increased geopolitical tensions create critical tensions for EU policy at this time. However, the EU response seems to be veering towards selecting an “elite” of MS states to take the RE transition forward with a number of MP and PP initiatives [47], [1, p.7], [11]. This is an alternative to further endorsement and support of the proven EU-wide RE pioneers who have dramatically increased RE penetration and permitted the EU to self18
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ACCEPTED MANUSCRIPT congratulate itself [2] on its RE success to date. A two-tier EU may be an effective modality to deliver the 27% RE target but this reflects previous target-based sectoral rhetoric rather than more contemporary aspirations for RE as an instrument for EU-wide competitiveness, economic development and tackling climate change. 5. Acknowledgements The authors would like to thank all the respondents to the questionnaire for their valuable inputs on which this research was based and Victoria Rutherford (Natural Power, UK) for guidance on questionnaire design and implementation. The authors would also like to thank the reviewers for their insight comments in improving this manuscript. 6. References [1] European Commission (EC), 2013. Green paper – A 2030 framework for climate and energy policies, Brussels, 27.3.2013. COM(2013) 169 final, Page 7 [2] European Commission (EC), 2014. Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions: A policy framework for climate and energy in the period from 2020 to 2030. COM (2014) 15 final, {SWD(2014) 15 final}, {SWD(2014) 16 final} [3] Commission of the European Communities, 2009. Investing in the Development of Low Carbon Technologies (SET-Plan). Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions. COM(2009) 519 final. Brussels, 7.10.2009 [4] European Commission (EC), 2016. The Road from Paris: assessing the implications of the Paris Agreement and accompanying the proposal for a Council decision on the signing, on behalf of the European Union, of the Paris agreement adopted under the United Nations Framework Convention on Climate Change. Communication from the Commission to the European Parliament and the Council. COM (2016) 110 final [5] European Commission (EC) 2015. Fact Sheet / Questions and answers on the proposal to revise the EU emissions trading system (EU ETS). Brussels, 15 July 2015. In: http://europa.eu/rapid/press-release_MEMO-15-5352_en.htm [6] European Trade Union Syndicat Confederation, 2016. ETUC position on the structural reform of the EU Emissions Trading System. In: https://www.etuc.org/documents/position-structural-reform-eu-emissions-tradingsystem#.WFp5ZlOLTIU [7 ] Creutzig, F., Goldschmidt, J.G., Lehmann, P., Schmid, E., Von Blücher F., Breyer, C., Fernandez, B., Jakob, M., Knopf, B., Lohrey, S., Susca, T., Wiegandt, K., 2014. Catching two European birds with one renewable stone: Mitigating Climate change and Eurozone crisis by an energy transition. In: Renewable and Sustainable Energy Reviews 38 (2014), Pages 1015–1028 [8] Kasmioui, O. El., Verbruggen, A., Ceulemans, R., 2015. The 2013 reforms of the Flemish renewable electricity support: Missed Opportunities. In : Renewable Energy 83 (2015) [9] European Commission, 2016. Proposal for a regulation of the European Parliament and of the Council on the Governance of the Energy Union. Brussels, 30.11.2016 COM(2016) 759 final 2016/0375 (COD) [10] Linklaters, 2016. European Commission presents Energy Winter Package 2016 [11 ] World leaders and the European Union, 2015. Mission Innovation – Accelerating the Clean Energy Revolution. In: http://mission-innovation.net
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