Preparing a New EU Reference scenario on energy, transport and GHG emissions is an exercise of critical importance. We therefore regret the extremely short time frame provided for this consultation which does not allow us to fully discuss and consolidate the input received. We also regret that no further background information is provided to stakeholders ahead of the consultation meeting. For instance, it is not specified how this data will be used in different scenarios, and what type of scenarios will be developed under which storyline. We understand that costs are a key element for such a modelling exercise, nevertheless regulatory frameworks, political decisions and taking into account societal benefits will also play a prominent role in the development and adoption of some technologies. The assessment has to take into account sociocultural aspects (e.g. acceptance of transport and storage of high volumes of CO2, visual or acoustic impact of generation units, benefits regarding air quality, land use) and some practical limits in potential development (e.g. wave or geothermal energy). It is therefore unclear from this consultation whether these costs will be used in a pure economic optimisation model or whether key qualitative elements will be included to achieve different scenarios. We would welcome that this issue is seriously debated at the consultation workshop.
Furthermore, the figures indicate just one value per technology and per year. As limited information is provided around the datasets, it seems that the figures chosen fail to encompass the diversity of situations. Indeed, it is difficult to understand whether this data set represents an EU average or whether some geographical variations are foreseen. We therefore call for clarification of the following items:
Whether capacity factors apply to new technologies or fleet averages (including already installed capacity).
A reflection of the values diversity of situations that influence investment costs (e.g. soils and sites of plants) and O&M costs, of tax systems and of natural resources (e. g. sunshine, wind speed). Alternatively, it should be specified that they are therefore only indicative and do not reflect the situation in some areas.
Differentiation between existing and mature technologies on the one hand and completely new ones that will emerge after major breakthroughs (e.g. underground storage of hydrogen, CO2 capture from air). The costs of these innovative technologies are highly uncertain and must be used in a cautious way.
The power sector supports a climate neutral Europe by 2050. Going forward electricity will be a key carbon neutral carrier which will help decarbonise other sectors, through direct and indirect electrification.
On the way to 2050 electrification should be further enabled through the relevant infrastructure in other sectors like e.g. charging infrastructure, regulatory framework e.g. PEF and a future proof investment environment for clean technologies.
The price of the commodity is also key in order to allow electrification to happen: freeing up the electricity bill from increasing fixed cost components will enable digitalisation, demand response and active customers’ participation in the electricity markets.
In this context, Eurelectric welcomes the opportunity to comment on the technology and costs assumptions as input to the new EU Reference scenario on energy, transport and GHG emissions. Nevertheless, for this crucial exercise we regret the short consultation period to stakeholders to consolidate their views and provide comments.
Costs are a key element for such a modelling exercise, nevertheless regulatory frameworks, political decisions, physical limitations and societal benefits will also play a prominent role in the development and adoption of some technologies. It is unclear whether the assumptions will be used in a pure economic optimisation model or whether key qualitative elements will be included to achieve different scenarios.
Data sets show just one value per technology and per year, which fails to encompass the diversity of situations such as new versus existing plants, as well as a number of criteria which influence investment costs such as sites of plants, tax systems and availability of natural resources (e. g. sunshine, wind speed). They are therefore only indicative and do not reflect the situation in some areas.
An appropriate regional differentiation for investment costs, learning rates, lifetime calculations or estimated capacity factors should be introduced.
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