Guarantees of Origin and their Implementation in Germany

Michael Börner

German Norwegian Energy Forum 23 October 2012

Guarantees of Origin and their Implementation in Germany

German Norwegian Energy Forum 23 October 2012

German Federal Environment Agency – Umweltbundesamt (UBA)

Central authority on environmental mattersLargest scientific environmental agency (1550 employees)Statutory mandate: Implementation of Environmental Laws

Guarantees of Origin and their Implementation in Germany

German Norwegian Energy Forum 23 October 2012

German Federal Environment Agency – Umweltbundesamt (UBA)

Location: Dessau (Saxony-Anhalt)

Dessau

Guarantees of Origin and their Implementation in Germany

German Norwegian Energy Forum 23 October 2012

Structure

1. Legal Fundamentals2. German GO System3. Issuance and Transfer4. Use and Cancellation5. Import and Export

Guarantees of Origin and their Implementation in Germany

German Norwegian Energy Forum 23 October 2012

1. Legal Fundamentals – European Community LawDirective 2009/28/EC (“Renewable-Energy-Directive“)

Art 2 (j):

• electronic Document• proof that a given share or quantity of energy has a special

quality• Quality = electricity was produced from Renewables• 1 MWh = 1 GO

Guarantees of Origin and their Implementation in Germany

German Norwegian Energy Forum 23 October 2012

1. Legal Fundamentals – European Community LawDirective 2009/28/EC (“Renewable-Energy-Directive“)

Art 15 (1): “ …Member States shall ensure that the origin of electricity produced from renewable energy sources can be guaranteed “Art 15 (2): “To that end, Member States shall ensure that a guarantee of origin is issued in response to a request from a producer of electricity from renewable energy sources “

Guarantees of Origin and their Implementation in Germany

German Norwegian Energy Forum 23 October 2012

1. Legal Fundamentals – German LawRenewable-Energy-Sources Act (EEG 2011)

EEG implements European Community Law (2009/28/EC) Art 55 EEG governs GO in GermanyUBA is competent body

Energy-Industry Act (EnWG 2011)Art 42 EnWG rules electricity labelling in energy suppliers billsUBA-GO must be used for disclosuremandatory only for Electricity from Renewable Sources that was not supported by feed-in tariff or market premium in Germany

Guarantees of Origin and their Implementation in Germany

German Norwegian Energy Forum 23 October 2012

2009/72/EC2009/28/EC

RES-Act (EEG) Energy Industry Act

HkNV

Herkunftsnachweis-Durchführungsverordnung (Executive regulation)

Fee regulation (HkNKostV)

Outline Legal Fundamentals German GO System:

Guarantees of Origin and their Implementation in Germany

German Norwegian Energy Forum 23 October 2012

2. Outline German GO System:

Guarantees of Origin and their Implementation in Germany

German Norwegian Energy Forum 23 October 2012

3. Issuance and Transfer of GO

scheme of GO in Germany is voluntary for plant operators• either GO• or EEG-feed-in tariff or market premiumfor reasons of correctness of the register • some plants need an audit by environmental auditors• UBA issues on electricity production data of grid operators

GOs are tradable • trading activities in Germany, European Union, European Economic

Area (= Norway) and Switzerland

Guarantees of Origin and their Implementation in Germany

German Norwegian Energy Forum 23 October 2012

4. Use and Cancellation of GO

Basic rule: GO in Germany “has the sole function of providing proof […] for the purpose of electricity labeling […] that a given share or quantity of electricity was produced from renewable energy sources” (Art 3 Nb 4c EEG)

Use:Declaration of an energy supplier… … to use GO for the disclosure of a specific amount of electricity in a specific yearUse only for calender year of electricity production

Guarantees of Origin and their Implementation in Germany

German Norwegian Energy Forum 23 October 2012

4. Use and Cancellation of GO

Basic rule: GO in Germany “has the sole function of providing proof […] for the purpose of electricity labeling […] that a given share or quantity of electricity was produced from renewable energy sources” (Art 3 Nb 4c EEG)

Cancellation:must be requested when GO is usedcancelled GO cannot be transferred or used anymore

Guarantees of Origin and their Implementation in Germany

German Norwegian Energy Forum 23 October 2012

4. Use and Cancellation of GO

Only energy suppliers are allowed to use and cancel GOEnergy suppliers need their own account, but can make use of service providers

Production period: 1 monthLife period: 12 months after end of production period

Guarantees of Origin and their Implementation in Germany

German Norwegian Energy Forum 23 October 2012

5. Import and Export

Art 15 (9) Directive 2009/28/EC: “Member States shall recognise guarantees of origin issued by other Member States in accordance with this Directive […].”

Germany will recognise GO from EU, EEA and Switzerland, when in line with Directive 2009/28/EC

• no well-founded doubts about accuracy, reliability or veracity• safe and reliable GO system in exporting country• electricity is not disclosed as Renewable Energy in exporting

country

Guarantees of Origin and their Implementation in Germany

German Norwegian Energy Forum 23 October 2012

5. Import and Export

UBA-register is only for GO for Electricity from Renewable SourcesNo other renewable energy cerficates acceptedNo certificates for fossil, nuclear or other forms of energy

technical implementation: in discussion with AIB about conditions of using AIB hub for international transfer

Guarantees of Origin and their Implementation in Germany

German Norwegian Energy Forum 23 October 2012

5. Import and Export – Role of Norway

Source: AIB Newsletter, Vol 5, 06.07.2012

Guarantees of Origin and their Implementation in Germany

German Norwegian Energy Forum 23 October 2012

5. Import and Export – Acceptance of Norwegian GO

Avoidance of double counting of GO

GO in Norwegian register can be transfered to a foreign country, although they were already used for the residual mix calculationPossibilty that these GO were used again for disclosure in a foreign country (double counting)

Flanders regulator refused Norwegian GO that were exported after being used for Norwegian electricity disclosureRecommendation: export to Germany should be finished before the date of usage in Norwegian register (28 February)

Guarantees of Origin and their Implementation in Germany

German Norwegian Energy Forum 23 October 2012

German Register for Guarantees of Origin for Electricity fromRenewable Sources – Herkunftsnachweisregister (HKNR)

www.hknr.de

Guarantees of Origin and their Implementation in Germany

German Norwegian Energy Forum 23 October 2012

Thank you for your attention!