One of the most troubling aspects for the wind industry of the EC's proposed revised renewable energy directive is the absence of individual national binding targets.
Responsibility for achieving the aim of at least a 27% share of renewables in gross European energy consumption by 2030 lies at European Union (EU) level.
It does not lie with individual member states, stressed the draft directive, which is part of the mammoth "winter package" titled Clean Energy for all Europeans, released late November.
So what will persuade EU Member States that, for instance, still rely heavily on fossil fuels or nuclear power to do their part to expand onshore and offshore wind energy and other renewables to ensure the 27% is achieved? Will business-as-usual be sufficient?
The 2030 target, of "at least 27%", is not an ambitious one, falling short of the European Parliament's call for 30%. And the EC believes the EU is "well on track" to achieve the binding 2020 renewables target of 20% renewable energy in gross final energy consumption.
Economies of scale and innovation have significantly reduced the related costs. Wind turbine prices, for example, fell by 30% between 2008 and 2015, the EC said.
But the Commission does not consider the business-as-usual approach will deliver in the longer term.
"Modelling shows that the EU is not on track to meeting the 2030 target. A continuation of current measures at Member State level would lead to a likely achievement of just 24.3% in 2030," it stated.
New measures will be required, if only to maintain the 2020 status quo as existing renewables plants reach the end of their technical lifetime.
For the coming decade, the EC insists that national targets set for 2020 should constitute Member States' minimum contribution to the new 2030 framework, and "under no circumstances should the national share of renewables fall below such contribution".
However, questions remain whether the EC has the clout to ensure Member States undertake additional and sufficient measures to 2030.
The proposed governance on this aspect is weak. It is not clear how the evaluation will establish whether or not the EU is on track, pointed out Germany's wind energy association Bundesverband Windenergie (BWE).
Nor is it clear how the "gap-filler" mechanism will work if it emerges that things are not running as they should to reach the 2030 target, the association said.
The Commission stressed binding national targets like those to 2020 will not be an option "as these have been rejected politically".
It also warned that relying solely on national measures would lead to a non-cost efficient and unevenly spread efforts across the EU, leading to an insufficient deployment of renewables "and a falling short of the agreed target".
Integrated plans
However, placing responsibility for target achievement at EU level does not let Member States off the hook.
Their upcoming duties are set out in the new proposed Governance of the Energy Union, a regulation rather than a directive, so it will be immediately applicable and enforceable by law in all Member States.
The Governance said Member States' respective renewables contributions to the overall 2030 target are to be set out and notified to the Commission as part of ten-year "Integrated National Energy and Climate Plans," the first to be delivered by 1 January 2019.
These plans include "trajectories" for the shares of renewable energy in final energy consumption from 2021 to 2030 in the heating and cooling, electricity, and transport sectors.
It will also include a roadmap for total planned installed capacity per technology and sector in MW.
January 2019 will now be a key date for the wind industry as the plans will provide the first firm guidance on the outlook for onshore and offshore wind in EU member states to 2030.
But what if these plans are not achieved during the course of the next decade?
The proposed Governance noted if the linear EU renewables trajectory is not collectively met, Member States "shall ensure that by 2024 any emerging gap is covered by additional measures such as adjusting the share of renewable energy in the heating and cooling sector, and the transport sector, making a financial contribution to a financing platform set up at Union level contributing to renewables energy projects and managed directly or indirectly by the Commission, or other measures to increase deployment of renewable energy".
If a Member State drops below its 2020 baseline level it will make a contribution to the financial platform, the draft Governance stated.
There is no measure of last resort to ensure fulflilment of the 2030 target. But Article 28 of the proposed Governance stated "recommendations" will be issued to the Member State concerned, to ensure achievement of the objectives of the Energy Union. The Member State shall "take utmost account" of the recommendation "in a spirit of solidarity between Member States and the Union".
In other words, all Member States will have been fully involved in developing and signing up to the Energy Union rules, including the considerable inbuilt transition and flexibility arrangements. They will have no excuse not to stick to them.
