Høringssvar - EUs Net Zero Industry Act

Planen kom som en reaksjon på den store subsidieplanen Inflation Reduction Act i USA, som skal pumpe store summer i utbygging av fornybar teknologi. I tillegg har gasskrisen og krigen I Ukraina gjort EU bevisst på faren ved å bli for avhengig av tredjeland. I dag har Kina nærmest monopol på mange av de råvarene som er helt nødvendig for det grønne skiftet, og de ligger langt foran Europa i grønn teknologi. Forslaget ønsker å styrke Europeisk industri, samt gjøre Europa mer motstandsdyktig i et skiftende geopolitisk klima.

EU-Kommisjonen hadde en høring åpen fram til 27. Juni, som vi svarte på. Ellers er saken til behandling i Rådet og Parlamentet i EU. De arbeider parallelt med sine posisjoner, før de skal forhandle seg imellom om et vedtak, som er ventet i første kvartal 2024. 

Under kan du lese Fornybar Norges posisjon til lovforslaget.

Renewables Norway input for the legislative proposal on the Net Zero Industry Act

Brussels, June 2023

Renewables Norway welcomes the focus of the EU on green industrial development, and we share the ambition to build competitive and sustainable supply chains in Europe. Norway can contribute significantly to the European green industry agenda. Net Zero Industry Act is an import step towards securing more competitiveness for the European green industrial development and securing supply lines for the European renewable energy sector. We have a huge deficit in energy infrastructure assets, and we need more clarity on the supply of components for building up capacity. We support following a market-based approach to secure efficient tendering and auctioning, in line with environmental and resilience needs.

We have some assessments for the political process going forward.

Firstly, hydropower must be defined as a Strategic Net-Zero Technology. The annex to the legislation, that specifies prioritized strategic technologies, lists several good and relevant project types, including wind and solar power. These technologies will receive priority treatment within the scope of the legislation.

Unfortunately, hydropower is not defined as such a technology. Europe needs a significant share of hydropower to achieve a net-zero energy system, both because of its renewable properties and flexibility of energy supply. It is necessary to support the supplier industry for necessary components for maintenance, upgrading, and development also for the competitiveness of hydropower.

Secondly, the push to being more self-reliant in European green industrial development is well-founded and important but must not work against its purpose.

It is important to strengthen European value chains, and the whole renewable energy sector will benefit from a strong and competitive European supply chain, especially in the current geopolitical climate. However, we acknowledge that some current projects are reliant on existing external supply lines, so there is a need for a balanced approach in the shorter term, to avoid delays on the large and necessary expansion of renewable energy.

Thirdly, we will address the proposal for "local content" as a criterion in public procurement of renewable energy. Generally, we recognize the political need to strengthen offshore wind as a European sustainable industry. We strongly support the use of non-price criteria in offshore wind auctions, and welcome measures to ensure that auctions help develop sustainable European supply chains. We would like to underline that it is in our common interest, that EU and Norwegian industrial value chains within renewable energy are treated as equals.

It is unclear how the "resilience" criterion of 65% should be assessed and calculated, and it must be specified whether it applies at the component level or project level. Some technologies have little local content to begin with, such as solar and batteries.

In addition, it is important that Norwegian suppliers and other market participants can join the tendering and auctioning processes that are proposed, from the start. This market participation must follow the European Economic Area. Otherwise, we may risk that Norwegian supplier industries will not be able to compete on equal terms on the resilience criterion, with a mutually detrimental effect. Offshore wind is a prominent example of a sector where Norwegian supply chains can prove valuable to Europe as a whole.

Finally, a consideration of Norwegian participation in the Net Zero Industry Platform. Some EU countries are pushing for more industrial subsidies. With the emerging industrial positioning between major global market areas, it is crucial that Norway is connected to the European green industrial initiatives and are regarded as internally recognized industries in Europe. Norway has great technological know-how and vast experience from the energy sector, especially, but not limited to offshore wind and hydro power, which could significantly contribute to the European green industrial development.

The Net Zero Industry Platform will be the governance structure for member countries. An important question for us is to what extent we can participate in this structure through the EEA agreement.