In a series of prior blog posts, we previously highlighted the historic implications of the Inflation Reduction Act (IRA) for the U.S.'s international climate commitments, as well as for private companies navigating the energy transition. Shortly after our series published, the Senate passed the IRA on Sunday August 7th with only minor modifications to the bill's $369 billion in climate and clean energy spending. Today, the House passed the IRA without any further changes, and soon hereafter President Biden is expected to sign it into law.
However, this is only the beginning of the road!IRA四角将产生广度效果。 未来数月和数年中,我们期望看到对机构规则的强力操纵将决定IRA实施,并判定它作为能源策略的最终成功
As an initial matter, it seems Congress has not finished its work revamping the nation's climate and energy laws. As part of his agreement to support the IRA, Senator Joe Manchin (D-WV) announced that "President Biden, Leader Schumer and Speaker Pelosi have committed to advancing a suite of commonsense permitting reforms this fall that will ensure all energy infrastructure, from transmission to pipelines and export facilities, can be efficiently and responsibly built to deliver energy safely around the country and to our allies." While the exact contours of this legislation are not currently known, Senator Manchin's office recently released a legislative framework, which includes proposals to, among other things:
- tighten environmental reviews under the National Environmental Policy Act (NEPA);
- clarify the permitting and regulatory authorities of the Department of Energy and the Federal Energy Regulatory Commission;
- reform Clean Water Act provisions that allow state and local governments to impose additional requirements on federal permits!and
- create a list of strategically important energy projects, that the President can designate and periodically update, for streamlined permitting reviews.
According to Senator Manchin's office, permitting reform will receive a vote before the end of the fiscal year on September 30, 2022. Unlike the Inflation Reduction Act, which passed through arcane rules of reconciliation—and thus required only a simple majority—permitting reform will be subject to the Senate filibuster and require the support of at least 60 senators (and bipartisan agreement) to become law. At the moment, it is unclear whether broad bipartisan support exists for this measure!some Republicans have publicly signaled skepticism, and environmental activists have long opposed expedited fossil fuel permitting.However, in the past Republican Senators have expressed an interest in speeding the nation's permitting system. During this Congress, a bipartisan group of Senators introduced a law to accelerate infrastructure permitting, and all Republicans and Senator Manchin supported a resolution to disapprove of recent revisions to NEPA. Together, these actions suggest there may be some interest within the Republican caucus in implementing meaningful changes to current law, partisan divisions notwithstanding.
II.万博体育app手机登录减通货膨胀法关键赋值指南 外加,IRA本身有几部分未来数月将通过行政引导和规则制定过程予以澄清和实施守法标准支付工资、学徒和家用内容要求并计算温室气体排放法新税抵免 。
ahrfss/www.insideEnergyandense.com/2022/07/enger-support-for-电机-车-车-车-门-电-电-电-电-电-电-电-电-电-电-电-电-电-电-电-电-电-电-电-电链/>这些规定并不适用于商业电车信用分量 。 具体地说,法律要求电电池组件的一定比例为“制造或组装北美 ”, 并适用百分比逐年变化 。 法律还要求电池中关键矿产品中一定比例为“提取或处理 ”, 在美国或与美国相邻的任何国家中实现“提取或处理 ” 。IRA § 13401(e).鉴于电车供应链的现状,预计许多汽车制造商难以满足这些外包需求万博体育app手机登录
However, key features of these clean vehicle credits have yet to take shape. By the end of this year, the IRA requires the Treasury Department to issue regulatory guidance to help shape and administer the battery and mineral sourcing requirements. Id. Among the questions open for interpretation are acceptable methods for calculating the "percentage of the value" for critical mineral and battery components, as well as better defining the terms "manufacture or assembly" and "extraction or processing." How Treasury addresses these points will have significant ramifications for the short- and medium- term value of the clean vehicle credits.
A much broader set of IRA tax credits seek to promote investment in, and use of, clean electricity, but their value depends on the interpretation of key labor and domestic content requirements. As currently structured, the IRA extends and modifies the Investment Tax Credit and Production Tax Credits that apply to certain renewable sources of power through the end of 2024. Id. §§ 13101, 13102. Beginning in 2025, similar projects will also be eligible for a new technology-neutral Clean Electricity Production Credit and a Clean Electricity Investment Credit, which apply to any domestically produced electricity source with a greenhouse gas emissions rate of zero. Id. §§ 13701, 13702. These credits, and others throughout the IRA, are keyed to the satisfaction of prevailing wage and apprenticeship requirements.
Specifically, if these wage and apprenticeship requirements are not satisfied the credits are worth five times less than they otherwise would be. Additionally, the IRA creates a 10% "domestic content bonus" when facilities certify that certain percentages of steel, iron, and other manufactured products used in the facility are made in America, and further increases the value of the credit for projects located in "energy communities," i.e.棕田网站或经济困境前化石燃料生产网站解释应用将极大影响政府可用支持值。 未来清洁能源项目必须注意确保适当文档并遵守这些条款Finally, many IRA tax credits are pegged to a demonstration of the life-cycle emissions of the underlying facility or fuel. For instance, the value of the clean hydrogen credit varies based on the project's "lifecycle greenhouse gas emissions rate." On the high end, a 100% credit value is awarded to projects with a lifecycle emissions rate of less than .45 kilograms (kgs) of carbon dioxide equivalent (CO2e), but on the low end, projects only receive 20% of the credit value if their emissions rate is between 4 and 2.5 kgs of CO2e. Id. § 13204. Additionally, the availability of the new credit for sustainable aviation fuels depends on a certification that the applicable fuels achieve at least a 50% life cycle greenhouse gas reduction percentage compared to petroleum-based jet fuel!燃料项目再为生命周期温室气体排放量增量百分比增量增益Id.
The full implications of the IRA are yet to be understood. The law is likely to have significant implications for our energy future, leading to sharp growth in the nation's clean energy production and a decline in national greenhouse gas emissions. Though we have laid out some initial consequences, there are undoubtedly many more interpretive questions that will arise in the coming weeks, months, and years. Additionally, by subsidizing and lowering the costs of clean electricity and other low-emissions technology, the IRA could improve the benefit-cost analysis for a variety of environmental regulations, leading to more stringent and durable rules. Further, by bolstering the domestic energy industry, the IRA could alter the political economy of climate policy, creating a broader base of support for future government investments in clean energy production or greenhouse gas curtailment. Regardless of how this future unfolds, it will surely be a dynamic time for energy and environmental law and policy.
The revised TEN-E Regulation 2022 continues to work towards developing better connected energy networks while updating the TEN-E framework to focus on the latest environmental targets and ensuring consistency with the climate neutrality objectives set out in the EU Green Deal.
Towards a better integrated and greener EU energy market
The TEN-E Regulation 2022 reallocates and identifies 11 priority corridors with the purpose of meeting objectives to (i) reduce carbon emissions by 55% by 2030 and (ii) achieve carbon neutrality by 2050.优先通道侧重于更新基础设施类别,如近海电网通道和可再生和低碳气体,如氢解电机天然气基础设施和石油管道将不再有资格获得PCI状态TEN-E条例2022还确定了新的优先专题领域:(一) 采行配有IT技术(“智能电网”)电气网络;(二) 开发跨边界二氧化碳网络。
/p>能源基础设施项目proto侧重于推广绿色清洁能源的项目可获取PCI状态,如近海风能和可再生/低碳氢化注解氢或可混入其他气体(如天然气或生物甲烷)或自成一体的能源源TEN-E第2022号条例也鼓励智能电网和二氧化碳运输存储的PCIs 。补充地说,TEN-E第2022号条例将欧盟能源市场边界扩展至第三国,为所谓的互利项目引入新合作机制与PCIs相似,如果他们为欧盟总体能源和气候政策提供保障和去碳化服务,可选择它们。
欧盟委员会将每两年通过PCIs和PMIs清单(“EU链表”),第一批欧盟链表将在2023年11月30日前通过。
TEN-E规范2022还为欧盟链表中所有项目规定了新义务PCIs和PMI必须满足强制可持续性标准,并依照举例说,估计耗资8 000亿欧元提高近海可再生能源的摄取量,根据欧盟绿色交易目标,其中三分之二将用于相关电网基础设施。电力传输配电网单实现2030目标每年估计平均投资505亿欧元。
并举,帮助支付巨额费用,欧盟清单上的PCIs和PMIs可能有资格获得财政援助:
连接欧洲机制下Finance支持On April 20, 2022, the cybersecurity authorities of the United States, Australia, Canada, New Zealand, and the United Kingdom—the so-called "Five Eye" governments—announced the publication of Alert AA22-110A, a Joint Cybersecurity Advisory (the "Advisory") warning critical infrastructure organizations throughout the world that the Russian invasion of Ukraine could expose them "to increased malicious cyber activity from Russian state-sponsored cyber actors or Russian-aligned cybercrime groups." The Advisory is intended to update a January 2022 Joint Cybersecurity Advisory, which provided an overview of Russian state-sponsored cyber operations and tactics, techniques, and procedures ("TTPs").
In its announcement, the authorities urged critical infrastructure network defenders in particular "to prepare for and mitigate potential cyber threats by hardening their cyber defenses" as recommended in the Advisory.
Overview. The Advisory notes that "evolving intelligence" indicates that the Russian government is exploring options for potential cyber attacks and that some cybercrime groups have recently publicly pledged support for the Russian government and threatened to conduct cyber operations on behalf of the Russian government. The Advisory summarizes TTPs used by five state-sponsored advanced persistent threat ("APT") groups, two Russian-aligned cyber threat groups, and eight Russian-aligned cybercrime groups. Additionally, it provides a list of mitigations and suggests that critical infrastructure organizations should implement certain mitigations "immediately."
Russian State-Sponsored Cyber Operations. The Advisory notes that Russian state-sponsored cyber actors have "demonstrated capabilities" to compromise networks!保持长期持续访问网络从信息技术网络和操作技术网络排出敏感数据并使用破坏性恶意软件干扰关键工业控制系统及OT网络咨询详解俄罗斯APT五大类:
Russian Foreign Intelligence Service ("SVR"): SVR has likewise targeted multiple critical infrastructure organizations, although the Advisory does not specify the sectors in which these organizations operate. SVR's TTPs include custom and sophisticated malware targeting Windows and Linux systems and lateral movement within a compromised network that can bypass multi-factor authentication ("MFA") on privileged cloud accounts. The U.S., UK, and Canada have attributed the SolarWinds Orion supply chain compromise to the SVR.
Russian General Staff Main Intelligence Directorate ("GRU"), 85th Main Special Service Center ("GTsSS"): GTsSS primarily targets government organizations, travel and hospitality entities, research institutions, non-government organizations, and critical infrastructure entities. Its TTPs include harvesting credentials to gain access to targets via spear phishing emails and spoofed websites that trick users into entering their account names and passwords.
GRU's Main Center for Special Technologies ("GTsST"): GTsST is known to target critical infrastructure entities, including those within the Energy, Transportation, and Financial Services Sectors, as well as member states belonging to the North Atlantic Treaty Organization ("NATO") and Western governments and military organizations. GTsST is particularly known to use destructive or disruptive attacks, such as distributed denial of service ("DDoS") and wiper malware.
Russian Ministry of Defense, Central Scientific Institute of Chemistry and Mechanics ("TsNIIKhM"): TsNIIKhM is known publicly as a research organization in the Russian Ministry of Defense, but the Advisory notes it has developed destructive ICS malware, known as Triton, HatMan, and TRISIS.
Russian-Aligned Cyber Threat Groups. The Advisory addresses two state-sponsored cyber threat groups: PRIMITIVE BEAR and VENOMOUS BEAR. The former is known to target Ukrainian organizations and the latter is known to target NATO governments, defense contractors, and "other organizations of intelligence value." Notably, the Advisory explains that none of the governments responsible for the Advisory have formally attributed either of these groups to the Russian government, but nevertheless seems to recognize that these groups are aligned with the Russian government.
Russian-Aligned Cybercrime Groups. The Advisory details eight cybercrime groups aligned with the Russian government. The Advisory notes that these groups are often financially motivated and pose a threat to critical infrastructure organizations throughout the world, primarily through ransomware and DDoS attacks. The Advisory notes that while these groups "may conduct cyber operations in support of the Russian government ...网络犯罪分子极有可能继续主要基于金融动机运作,这可能包括攻击政府和关键基础设施组织。
MUMMY SPIDER: This group operates an advanced, modular botnet, known as Emotet, which primarily functions as a downloader and distribution service for other cybercrime groups. Emotet has been used to target "financial, e-commerce, healthcare, academia, government, and technology organizations' networks" throughout the world.
SALTY SPIDER: This group also operates a botnet, known as Sality, which uses advanced peer-to-peer malware loaders. SALTY SPIDER has conducted DDoS attacks against Ukrainian web forums discussing the Russian invasion of Ukraine.
SCULLY SPIDER: This group operates a "malware-as-a-service" model, which includes maintaining a command and control infrastructure and selling access to its malware and infrastructure to affiliates. SCULLY SPIDER also operates the DanaBot botnet, which effectively functions as an initial access vector for other malware and can result in ransomware deployment. The group primarily targets organizations in the United States, Canada, Germany, United Kingdom, Australia, Italy, Poland, Mexico, and Ukraine.
SMOKEY SPIDER: This group operates a malicious bot, known as Smoke Loader or Smoke Bot, which is used to upload other malware. The group's bot has been used to distribute malware payloads used in DDoS attacks against Ukrainian targets.
WIZARD SPIDER: This group develops TrickBot malware and Conti ransomware. This group has targeted construction and engineering companies, legal and professional services, manufacturing, retail, U.S.healthcare, and first responder networks, and has publicly pledged support to the Russian government, threatened critical infrastructure organizations of countries perceived to "carry out cyberattacks or war against the Russian government," and threatened to "retaliate against perceived attacks against the Russian people."
The Xaknet Team: The Xaknet Team has only been active since March 2022 and has stated they will work "exclusively for the good of [Russia]." The group has threatened to target Ukrainian organizations in response to perceived attacks against Russia and, in March 2022, leaked emails of a Ukrainian official.
Mitigations. The Advisory provides several mitigations that it recommends critical infrastructure organizations implement "immediately": (1) updating software!最大可能执行MFA并需要强密码安全监控远程桌面协议并(4)提供终端用户对潜在网络威胁的认识和培训。
a咨询还建议关键基础设施组织维护者“在识别潜在恶意活动指标时努力克尽职责”,并在检测APT或绑定软件活动后采取具体步骤。
这些步骤包括:(1)立即隔离受影响的系统识别阻塞疑似攻击者IP流量,允许防火墙速率限制,通知组织互联网服务提供人和远程触发黑洞安全备份(4) 收集并审查相关日志、资料和人工品(5)考虑加入第三方IT组织并(6)向适当的网络和执法当局报告事件。咨询还“强烈劝阻”向犯罪方支付赎金,指出支付并不总能成功恢复受害者的档案,这种支付可能“鼓动对手攻击更多组织,鼓励其他犯罪方分发赎金件和/或资助非法活动。”
As the world struggles to adjust to the harsh new reality of Russia's invasion of Ukraine, the most recent instalment of the Sixth IPCC Report slipped out almost unnoticed. And that is worrying, since the assessment in this section of the Report is even starker than previous assessments – noting in particular that in order to avoid global temperatures increasing by greater than 1.5 degrees C above preindustrial levels, the world needs to halve its emissions this decade: a reduction that the world does not currently appear to be remotely on course to do.
However, whilst the IPCC Report and the Russian invasion of Ukraine are not linked, Russian aggression in Ukraine may serve as a catalyst to speed up the European energy transition and accelerate its retreat from dependency on Russian gas and exposure to volatile international oil markets, which could in turn deliver a more rapid reduction in European emissions. In the process, perhaps setting the world on a path to achieving an outcome that currently seems unattainable.
What is the IPCC Report?
The Intergovernmental Panel on Climate Change (IPCC) is a panel of the world's leading climate scientists. The Panel publishes regular updates of global knowledge on the climate crisis.更新设计帮助政府决策。更新内容非常全面,每次需要5至7年完成The current Report is the Panel's Sixth Report since its establishment in 1988, and commentators have noted it may be the last to be published while there is still some chance of avoiding the worst impacts from climate change.
This Sixth Report is being released in four parts between August 2021 to October 2022. The first part examined the physical basis of climate science (how the atmosphere is changing – and will change – and whether human influence is responsible). The second part, which was released on 28 February, assesses the effects of climate change, such as extreme weather, droughts, floods and temperature rises, and how best to adapt to these changes[i].
What does the Second Part Say?
The conclusions of the most recent instalment of the Sixth Report make for sobering reading:
- The risks associated with lower levels of warming are greater than the previous 2014 IPCC adaptation assessment had concluded;
- The window to adapt to climate change is "brief and rapidly closing";
- The impacts on human systems, natural systems, and ecosystems are more widespread and accelerating;
- Ecosystems are reaching the limits of their ability to adapt to the changing climate, and the effectiveness of adaptation will decrease with increasing warming;
- Some losses are already irreversible;
- Sea-level rise is already inevitable, posing an existential threat for some small islands and increased vulnerability for infrastructure, including ports and energy systems;
- Up to 1bn people could be at risk from coastal flooding by 2060;
- Half the world's population live in areas that are "highly vulnerable" to climate change;
- Even at 1.5 degrees or less, 8% of current farmland will become unproductive.
Given that the world has already warmed by 1.1 degrees since the pre-industrial period and that there is a lag in the world's climate response to emissions, it is likely that the world will warm by 1.5 degrees within 20 years, even if deep greenhouse gas emissions cuts are achieved.COP26多次表示,本十年是决定性的十年:2030年前排放量必须减半,世界才有机会保持在1.5度以下变暖状态。
/p>若不将全球变暖限制在1.5度以下,将触发冰帽和冰川融化的灾难性链反作用增加野火和树死accelerating peatland dry-out and permafrost thaw – all of which would release additional carbon emissions further accelerating global warming.
The Report identifies five areas as priorities for future climate adaptation. One of those areas is the reform of energy systems, where the Report makes a number of recommendations:
- Energy generation diversification.
- Improved demand-side management through better storage, and energy efficiency.
- Climate responsive energy markets, smart-grids, robust transmission systems, and improved supply-deficits response capacity.
So How is the Russia-Ukraine Crisis Relevant?
A Commission Communication ("Joint European Action on Affordable, Secure and Sustainable Energy") was due for release on 2 March!however, the Commission has announced a delay to the publication in order to revise it in light of the Ukraine crisis. A leaked draft of the original Communication set out a number of recommendations that were very closely aligned to the IPCC Report recommendations set out above – though the Communication's conclusions were motivated as much by geopolitical and economic, as climate change factors.
It is likely that Putin's aggression in Ukraine will shift the focus of the redrafted Communication to an accelerated switch to renewables, which would also help deliver against the IPCC Report's demands. In his twitter feed, Commission Vice President Timmermans noted on 28 February: "It's time we tackle our own vulnerabilities.以闪电速度跳入可再生能源我们自己清洁廉价无穷能量越快移动,越快减少对他人依赖度,我们站在一起越强。
Whilst远非唯一文件显示欧盟通向2050NetZero目标,尽管即将修改,看通信初始草稿仍然有启发作用,它清楚地表明欧盟从依赖俄罗斯燃气向可再生能源过渡的方向。
EU40%的能源需求依赖俄罗斯燃气并承认迫切需要减少这种依赖度,甚至在俄国入侵乌克兰前都如此。文稿表示:“欧盟仍然高度依赖能源进口发电加热This is the case in particular as regards gas, where we rely on imports for 90% of our consumption… This dependency has aggravated the current situation of high energy prices."Even before the Ukraine crisis, the draft Communication was crystal clear on the dangers of European "dependence on a single supplier of fossil gas" demanding "diversification of gas supply and using the full potential of green and low carbon energy sources" including increasing the use of LNG to "reduce our dependence on imported Russian gas and strengthen security of supply."
The draft Communication argued that "[s]ustained high energy prices are impacting the entire economy….廉价燃气价格.使可再生清洁能源投资更有利可图,这意味着“快速清洁能源过渡需求从来就没有更强和清晰”,提高燃气价格缩短了“从易变化石燃料向更廉价可再生能源技术过渡的回溯时间.减少对进口依赖并推倒物价”。
通信草案以这一结论为基础,侧重于能源多样化的重要性通信草案反射气专委报告的结论,就如何增加使用太阳能和促进生物量和氢量生产提出若干建议文中称快速提高可再生发电能力“是我们能源向2050年去碳化过渡的关键”,并称它为“终端使用部门电气化和再生氢生产之工具”,并补充多样化是减少该大陆对俄罗斯天然气过度依赖的最有效方式。通信草案建议多项需求方响应,包括提高能效清除监管屏障加速天然气存储投资The motivation may be different – "to make Europe less vulnerable to fluctuations on the fossil fuel markets" – but the sense of urgency is the same "as soon as possible."
Once again, mirroring the IPCC's conclusions, the draft Communication proposed an "ambitious combination of funding and regulatory measures [to] accelerate the green transition." Although it does not feature in the original Communication, it would not be a surprise to see the amended version place an expanded role for nuclear power as a green alternative back on the agenda again – not least given the recent announcement by the German Government that they would consider postponing the decommissioning of German nuclear reactors as part of the national response to the Russia-Ukraine crisis.
Conclusion
Although perhaps reached for different reasons, the conclusions of the IPCC Report and the Commission are identical: an accelerated shift away from dependence on hydrocarbons for energy and an increased focus on the rapid deployment of renewable energy is essential. For the EU, the shift is necessary not only for climate change reasons, but also for its long-term political, economic and social well-being.
The EU was already heading down the renewables path: the Russian invasion of Ukraine will accelerate that process in the medium- to long-term and will force the EU to seek other sources of natural gas in the short-term. The process of seeking new sources of gas will have an impact on global gas prices, which will in turn further accelerate the global shift to an increasing reliance on renewable energy.
No one should be under any illusion that the energy transition will be rapid, pain-free, or easy, but the EU's experience with dependence on Russian gas demonstrates clearly one of the real geopolitical vulnerabilities of continuing to rely on the existing model.
Covington's mixed teams of regulatory and public policy experts are uniquely placed to advise clients on how to navigate the turbulent geopolitics of international relations and their impact on the energy transition.
We would be happy to discuss with you how these complicated inter-relationships may affect your company and your business.
[i] The report of the third working group, which will examine how to cut emissions, will be released at the end of the second quarter.第四即最后一次工作组报告综合其他三个工作组报告的结论,将于10月在COP27前发布-定于2022年11月举行。
援救市场失效阻碍实现足够程度的环境保护或高效内部能源市场援助的适当性,即目标是否无法通过替代措施实现(充分)基于市场工具,如排放交易机制或偏差性小辅助工具(例如可偿还预付直接授标援助的相称性,即援助是否限为最小需求, 即实现援助量度目标所需净额外成本透明性援助,即或公诸于世(v) the avoidance of undue negative effects of the aid on competition and trade, considering the distortive effects on competitors that likewise operate on an environmentally-friendly basis, and it will (vi) weigh up the positive and negative effects of the aid, paying attention to the sustainability of the activity and in particular that it ‘does no significant harm' to environmental objectives.
These assessment criteria are further elaborated for each specific category of aid.
Categories of aid that can be assessed under the CEEAG
Most of the categories of environmental protection and energy measures falling in the scope of the previous EEAG are covered by the CEEAG in a much larger fashion.These categories relate to support:
- for the reduction and removal of greenhouse gas emissions including through support for renewable energy and energy efficiency;
- for the improvement of the energy and environmental performance of buildings;
- for resource efficiency in respect of which the CEEAG also cover the transition to a circular economy, beyond the mere waste management foreseen in the EEAG;
- reductions in taxes or parafiscal levies where these taxes or levies aim at sanctioning environmentally harmful behaviour but create such a competitive disadvantage that it would not have been feasible to introduce them in the first place without having foreseen reductions for certain companies;
- for district heating and cooling, including highly-efficient cogeneration;
- for the security of electricity supply, extending to storage or demand response, interconnection, as well as network congestion measures, the possibilities initially offered under the EEAG to support generation adequacy;
- reductions for energy-intensive users from electricity levies.前EEAG下,有可能削减旨在为可再生能源支持筹资的收费。With the CEEAG, possible reduction can apply to levies aimed at the broader goal of funding decarbonisation;
- for studies or consultancy services on matters relating to climate, environmental protection and energy, whereas the EEAG only covered environmental studies;
- for the remediation of environmental damage, which constitutes a larger possibility than the aid for the remediation of contaminated sites under the EEAG.
The CEEAG further extends the list of measures that can be aided to support:
- for clean mobility:
- for the acquisition and leasing of clean vehicles (used for air, road, rail, inland waterway and maritime transport) and clean mobile service equipment and for the retrofitting of vehicles and mobile service equipment;
- for the deployment of recharging or refuelling infrastructure for clean vehicles;
- for the prevention or the reduction of pollution other than from greenhouse gases;
- for the rehabilitation of natural habitats and ecosystems, the protection or restoration of biodiversity and the implementation of nature-based solutions for climate change adaptation and mitigation;
- reductions in taxes or parafiscal levies, to encourage undertakings to change or adapt their behaviour by engaging in more environmentally-friendly activities;
- for the closure of power plants using coal, peat or oil shale and of mining operations relating to coal, peat or oil shale extraction.
Whereas previously investment aid for large airports (more than 5 million passengers per year) could only be authorised in exceptional circumstances, such as relocation of an existing airport, aid for large airports would now be authorised also where the purpose of the aid is to improve environmental protection.
Nuclear energy remains outside the scope of the CEEAG, because it relates to limited but very large projects, subject to the EURATOM Treaty.核电援助直接依据条约条款评估 。
Covington团队将继续监控开发并随时更新
苏格兰政府热切地确保现有(碳氢化合物)部门就业者得到再技能和再生部门提供的机会,可再生能源价格可承受苏格兰水电部门将在支持这一过渡方面发挥重要作用,计划要求苏格兰政府评估如何为碳密集部门工人创建长期“技能保证”。Plan还突显苏格兰成为欧洲低成本氢矿生产者的潜力苏格兰政府将在2022年能源策略和公正过渡计划中更详细地说明其方法。
This money will fund FEED studies for large-scale renewable Hydrogen production projects with a view to making full investment decisions later in the decade.
The Scottish Government wants to use the £100m fund as a means to accelerate as many projects as possible from pilot stage to large scale commercial and has hypothecated £10m to prioritise innovation and research through the creation of the Scottish Hydrogen Innovation Fund, which will be launched early in 2022.
The remaining £80m of the EETF will fund the development of carbon capture, utilization and storage technologies – suggesting that the Scottish Government views blue Hydrogen as an important element of its Hydrogen revolution.
Timeline
The Plan sets out detailed action points until the end of 2026.苏格兰政府期望到2026年大规模氢生产基础设施到位,与大规模碳捕获存储相联(super>CCS )以及岸上和近海风开发。
计划还提出了2045至2045年Hydrugen经济路径图苏格兰的目标是到2035年实现100%可再生电运营,同时增加向英国和欧洲其他地区的氢输出量In the 2040s, the Scottish Government aims to have capacity to produce 25 GW of Hydrogen and to be established as an enduring and reliable exporter of Hydrogen to Europe.
Underlying Themes
- Strategic Scotland – the Plan stresses Scotland's ideal position – due to its location, infrastructure, skilled workforce and natural resources – to grow its Hydrogen industry and become a world-leader in the Hydrogen sector.
- Private Sector Diversification – the Plan notes the opportunity that Hydrogen offers for existing energy companies not only to diversify their offer, but also to reduce their carbon emissions.
- Regional Approach – the Plan reinforces the importance of Scotland's key regional hubs, in particular Orkney and Shetland, for potential growth in the Hydrogen industry.Aberdeen City is already deemed to be a Hydrogen hub in this regard, and the aim is for the initial public investment in these hubs to facilitate more significant private investment.
- Collaboration – the Plan sets out a collaborative approach to developing Scottish Hydrogen for export, particularly with Germany and other Northern European nations.
Relationship Between Hydrogen and Other Renewable Energy Sources
Although the Plan is not explicit on this point, it acknowledges that initial low-carbon Hydrogen infrastructure will pave the way for establishing the transportation and storage infrastructure to support a green Hydrogen economy in Scotland.
The Plan acknowledges that a strong renewables sector is essential to the development of Hydrogen projects.计划指出岸风部门支持小型和大型可再生水力项目的重要性,但承认该部门需要进一步投资。
离岸风部门更先进Successful bidders in the July 2021 leasing round will be announced in early 2022, and August 2021's leasing round had the specific objective of constructing offshore wind farms to decarbonise oil and gas infrastructure operations, support oil and gas-field decommissioning, and use excess generation to create Hydrogen.
Key Goals
The Plan set out six key goals:
- Drive Scotland's Hydrogen production capability to meet an ambition of 5 GW of renewable and low-carbon Hydrogen by 2030 and 25 GW by 2045.
- Address current barriers to the uptake of green and low-carbon Hydrogen, including high production costs.
- Support the growth of Regional Hydrogen Energy Hubs.
- Encourage demand for Hydrogen by supporting Hydrogen use and developing supply chain capability and export potential.
- Secure broad economic benefit from public sector and private sector support for development of regional Hydrogen production and use.
- Encourage the development of a strong Hydrogen sector in Scotland which supports a just transition to net zero.
II. ACTION PLAN
The Plan sets out six key challenges to be overcome during the next five years.
Scaling Up Hydrogen Production in Scotland
To unlock Scotland's potential to meet its ambitious targets for Hydrogen production, barriers such as regulation, planning laws or infrastructure constraints will need to be addressed.The Plan therefore commits the Scottish Government to a review of existing legislation, regulation and standards, to identify and remove potential barriers to the growth of the Hydrogen industry.
In order to improve understanding of the likely role to be played by Hydrogen in the domestic and global markets, the Scottish Government aims to establish the expected cost-trajectory for renewable Hydrogen up to 2045.
The Scottish Government will work with its counterpart in Whitehall to establish a UK Hydrogen Standard, and until this is established, the Scottish Government will only grant funding to Hydrogen projects with capture rates of at least 90%.将不向COsub>2 排放不减量的新Hydgen网站提供资金。
促进国内Hydrogen市场增长、规模经济和技术进步是关键交通产业被视为可能高氢需求行业。
Scottland政府会邀请能源密集制造厂商申请苏格兰工业能源变换基金赠款支持深度去碳化项目新的工业开发无阻碳排放将不符合苏格兰政府供资计划的资格。In the transport sector, the Scottish Government will establish a consortium for implementation of the Plan.
In the heating sector, the Scottish Government will support SGN (formerly known as Scotia Gas Networks), in converting elements of its network to Hydrogen, but only where doing so is consistent with keeping options open and limiting consumer costs.
Finally, the Scottish Government notes the urgency of amendments to existing UK-wide regulations to support the role of Hydrogen in the gas grid, to support Hydrogen blending and to maximize the volumes of renewable Hydrogen available in the energy system as quickly as possible.
Maximising the Benefits of Integrating Hydrogen into the Scottish Energy System
The Plan notes that converting renewable energy into Hydrogen provides new routes to market and may well change the investment proposition for new and existing renewables investors.
The Scottish Government believes that a key way to maximize the benefits of Hydrogen integration is to work with the UK government, Ofgem and the energy network sector to ensure that regulation rewards Hydrogen projects appropriately.关键行动点是建立氢流交通配送基础支持苏格兰氢流输出目标。
计划强调技能投资,包括提高工人技能并重新培训工人进入Hypgen部门。Hypgen工商开发服务将旨在促进产业和学术研究之间的协作。
企业机构将特别支持Scot2Ger项目,目的是到2024年向德国消费者提供苏格兰生产的可再生氢计划指出必须确保苏格兰氢流国际输出不存在法律或监管障碍,苏格兰氢流行业国际内向投资也不存在障碍。
Scottish Development国际外联方案将与280家被确定为苏格兰氢流行业外国直接投资潜在目标的国际公司积极接触将寻求与德国、比利时、荷兰、丹麦、加拿大、澳大利亚、日本和法国的关键协作。
加强创新和研究 一个新的苏格兰氢创新网络将促进苏格兰氢创新资产间增强协作并避免研究重复苏格兰政府支持苏格兰通过清洁氢欧洲合作伙伴关系申请欧盟资助,并启动150k英磅研究电话支持苏格兰和德国学术应用研究所之间的合作The European Commission seeks stakeholders' feedback until 18 November on its proposal to define cross-border projects in the field of renewable energy generation that would be eligible to receive EU funding under Connecting European Facility instrument.
In July 2021, the European Union adopted its Connecting Europe Facility (CEF) program for the period 2021-2027 worth EUR 33.71 billion to fund the development of high-performing infrastructures in the transport, energy and digital sectors.
Out of the CEF program devoted to energy (EUR 5.83 billion), 15% (EUR 875 million) is earmarked for a new category of eligible projects, namely ‘cross-border projects in the field of renewable energy', including for instance the generation of renewable energy from on- and offshore wind, solar energy, sustainable biomass, ocean energy, geothermal energy, or combinations thereof, their connection to the grid and additional elements such as storage or conversion facilities.
The Commission is now consulting stakeholders on its draft delegated act aiming at laying down the specific selection criteria and selection procedure of cross-border projects in the field of renewable energy.europa.eu/info/law/better调控/Have-your-say/intiatives/13239-Re在这方面,委员会强调推广者似可申请可再生能源领域跨边界项目状况,但不申请CEF供资状态确实必须被视为项目“质量标签”,允许推广者从市场或从会员国获得适当资金ec.europa.eu/news/cef-Energy-eu1-munds-support-prete-stude-service-s/p/p>Covington团队拥有丰富经验帮助你从早期阶段构建欧盟能源项目帮助您准备对咨询的回应-我们经常对一系列问题做-后,设计您的项目并按CEF、欧盟国家援助法、能源监管、公共订约和项目融资供资万博体育app手机登录ahrfss/www.cov.com/en/candido-garcia-molyneux'>CandidoGarcía Molyneux Energy and Project Development and Finance teams.
2020年12月,英国总理提出了绿色工业革命宏大10点计划,其中关键点之一是到2030年英国生产5千兆瓦低碳氢计划设想氢解碳密集工业和重交通并替换家庭供热中的天然气方面起关键作用。
8月17日,联合王国政府发布氢化战略(连同数项相关咨询),为联合王国未来氢经济打下基础,并阐明联合王国政府将如何支持创新和刺激对低碳氢的投资以达到5GW目标。战略还指出迫切需要公众认识运动消除消费者对安全的关切。
策略划分为五大部分:
- 潜在作用实现净零UK氢经济全系统方法:通向2030年的路径图开发氢值链中每个元素所需动作实现2030目标-碳预算六和净零市场和管理框架英国需要到2030年开发氢市场。
- 提高研究创新速度以加速成本削减和技术部署最大未来氢输出机会. /li>国际协作支持全球向净零过渡.
- 监控和评价:英国将如何监测进度以确保其实现前两章规定的目标.
LCHS可排除超出单位氢二氧化碳水平的项目参保政府支持计划。
本咨询开放10周,2021年10月25日结束回复尚不清楚政府将如何确定公平补贴,以及任何此类计量费用均通过家庭帐单或国库支付。 查询政府当前对合同长度、未来生产量支持规模和与其他收入支持机制兼容性的看法; This consultation is open for 10 weeks and will close for responses on 25 October 2021. Net Zero Hydrogen Fund Consultation The Fund is designed to encourage the of low carbon hydrogen during the 2020s in order to accelerate scale-up to meet the 5 GW target in 230. The Consultation sets out the proposed scope, design and delivery of the Fund, worth up to £240 million. The Consultation focuses on: 本咨询开放10周,2021年10月25日结束响应。
除是英国能源转换的重要组成部分外,联合王国政府视氢为职业创造者工具交付'平整'目标并以此方式鼓励对英国经济的大量投资与战略相伴的部会评论引用英国到2030年9000亿英磅投资和9000个工作值,到2050年可能上升至130亿英磅和10万个工作值,预测英国到2050年20-35%的耗能可以氢为基值。
Industry对发布战略广表欢迎,但呼吁政府提高雄心水平部分行业数字指出,英国2030年5千兆瓦低碳生产目标与欧盟2024年6千兆瓦目标相比不利,而其他人则评论说欧洲已经有23座氢钢厂-英国没有By using the terminology of ‘low carbon' hydrogen, the Strategy avoids explicitly choosing either blue or green hydrogen, opting instead to use a Consultation to establish emissions standards for blue hydrogen projects.
The decision to include both green and blue hydrogen in its Strategy differs from the EU approach whose focus has been more on the production of green hydrogen. Blue hydrogen has also been the subject of some controversy with a recent study by researchers at Cornell University suggesting that blue hydrogen may produce more overall lifecycle emissions than burning natural gas.
The UK's decision to include both blue and green hydrogen in its Strategy may be partly explained by the existence of North Sea gas and depleted oil wells which can be used to create blue hydrogen and store the resulting carbon dioxide. But it is also a tacit acknowledgment that, with domestic production currently so low, both forms of hydrogen will be required to meet its 2030 target.
Another question that has been raised is whether hydrogen is an effective energy source for all the different sectors for which the UK Government has indicated it is intended. Some commentators have argued that hydrogen's short supply means that it should be targeted at hard-to-decarbonise sectors such as cement and steel production, aviation and shipping.
However, the UK Government remains keen to investigate the possible use of hydrogen in domestic heating and has launched a series of trials which will help inform a decision in 2026 on the role of hydrogen in decarbonising heat.政府还计划评估以20:80混合方式将氢注入现有天然气供应的安全性和技术可行性,并估计可实现7%排减量热楼策略预期会提供更多细节。
UK Hypen策略和咨询为氢行业公司创造机会和风险Covington的政策和法律团队将乐于帮助公司在引导这些新创举方面征求建议。
2030年之前,英国的目标是5GW低碳氢生产,并计划围绕CCUS和Hi英国政府的目标是利用现有天然气基础设施向全英国家用烹调和取暖器提供氢(与天然气混合)并支持这一目标,政府宣布氢热试验,以在2030年之前创建氢邻和潜在氢镇为雄心。
本月早些时候发布英国工业去碳化策略IDS不试图决定是否更加重视集群(更多电气化)或全英国的基础设施投资(多氢混合)。然而政府承认,实施聚类策略可能冒重工业资产(例如水泥和钢铁工程)2035年后紧接风险,到2050年系统留有更多“剩余碳”,这将需要更多冲抵GGR技术。
IDS确认联合王国脱碳路径中需要更多关注氢以避免“绑定碳”更新内容包括侧重于加速工作支持氢业务模型以克服低碳氢与天然气等高碳燃料之间的成本差联合王国政府正计划在Q22021中就首选低碳氢商业模型进行磋商,最终模型将于2022年商定。英国政府支持Hydgen
然而,政府承认,如果不干预解决当前市场失效问题(以及监管不确定性和新技术带来的高风险),大氢不太可能找到一条可行的市场路线。英国正在考虑一系列干预支持英国氢开发-包括燃料标准能否在帮助行业投资方面起有益作用-并正在审查与不同氢生产技术相关的排放问题,以开发英国定义低碳氢的标准。
政府向Hypgen处置注资2亿2千万元Net零氢基金-这将为早期低碳氢生产提供资本共投10亿元净零创新组合(估计由行业和学术界提供35亿元资金补充)3300万英镑低碳供货竞赛。
APPG2021年3月中旬相聚HAC最后一次会议是在2020年12月两组支持并行开发英国蓝氢和绿氢,基础是蓝氢可成为绿氢的路径HAC目前正在绘制跨行业氢部署图,这将支持英国政府延迟氢化策略,该策略将在Q2发布:
Covington氢工队正在审查英国和世界其他辖区开发氢立法和框架的情况,并乐于帮助开发这个行业客户计划。
2类条款似乎是委员会调查焦点:
- Clauses 预防LNG货物移向欧盟内部替代目的地
- restricts rei/p>
2002年委员会调查NLNG尼日利亚天然气公司供应合同的领土销售限制5年后,它调查阿尔及利亚公司SonatrachLNG供应合同中的类似限制在上述两例中,委员会结束调查后,公司承诺删除LNG合同中的目的地条款。
事实上,委员会观察LNG部分已有相当长一段时间。ahrefss/ec.europa.eu/studies/follow-study-lng-sortage-strategy2017年6月,日本公平贸易委员会(JFC)结束全部门密集审查和辩论后得出结论,LNG供应合同中的目的地条款和转移限制和利润分享机制视相关合同条件而有可能或极有可能违反日本反垄断法不久后,韩国公平贸易委员会同样开始研究这些条款对竞争的影响。欧盟委员会和印度竞争委员会还去年与JFC签署了双边合作协议,旨在抑制LNG安排中问题目的地条款。
在前几例中,委员会较详细地审议了各类游戏安排和约束(目的地条款和潜在变异,如利润分享机制、隐式条件(FOB、DES、CIF等)),JFC2017年6月报告也进行了详细审议。无论其方法如何,都可公平假设委员会调查可能产生的影响远远超出本案特性并可能影响大LNG行业。
- restricts rei/p>