The Regulation's market intervention is exceptional (albeit in response to an extraordinary geopolitical market disruption). It will have widespread positive and negative impacts for energy market sellers and buyers. These circumstances may provoke a range of disputes, transaction (re)structurings or additional compliance obligations that will require expert advice and understanding of the details of the Regulation.
Reduction in electricity consumption
EU Member States will endeavour to reach an overall 10% reduction in electricity consumption by all consumers. The benchmark against which that reduction will be measured is the average of gross electricity consumption in the corresponding months of the reference period, i.e.11月1日至前5年3月31日,自2017年开始此外,为降低零售价并增强供应安全,成员国有义务在峰值时将电耗减少5%(定义为日头批发电价预期最高日间时数!总电耗预期最高或可再生能源以外的源电总耗量预期最高)。自2022年12月1日至2023年3月31日适用这些措施。
参数中包括防止违反欧盟绿色目标的保障措施成员国只能为未按预期耗电提供经济补偿市场运营商除收入外所支付的财政补偿金额必须通过竞争过程确定。 非加气/硬煤电厂剩余收入Cap
确定这种上限水平,以免转移可再生能源投资是一项复杂工作。高压电价高于过去十年平均批发电价和当前能源平化成本相关发电技术。
UnlikeIberian半岛 < ahrfs='chrome-extension/feaidnbnibcpclefmkaj/https/ec.eu/competice/state_aid/cass1/20225/SA_102454_407781-00-C327-A344-3EC9A772C4AF_72_1.pdf>成员国必须使用封顶剩余收入支持终端电客。剩余拥塞收入来自跨区容量分配,由传输系统操作符累积正常市场环境下,相关TEO可自由决定是否使用欧盟 The Regulation also contains a provision to redistribute the surplus revenues between net importing and exporting countries, to ensure that all Member States have the resources needed to support their final customers. Retail price regulation of electricity The Regulation allows SMEs to benefit temporarily from State intervention in setting the retail electricity price. This provision foresees the possibility that the end price could even be set below cost, provided that such an intervention does not distort demand reduction and that suppliers are both compensated and not discriminated against. Since State intervention in electricity pricing is generally considered to create market distortions, it is normally only permitted in specific and limited circumstances – as set out in the Electricity Directive – through the entrustment of a Public Service Obligation (PSO).委判定当前状况满足这些条件,因此监管授权偏离欧盟 /p>理事会授权将这笔捐款的收益用于向最终能源客户提供财政支持-特别侧重于脆弱家庭和能源密集产业(后者必须使用支持投资于可再生能源、能效或其他去碳化技术)。 Covington将继续监控并更新当前危机背景下欧盟法律的最新动态。
2022年10月5日,国库局和国税局发布通知,请求对《降低通货膨胀法》('IRA')中能源税益的不同方面发表评论11月4日星期五前应提交所有评论,或电子发布www.reducts.gov或寄送国税局万博体育app手机登录日期过后提交的书面评语将予考虑,只要不延迟发布指南。
通知征求一般性意见,但也侧重于具体定义问题和业务问题除其他外,请求出自爱尔兰共和军新的国内生产和采购需求,包括采购关键矿产品以制造电动车辆和用美国生产的材料搭建某些合格设施需求新的双级信用结构中也产生请求,对于其中许多信用,纳税人如果满足某些工资和学徒需求,有资格获得更高信用(通常是基数的五倍)。万博体育app手机登录一份通知侧重于某些信用项新的直接支付或可转移性特征,这基本上导致向纳税人支付现金,而不管他们在申请信用的年份是否负税。
IRA为国库向纳税人提供指导设定极短的最后期限结果是,如通知中所述,利害相关方有有限时间权衡今日发布通知请求在11月截止时间前提交评语,既包括年末到期的受管制入计量(如EV税抵免),也包括后年到期受管制入计量(如ITCPTC技术中和PTC)。除征求一般性意见外,每份通知都提出一些具体问题,下文摘要中强调其中一小部分问题。
/lqliququq3MD4NDLCJ1cwiOiJOdhuczovL3d5cnMvcre万博体育app手机登录Notice 2022-46 asks stakeholders to answer a number of specific questions related to:- What factors and definitions should be considered to determine the place of extraction or processing of critical minerals and the value of those minerals;
- How the guidance should define the components of a battery and determine the place of manufacture or assembly of battery components and the value of those components;
- Whether guidance is needed to clarify the definition of "foreign entity of concern" and to the extent available, whether there is any existing regulatory or guidance frameworks for tracking whether manufactures are in compliance with the foreign entity of concern rules!万博体育app手机登录and
- Whether guidance is needed on the definition of "acquired," "use," and "lease."
- Notice 2022-47 requests comments on energy security tax credits for manufacturing under § 48C and 45X.通知2022-47请利害相关方评论:
Where需要进一步澄清第45X(c)节中“合格组件”定义; 应如何确定“整合、集成或集成”短语,当合格组件整合、集成或集成为另一个组件时; 财政部和IRS在判定合格先进能源项目信用评分选择标准时应考虑什么i>/li+li+i+i+i+i+i+i+i+i+i+i+i+2+2万博体育app手机登录通知2022-48提出了多项定义问题,包括:政府在制定指南时应考虑哪些标准和技术用于确定节能商业大楼的“用能强度”。万博体育app手机登录i>li+li+i+i+i+i+i+i+i+i+万博体育app手机登录政府在通知2022-49中寻求的部分评论包括: 政府在制定指南和确定纳税人的信用资格时应考虑哪些行业标准;投资信用设施要求投资税抵免必须满足生产税抵免的所有要求,例如要求将发电出售给无关者;政府需要定义指南和政府确定术语时应考虑哪些条件(例如技术类型),如“无关人员”、“结构”和“毛收入!万博体育app手机登录i>/li+li+li+i+i+i+i+i+i+i+i+i+i万博体育app手机登录Notice 2022-50 requests comments from taxpayers on a number of questions, including: - Whether any guidance is needed on the terms used in these monetization sections, such as "applicable credit," "excessive payments," and "applicable entity";
- What potential issues and factors that the government should consider when a partnership or an S corporation makes such an election;
- What types of structures may be entered into by applicable entities and taxpayers that have elected to be treated as applicable entities;
- Whether any documentation or registration should be required and what factors the government should consider to prevent improper payments or excessive payments and whether clarification is needed on the penalty provisions for excess payments!CHIPS/LILQLIJJJJJJJJlGLU2JJJJJUJUNJUNQ3MD4EILCJIOIJOJJOJJOJJOJJOJOJOJL3D5cnMU3B2L3BJI9PNJJCLSSLVLVLVLVLIJJJJJJJJJJJUJJJBLGLULXLXLIJJJJJJJJJUJLUGLXUNQNQQQMDUNQ3MCDEILCILCJJJICUIOIJOJOJOJL3DL3DL2L2LLLLLICI通知2022-51具体请求评论,包括:
文献或证明应用来证明遵守奖金信用要求的情况以及信息方目前维护并可能创建的信息量;国库司和IRS应一致使用48C.F.R下提供的定义万博体育app手机登录§661对内容需求以及现有规范或指导,如FederalCrap Regional和BuildingAmerica BuyCA指导,可能有益于开发指导; 定义,如“合格设施组件”、“制造产品”、“终端产品”和“总成本”需要澄清国内内容需求万博体育app手机登录和/lili>处理制造产品子组件需要澄清。 squal='wp-blest-separator has-alpha-chane-o2023年2月12日清洁氢生产税抵免 第45V节 2023年8月16日技术中立PTC和ITC(第45Y和48E段)2025年1月1日前完成
供应链链DOE可直接提供金融支持以拓展变压器或关键材料输入量的国内制造能力或可承诺购买量变压器向厂家提供需求确定性。 除变压器和电网组件外,RFI还覆盖下列技术:太阳能光电隔热素材电解器、白金类金属和净氢燃料电池东区2022年11月30日
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.
Driven by the entry of renewable generation resources locating far from load centers and the new demands placed on the grid by their differing characteristics, the Federal Energy Regulatory Commission (FERC) launched a comprehensive review of its policies regarding regional transmission planning, interconnection and cost-allocation. In an Advance Notice of Proposed Rulemaking (ANOPR), the agency requested public comments on its current policies and offered potential areas for reform with a view toward anticipated future generation. According to FERC Chairman Richard Glick, "(a) piecemeal approach to expanding the transmission system is not going to get the job done.We must take steps today to build the transmission that tomorrow's new generation resources will require."
This initiative is likely to result in specific proposals from FERC and ultimately reform of its rules and policies that could substantially change how the electric grid is planned and paid for. Accordingly, the ANOPR should be of interest to any company with a current or anticipated interest in, or use of, grid facilities.
This is the second initiative in as many months that FERC has taken a big step toward addressing the kind of grid needed for renewable generation As discussed in a prior post to the blog, last month FERC established a Joint Federal-State Task Force on Electric Transmission with state and local regulatory agencies to address barriers to transmission planning and development, opportunities for states to coordinate on regional transmission solutions, and barriers to interconnecting new resources.
The ANOPR
After providing a comprehensive discussion of its current policies regarding transmission planning, cost allocation and interconnection, FERC says "it is now appropriate to examine whether the existing regional transmission planning and cost allocation and generator interconnection processes adequately account for the transmission needs of the changing resource mix." Accordingly, the ANOPR identifies the following major aspects as potential areas for reform.关于每一方面,ANOPR请求评论当前政策的适当性并同时建议潜在的改革。
Identifying the benefits, cost and responsibility for grid facilities. One potential reform is to eliminate the current policy that requires interconnecting generators to pay the total cost of grid network upgrades that would not be needed but for the interconnection. FERC observes that a network upgrade may sufficiently benefit grid customers or later-in-time interconnections that it is appropriate to allocate the costs more broadly. Eliminating the policy could increase integration of generation by reducing cost uncertainty to resources in the interconnection queue and by removing a potentially prohibitive cost assignment to the resource first in line in the interconnection queue, which will bear the full brunt of needed grid upgrade costs that may also benefit resources next in line.
Enhanced transmission oversight. Given the potentially significant investment in transmission facilities to come, FERC is considering enhanced oversight of transmission planning and spending to ensure that transmission rates remain just and reasonable. For example, FERC could require that transmission providers establish an independent entity to monitor the planning and cost of transmission facilities in a region and to possibly provide advice on the design and implementation of the regional transmission planning and cost allocation processes.FERC also requests comment on involving state commissions in transmission planning and cost allocation processes and in limiting the costs that can be recovered for regional transmission facilities that are abandoned prior to going into service.
Commissioner statements
While the ANOPR was approved unanimously, all four commissioners issued concurring statements.[1]
Chairman Glick and Commissioner Clements issued a joint concurrence that provides a deeper discussion of certain topics than appears in the ANOPR, such as the extent of the shift toward renewable resources and the reasons for it. The concurrence is also more conclusory regarding how and why the current regional transmission planning, cost allocation and generator interconnection processes may no longer ensure just and reasonable rates for transmission service. Finally, the concurrence offers the following:
We anticipate that this effort will be the Commission's principal focus in the months to come.In addition to reviewing the record assembled in response to today's order, we intend to explore technical conferences and other avenues for augmenting that record—including through the joint federal-state task force (footnote omitted)—before proceeding to reform our rules and regulations.
Commissioner Danly's concurrence observes that many of the proposals would "exceed or cede our jurisdictional authority, violate cost causation principles, create stifling layers of oversight and ‘coordination,' trample transmission owners' rights, force neighboring states' ratepayers to shoulder the costs of other states' public policy choices, treat renewables as a new favored class of generation with line-jumping privileges, and perhaps inadvertently lead to much less transmission being built and at much greater all-in cost to ratepayers." Accordingly, Commissioner Danly requests that comments address whether each proposal is a proper exercise of the Commission's authority and the ultimate effect on ratepayers.
Commissioner Christie's concurrence notes that "(t)his consideration of potential reforms is especially timely as the transmission system faces the challenge of maintaining reliability through the changing generation mix and efforts to reduce carbon emissions" but notes that he does not endorse any of the proposals included in the order.
Comment deadlines
Initial and reply comments on the ANOPR are due 75 days, and 105 days, respectively, after publication in the Federal Register.
[1] Commissioner Chatterjee, whose term has expired, did not participate in this matter.
The European Commission has published a proposal for a Corporate Sustainability Reporting Directive (2021/0104) ("CSRD"), which forms just one part of a comprehensive package of sustainable finance measures (see our blog here).欧委会提出这些措施响应对更强和更广泛的可持续性报告标准的要求,超出欧委会当前提供s/eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32014L0095CSRD通过修正欧盟现行法律,包括透明指令、会计指令和审计指令,努力授权可持续性报告与保证More fundamentally, according to the Commission, it will move the EU one step closer to realizing its aim of having sustainability reporting be "on a par" with financial reporting, in terms of attached weight and importance. This is reflected in the change of terminology used in the CSRD proposal, from a focus on "non-financial" information reporting, to "sustainability".
We cover below the background and detail, but in summary, these are the key elements of the CSRD proposal that corporates should be aware of:
- Scope: The CSRD reporting requirements will apply to all large EU companies and all listed companies, including listed small and medium-sized enterprises ("SMEs").估计覆盖约49,000家公司。
- Audit: The CSRD will require, for the first time, a general EU-wide audit (assurance) requirement for sustainability information.
- Digitization: The sustainability information must be published in companies' management reports — and not separately reported — and the information will need to be digitized or "tagged" so it can be incorporated into a planned European Single Access Point.
- Timing: If the proposal is adopted and standards can be agreed in line with current ambitious estimates, large in-scope companies must comply from financial years starting on or after 1 January 2023, publishing reports from 2024!whilst SMEs have to comply from 1 January 2026.
Context: Need for Reform
To reach the EU's aim of becoming net zero by 2050, the Commission understands that private capital must be directed towards green, sustainable projects, and this requires that investors have access to clear and comprehensive information on their potential investees relating to, among other things, environmental sustainability and corporate governance practices.
Currently, the Non-Financial Reporting Directive requires in-scope companies to report on sustainability matters, including on environmental protection, social responsibility and treatment of employees, respect for human rights, anti-corruption and bribery, and diversity on company boards.
Yet, despite the Commission's publication of non-binding reporting guidelines and specific guidelines on climate-related reporting aimed at standardizing disclosures, concerns remained over the quality and consistency of the information disclosed.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02019R2088-20200712多家这样的机构因此游说鼓励改革2019年底,委员会承诺,作为其“https://ec.europa.eu/info/strategy/priorities20192024/european-green-deal_en/EuropeanGreenDes
Company非欧盟公司欧盟子公司建议免责,供母公司遵守立法的集团内公司使用并注意,根据该提案,免责子公司需要发布合并管理集团报告并在其个人报告中注明免管CSRD。 与此相关,委员会澄清说,虽然公司可免交合并财务报告要求,但合并可持续性报告机制将分离,因此它们不一定免交后者。
非财务报告指令目前捕获约11 000家公司Under the CSRD, due to the broader definition of "large undertaking", as compared with "large public interest entity" under the Non-Financial Reporting Directive, the Commission estimates this number could rise to approximately 49,000.The listed SMEs, however, would not be subject to the same reporting standards as large undertakings. In parallel with the new rules for large undertakings, "proportionate standards" (i.e., simpler, less onerous standards) will be developed for SMEs by October 2023. While SMEs that are not listed on EU regulated markets do not fall under the proposed rules, the Commission suggests they would be able to use such standards on a purely voluntary basis, possibly as a method to enable more cost-efficient responses to requests for information from upstream entities, including banks and insurers.
(ii) Reporting Requirements: Inwards-Outwards, Forwards-Backwards…
One of the criticisms levied against the Non-Financial Reporting Directive was that it did too little to encourage consistent coverage in reports.The CSRD is intended to provide a much more granular level of detail regarding what information undertakings should report, covering the entire value chain.
The Commission now proposes that mandatory disclosures form part of a company's management report and include descriptions of:
- business model and strategy, including plans and implementation;
- sustainability targets and progress made towards achieving those targets;
- role of the management and supervisory bodies regarding sustainability;
- policies in relation to sustainability factors;
- due diligence processes for operations and the supply chain;
- principal risks and dependencies;
- indicators relevant for measuring all the above;
- intangibles, including intellectual, human, social, and relationship capital!并 进程识别披露信息。
As和量化信息,CSRD建议要求定性信息也包含在披露中,提供面向前和回溯信息覆盖短期、中期和长期提案还澄清说,“双重相对性”原则仍然存在,但澄清说,这意味着企业应报告理解可持续性问题对自身影响的必要信息,并报告理解对人与环境影响的必要信息-i.e./em大型多国公司应该知道,这一点和对“可持续性信息”(相对于非金融信息)的重视不同于气候相关财务披露标准工作队单镜或金融重要性透镜。
CSRD建议还引入强制可持续性报告标准这些标准旨在补充上文披露链表并进一步具体说明信息企业需要披露-可针对具体部门这些标准将采取委托行为形式,根据欧洲财务报告咨询组-欧盟支持的私人协会-的建议编写并咨询关键利益攸关方第一套标准规划于2022年10月前完成,第二套一年后完成。
持续报告标准预计将与下列主题标题相关:标准将包含全球接受标准的基本内容,包括与气候相关金融披露标准较窄与气候相关特别工作组,以确保欧盟保持广泛的一致性-即使欧盟决定更深入。
/so报告的可持续性信息准确可靠,CSRD提议对提供的可持续性信息进行强制性全欧盟审计或保证要求初始保证义务为“有限性”,但随着可持续性保证标准的发展,我们最终可能看到保证义务类似于财务报告所用的保证义务。CSRD建议允许成员国选择公司而非普通财务信息审核师确保可持续性信息 。
CSRD建议要求公司用欧洲单一电子格式编写管理报告和财务报表数字报告和标签系统允许将报告数据纳入规划中的欧洲单一存取点中(插图见https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:522020DC0590&from=ENCapital市场联盟行动计划 )并允许应用新手AI和机器学习技术EFRAG并行报告标准如果最终立法文本正式通过并可按照当前雄心勃勃估计商定可持续性报告标准(2022年上半年前),欧盟成员国需在2022年12月1日前实施CSRD大范围公司从2023年1月1日或以后的财年必须守法,发布2024年报告,上市中小企业从2026年1月1日守法。
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John Ahern +44 20 7067 2190 JAhern@cov.com
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