Memo
 To: WePlanet Europe
 From: WePlanet Netherlands / e-Lise Foundation - Gijs Zwartsenberg
 Subject: From RED (Renewables Energy Directive) to CED (Clean Energy Directive)
 Last update (date): 20240320

Anyone in favour of clean energy can’t have failed to notice that the European Union has a technologically one-sided definition in its RED (Renewable Energy Directive).¹ This directive explains why France, with an average carbon intensity of its electric grid of 53 grams in 2023, was recently reprimanded² for not setting ambitious enough goals for 2030, regarding “renewable energy”. The average carbon intensity of Germany’s grid in 2023 was 399 grams.³

In its directive, the EU has established legally what “renewable sources” are: “energy from renewable non-fossil sources, namely wind, solar (solar thermal and solar photovoltaic) and geothermal energy, osmotic energy, ambient energy, tide, wave and other ocean energy, hydropower, biomass, landfill gas, sewage treatment plant gas, and biogas;”

With the RED, the EU has opted for a MEANS (“renewable energy”) in its directive instead of a GOAL (clean, affordable energy).

The RED is politically one-sided and requires urgent adjustment. We propose to make this a WePlanet theme around the European elections, which will take place in early June 2024. To be specific, the proposal is to replace the RED with a CED: a Clean Energy Directive, in which EU objectives are formulated in terms of CO₂ intensity and other environmental impacts per unit of energy.

This creates a more level playing field in which the most socially useful forms of generation can emerge as much as possible through the market mechanism. This includes a major(er) effort by the EU in the field of life cycle assessments (LCA) for every form of generation.

The choice of a MEANS in the past was based on political preferences, not on scientific considerations. However, the scientific studies that formed the basis of the decision to include nuclear energy in the EU Taxonomy no longer leave room for the one-sided policies of the past that now lead to intense, unnecessary and increasing polarization within the EU.^4,5 It is time for a technology-neutral European directive: the Clean Energy Directive (CED).

This CED can function well in combination with existing directives such as those of the Emissions Trading System (ETS)⁶ and the Carbon Border Abatement Mechanism (CBAM)⁷. These may need to be supplemented with important changes in the European electricity market.⁸ These adjustments can lay the foundation for a politically broadly supported and globally economically competitive energy transition policy for the EU.

The current congestion problem in almost all of the European grids makes it clear that there is a need for haste in realizing this CED: the current one-sided choice for electricity sources with a capacity factor of often much less than 50% affects both the political and technical flexibility to choose for a balanced mix at a high pace. Urgent action is therefore required: any further restriction of the choice for a socially optimal mix requires drastic legislative action NOW.

1 The original version (RED I) is known as Directive 2009/28/EC, and the current, revised one (RED II) as 2018/2001/EC. On November 20^th, 2023, RED III (2023/2413/EU) was published, and should be incorporated in the legislation of the member states within 18 months. https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:L_202302413.

2 https://www.euractiv.com/section/energy-environment/news/eu-commission-urges-france-to-raise-renewables-target-to-at-least-44/

3 Average carbon intensities per year per kilowatt hour. Source: https://www.electricitymaps.com/

4 https://ec.europa.eu/info/sites/default/files/business_economy_euro/banking_and_finance/documents/210329-jrc-report-nuclear-energy-assessment_en.pdf

5 https://unece.org/sed/documents/2021/10/reports/life-cycle-assessment-electricity-generation-options

6 https://climate.ec.europa.eu/eu-action/eu-emissions-trading-system-eu-ets_en

7 https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism_en

8 https://www.europarl.europa.eu/RegData/etudes/BRIE/2023/745694/EPRS_BRI(2023)745694_EN.pdf