The Renewables Grid Initiative (RGI) welcomes the opportunity to contribute to the Energy Sector Strategy of the European Bank for Reconstruction and Development (EBRD). We acknowledge the efforts to draft a well-rounded strategy and call on EBRD to pursue a holistic approach to the energy transition in line with the EU and global priorities.
RGI is pleased to see that the role of electricity transmission infrastructure is highlighted in the proposed Strategy. Indeed, an accelerated deployment of renewable energy sources (RES), especially wind and solar, should be coupled with the deployment of the necessary electricity grid infrastructure at the same pace. This will allow for the necessary electricity grid, within and between countries, to be in place and integrate the increasing shares of variable RES into the energy systems, maximising social welfare and avoiding costly and polluting remedial actions, as well as to foster market integration and solidarity among countries.
Effective and continuous coordination between different voltage levels should be facilitated to design and operate the future decarbonised energy systems based on variable RES. This will not only unlock and leverage the potential of distributed energy and demand response but will also empower consumers and reduce spatial needs. Moreover, to ensure system security and reliability, effective regulatory frameworks should be introduced, aiming at identifying flexibility needs and enabling system operators to assess different flexibility options.
Robust energy scenarios and scenario development processes should be at the core of the design of a decarbonised energy system and energy network planning. These scenarios should reflect ambitious national decarbonisation trajectories (aligned with the Paris Agreement) and robust GHG budget methodologies.The energy efficiency first principle should be applied, besides the demand-side, at the system level to avoid waste of energy and resources. Thus, renewables-based direct electrification should be prioritised as the most cost- and resource-efficient way to decarbonise societies and economies. In line with this, the energy scenarios and accompanying investments should push forward ambitious rates of direct electrification, which in turn, should be assessed against robust indicators. Such an approach has the potential to drive economic development and innovation in the EBRD-supported economies.
The Strategy should ensure that the green hydrogen production and use does not lead to further infrastructural and technological carbon lock-ins and/or stranded assets. Although green hydrogen will have a role to play in the energy transition, it is associated with losses and inefficiencies and, therefore, its use should follow realistic timeframes and be limited to currently hard-to-electrify applications. RGI raises concerns over the envisaged use of hydrogen in buildings and transport, sectors for which mature electrification technologies offer viable, efficient, and affordable alternatives to fossil fuels already today. Direct electrification of these sectors, coupled with sustainable supply chains and focus on circularity would maximise benefits for the supported economies and societies. Furthermore, EBRD economies should safeguard that green hydrogen is truly renewable, to maximise greenhouse gas (GHG) reduction.
RGI regrets that the proposed Strategy envisages continuous support to fossil-fuel investments. Such an approach is incompatible with the climate urgency the world is facing and the long-term objective of climate neutrality/net-zero. Moreover, it could lead to the reliance on costly and dubious in terms of effectiveness and safety technologies, such as Carbon Capture and Storage (CCS). Instead, we urge the EBRD to prioritise phasing out support and subsidies to all fossil fuels, including fossil gas, and furthermore, to raise the Strategy’s climate/energy ambition, and replace the current prioritisation of ‘low-carbon pathways’ and ‘low-carbon readiness’ of infrastructure with ‘RES pathways’.
Planning, sitting and deployment of electricity infrastructure, including electricity grids, should encompass nature and resilience considerations. RES and electricity grid infrastructure can and should go hand in hand with nature protection and restoration. The Strategy’s reference to environmental effects, though, fails to capture the adverse impacts that energy infrastructure could have on biodiversity and ecosystems, if not properly planned and designed. We, therefore, urge EBRD to embed nature considerations in the Strategy, and make an explicit reference to nature and biodiversity in the narrative.
Resilience is a multi-layered term that should be further assessed. If not properly addressed, risks on the energy system, and adverse effects on the vulnerable citizens will be exacerbated. We welcome the fact that the proposed Strategy recognises the various levels of the impacts of climate change and call on the EBRD to assess these through a broader lens beyond the implications on hydropower. This necessitates, among others, the integration of tools and instruments with regard to energy system/electricity network development, environmental and adaptation/resilience planning. Moreover, national strategies that prioritise nature-based solutions and nature inclusive design of infrastructure could enhance public acceptance and biodiversity, while increasing adaptive capacities of the energy systems.
Lastly, negative externalities on societies should be carefully assessed and alleviated through a strong societal agenda. This should go beyond merely employment aspects of regions in transition, towards inclusive decision-making and empowerment of citizens. Creating supporting and convincing narratives at the national level, coupled with actions aimed at minimising and potentially reversing impacts on local, affected communities, can enhance public acceptance and ownership of the energy transition by the citizens. Therefore, in view of the development of just transition strategies, we call on EBRD to expand the scope of the envisaged engagement beyond governments and energy utilities to explicitly include electricity grid operators and citizens. Granular, early, meaningful and continuous communication and stakeholder engagement processes, including with citizens and NGOs, should be in place as integral part of the local renewable energy ecosystems.
At the local/project level, these processes should expand throughout the phases of electricity grid developments; from scenario-building to operation. Moreover, they should be purpose-oriented and generate tangible, perceived benefits for affected communities, that reflect local specificities and needs, as well as jointly tackle the intertwined biodiversity, energy and climate crises. In line with this, action areas for promoting equality of opportunity should prioritise the utilization of existing resources such as built environment and land in coal regions to reduce pressure on nature and societies.