to motivate Member States to remove barriers and create favourable conditions for consolidating existing and building up new CHP capacities.
However, in order to truly meet these goals, the Directive will now need thorough revision by the European Parliament and the Council of Ministers, especially in respect of the following points:
Unacceptable 50 MW threshold
The Proposal contains a recommendation for Member States to focus public support capacities below 50 MWe, thereby excluding a significant share (from 25 up to 80% in some Member States) of existing capacities and a considerable share of future potential projects from the scope of the Directive. Not only is there no economic or environmental justification whatsoever for such a threshold, it is also in obvious contradiction with the main objective of the Directive and it will to lead to sub-optimal plant design in the future.
Lack of targets
One of the main goals of a Directive Proposal on Cogeneration must be to grow the amount of cogeneration in the European Market. Without targets setting the direction for Member States there is a danger that little overall progress will be made. The CHP Strategy of 1997 set a doubling target for the EU as a whole and this could be used as a good starting point.
Confusing and distorting two-step approach on the definition
The two-step approach proposed by the Commission in Annexes 2 and 3 (basic definition and high-efficiency CHP) is both confusing and misleading and must be revised. Euroheat & Power and COGEN Europe consider that a single and accurate definition of CHP would provide better clarity. The basis for this definition could be derived from earlier EU supported work, especially the so-called Protermo methodology.
Euroheat & Power and COGEN Europe welcome the Directive Proposal but call on the European Parliament and the Council of Ministers to take action on our concerns.
The full Directive for the promotion of cogeneration can be downloaded here as a pdf file