vgbe publishes note on EU taxonomy and hydropower

28 January 2022


vgbe energy has announced the publication of an Interpretation Note on Hydropower & the EU Taxonomy Climate Delegated Act (C/2021/4987 final) as a step within the dialogue process with the European Commission and several other affected stakeholders.

vgbe says its hydropower members and experts fully support the ambition to become the first climate-neutral continent by 2050 and are ready to invest into and further develop sustainable hydropower generation and storage across Europe. The EU Taxonomy is seen as a crucial instrument in this regard, helping to scale up sustainable investment and to implement the Green Deal. 

vgbe says that the technical criteria for hydropower generation and storage are inadequate as they are not as clear and specific as they should be in order to be ready for immediate use and implementation, and as a result it initiated in-depth discussions across the sector to reach both a common understanding as well as aligned interpretations. The result is the Interpretation Note, providing commonly agreed as well as feasible definitions and pre-senting possible solutions, mainly related to current shortcomings and potential misunderstandings.

vgbe says the key messages and motivation for the publication of the Interpretation Note were as follows:

  • The EU Taxonomy does not provide a level playing field for either renewable electricity generation technologies nor for storage technologies.
  • Hydropower is the only renewable technology that is split into different economic activities that all have to fulfil a long list of requirements, marked by unspecific and unclear terminology, hindering a direct, immediate and swift application.
  • EU Taxonomy Climate Delegated Act does not take into account the complexity and multipurpose use of hydropower generation and storage facilities, and simultaneously introduces new terms that have not been previously defined in existing EU legislation or in valid technical standards.
  • The EU Taxonomy criteria use similar but not the original wording of EU legislation, which might lead to legal uncertainty.
  • Numerous requirements and documentation duties are imposed to manufacturers as well as to operators, which may still apply in cases where they are not in charge of fulfilling the requirements or do not have a specific mandate to do so.



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