Wind turbines: REPowerEU directive. EPAW junio 2022
Wind
turbines: REPowerEU directive. CALL TO ALL !!!
Consultation before the adoption of the REPowerEU directive.
CALL
TO ALL !!!
The European Commission, under the pretext
to free Europe from Russian gas, has launched a consultation under the name of
"REPowerEU" to impose a renewable energy directive based on the
invasion of European countries by hundreds of thousands of new wind turbines.
This program "REPowerEU" is supported by the lobby of wind developers
(RES SIMPLIFY Report) and carried by the green environmentalist parties that
hold power in Europe.
To achieve its goals, the commission simply wants to flout democratic
principles and suppress fundamental laws, particularly environmental laws,
which allow citizens to fight against this plague
"REPowerEU" is just the program of the ruling coalition in
Germany. It is potentially, the shattering all environmental protections
and may be the end of our capacity to resist.
( Jean-Louis Butré - Patrick Kawala pdt FAEV)
Your participation is
required if you do not want to ruin the future of our union.
Consultation prior to the adoption of
the REPowerEU Directive.
(Michel de Broissia, Michel Faure FED administrators)
The war in Ukraine has brutally revealed
the fragility of the European energy transition based on renewable energies and
gas. Far from questioning its strategic choices, Europe has chosen to rush
ahead and is preparing a directive to double down on this path, which many
consider to be a dead end. Without any prior impact study, this new
rule will apply to all countries, regardless of their own greenhouse gas
emissions (GHG).
Directive Project main
issues (18/05/2022):
https://www.dropbox.com/s/iyzovoazrvw2bxu/090166e5ec6de6e7%281%29.pdf?dl=0
Commission Recommendation
(18/05/2022) :
https://www.dropbox.com/s/r60i008oilnh7hq/l_14620220525en01320138.pdf.en.pdf?dl=0
The directive currently being adopted is
subject to a public consultation from 20 May to 27 July 2022. Its content opens
the way to all kinds of abuses and we will have to mobilize as never before..
To participate
(Associations or individuals),
click on the following link:
https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13334-Renewable-energy-projects-permit-granting-processes-power-purchase-agreements_en
Beware, the web page is confusing. By
scrolling down the page, a first call for contributions appears followed by 728
opinions. This is a first consultation that is now closed and that took place
from January 18 to April 12, 2022, including the two summary documents.
The current public consultation appears just after scrolling down the web
page. It is easy to recognize with its orange highlight.
Scroll down the web page to see the
following content (highlighted in orange):
All you have to do is click on
"Give feedback".
All that remains is for you to give your
opinion on behalf of yourself or your association by creating an account if you
have not already done so. If your association is declared in the transparency
register, you can indicate your identification at the top of your contribution.
To build your argument, it is best to
read the draft directive and/or the summary given below. It is always better to
give your point of view with your own expression. It will not be or appear to
be the comment of an organization.
Some issues seem particularly worrying:
· The precipitation of
procedures will exacerbate conflicts instead of mitigating them,
· The absence of impact
assessments on the scale of projects in favorable areas (“go-to areas”),
combined with the very short deadlines, opens the door to all kinds of abuse.
· The shortened deadlines
are incompatible with the observation of nature
· The lack of information
and public participation at the level of each project is a negation of the
Aarhus Convention.
· The easy re-equipment of
old plants, as well as the will to concentrate all the RES in go-to areas,
designates some territories as abandoned areas in contradiction with the
principle of equality of territories.
· The principle of
subsidiarity is flouted by imposing without saying it a partial abandonment of
the nuclear power produced in Europe without any GHG emissions.
· The draft directive
flouts certain European treaties (Euratom) and runs counter to the restoration
of biodiversity, which was previously designated as a priority.
· The prior public
consultation integrated in the process of elaboration of the present draft
directive, which took place from January 18 to April 12, 2022, did not take
into account any observations in opposition to the object of the inquiry. This
is a practice far removed from the spirit of a consultation.
· Accelerating the
procedure process will increase rather than mitigate conflicts.
Key points of the draft directive
The following paragraphs provide an
overview of the most critical points that will become binding on member states
if they are adopted without an impact assessment. They reflect the
considerations formulated in the draft directive. ;
The opinions given in the form of a note
are those of the authors of this key note.
OUTLINE OF THE MAIN FEATURES OF THE
DIRECTIVE:
1. The massification of
renewable energies (RES):
The directive (EU) 2018/2001 set a binding target of 32% RES deployment by
2030. The war in Ukraine is the pretext for fixing this RES deployment to 45%
by 2030 [1].
2. In order to accelerate
the implementation of renewable energy projects, it is first necessary to
simplify and shorten the procedures for granting permits.
1. The development and
operation of RES must be considered to be in the “overriding public
interest [2] and serving public health and
safety”. As such, they should be given the most favorable procedure among other
planning and permitting procedures.
2. Member States should
immediately map and assess suitable onshore and offshore areas for renewable
energy projects, known as "renewables go-to areas", and ensure
their availability.
3. Member States will
have to quickly define a zoning of their territories
1. The renewable go-to
areas for which projects will be subject to accelerated procedures.
1. Only a global
environmental assessment [3] of go-to areas
will be carried out, valid for an indefinite period.
2. If necessary, member
states will adjust unforeseen impacts through corrective actions [4].
3. The designation of
go-to areas shall meet the needs defined by the commission in terms of produced
energy [5].
4. The preliminary
environmental assessment, which is therefore at the zoning plan level, makes it
unnecessary to carry out impact studies for each project. In the event of
unforeseen impacts that are duly justified within a short period of time, an
impact study at the project level may be required, but its duration is limited
to 6 months
2. The other areas
(outside “go-to areas“)
The fact that a RES project is located in a non go-to area should not
prevent its realization. In this case, an environmental assessment must be
carried out [6].
4. Taking biodiversity
into account will become less restrictive.
The killing of protected species [7] is allowed
provided that mitigation measures are in place and monitoring is carried out.
Member States may authorize experimental mitigation measures for a limited
period of time and under strict control.
There will no longer be any need to request exemptions for the destruction
or disturbance of protected species.
5. Repowering of
renewable energy plants at end of life will be simplified [8]:
The directive includes very simplified procedures for the repowering of old
wind farms. The reasons are given: the first projects were set up on the most promising
sites, the local residents will have a better acceptability, the power
connections are available and the effect on the environment is known
1. Environmental studies
will only address changes for plants located outside go-to areas (plants in go-to
areas will be exempted),
2. Permit granting
procedures are shortened.
6. Member States should
consider renewable plants and their associated infrastructure to be in the
overriding public interest and to serve public health and safety
Unless there is clear evidence that some projects have major adverse
environmental impacts that cannot be mitigated or compensated for.
As these renewable plants are projected in the overriding public interest
and serving the public health and safety, these projects must receive a
shortened assessment.
7. Some directives need
to be amended to allow for the required simplifications:
1. About environmental
studies: directive (EU) 2018/2001 should be amended.
2. About housing ;
directive 2010/31/UE 2001 should be amended.
3. The energy saving factor,
which is expected to be 32.5% in 2030 compared to 2007, should be increased to
41.5% by the same date. Directive 2012/27/EU should be amended accordingly.
8. Authorization
procedures are time-limited and are subject to a very tightly controlled process
1. application
request: the administration must respond to the promoter within;
1. 14 days in a go-to
area. If the application is incomplete, the developer must respond within 14
days. He will have the possibility to re-file a new application if he passes
the deadline for the formal admissibility examination.
2. 1 month in a non go-to
area
The start date of the granting procedure starts on the date when the
project is defined as complete by the administration..
1. The administration
states a single contact for the entire procedure.
This contact has a guide that he gives to the promoter..
1. For the resolution of
disputes, the member states provides the quickest legal framework available.
2. In go-to areas, the
granting process should not exceed one year (with a maximum extension of 3
months in exceptional cases).
3. Outside go-to areas,
the period is 2 years, extendable by 3 months.
4. For repowering, the
authorization procedure should not exceed 6 months (this period can be extended
in “extraordinary” circumstances).
5. Permit-granting
6. Inside go-to areas, there is no need for
impact studies [9]. The administration
has 30 days to exceptionally require an environmental study [10]. In the absence of a
response within the deadline, the project is considered to be accepted as is.
7. Outside go-to areas, the granting procedure
requires an impact assessment. In total, the entire procedure should not exceed
2 years (which can be extended by 3 months in exceptional cases).
[1] In practice, to
comply with this new directive, some countries will have to shut down or
mothball some of its nuclear power plants.
[2] Note the
definition of an "overriding" category intended to be placed above
the "general" interest.
[3] Thus clearly
insufficient because at this stage, the characteristics of the projects are
unknown.
[4] The current
drifts based on this kind of precaution are well-known.
[5] This requirement
in terms of energy produced mignt become extremely restrictive without even
taking into account the energy potential of a country.
[6] But, the State
services will define the content and it will become intangible!
[7] This is a
considerable regression. The European Commission places the deployment of
renewable energies above the protection of biodiversity including protected
species.
[8] Bad luck to the
territories that have accepted or suffered the deployment of wind farms.
[9] A project can
therefore be authorized without any assessment of the biodiversity, without an
acoustic study, without a landscape or cultural study,…
[10] The 30 days
deadline is very short as the State services will have to prove that the
project is highly likely to have unforeseen significant negative
impacts on the environment to require an environmental assessment! It
is obviously an impossible mission in such a short time.
More informations please contact
Michel de Broissia : debroissia.michel@free.fr
Michel Faure : michel.faure@yahoo.fr
____________________________________________________________________________
Cordialy
Jean-Louis Butré
Président
European Platform Against Wind Farms
Fédération Environnement Durable
http://environnementdurable.net
contact@environnementdurable.net
tel 06 80 99 38 08
Petición de re-examinar la recomendación de acelerar los procedimientos de proyectos renovables. Request for re-examination of the recommendation on accelerating permitting procedures for renewable energy projects. EPAW NEWSLETTER : Thursday 16 june 2022
Request for re-examination of the recommendation on accelerating permitting procedures for renewable energy projects.
EPAW NEWSLETTER :
Thursday 16 june 2022
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