Powerful national support systems versus Europe-wide
har monisation – assessment of competing and converging
suppor t instr uments
Markus Kahles & Thorsten Müller
“The time has come for energy policy to become truly European”. This is the claim made by the
European Commission with respect to energy-related issues (European Commission 2010, p. 4).
However, it raises the question how such a European approach can be structured in a meaningful
manner. Wanting to answer this question by saying that only a harmonised system can be European
would be premature and would negate differences as well as existing market failures and other
necessary learning processes. It is not only reactionary forces in the Member States who consider
energy policies as an integral part of national interest and are therefore against harmonisation.
Rather, important questions pertaining to the meaningfulness and structure of such a procedure
are still unresolved.
The ambivalence between the desire for harmonisation on the one hand and the consolidation of
the existing support schemes on the other is also reflected in the directive for promoting the use of
energy from renewable sources (Renewables Directive 2009). According to Recital 25, the direc-
tive follows the objective of “facilitating cross-border support of energy from renewable sources
without affecting national support schemes”. According to this, the Member States can them-
selves decide in accordance with the second subparagraph of Article 3(1) of the RES-Directive
to which extent they want to promote the energy generated from renewable sources in another
Member State. Processes are initiated within this legal framework, which during the course of
the competition among systems and the mutual learning process enable a convergence of the sup-
port schemes of the Member States even without central legal harmonisation and will definitely
improve the understanding of effective as well as efficient approaches for promoting electricity
generation from renewable sources. Subsequent to a brief overview of the support schemes used
in the Member States, which is meant to explain the spectrum of the approaches followed in
the Union for promoting electricity generation from renewable energies (refer to 6.2 for this),
basic considerations about the conflict between desired increased efficiencies of harmonisation
and possible disadvantages of a premature harmonisation have to be made (refer to 6.3 for this).
Based on this, a description is provided as to how the coexistence of different support schemes can
be used to determine the most efficient manner of promoting renewable energies through compe-
tition among systems (refer to 6.4 for this). This competition among systems is supplemented by
the instruments of intergovernmental cooperation included in the RES-Directive, which enable
the Member States to mutually promote renewable energies (refer to 6.5 for this).
6.2 OVERVIEW OF THE SUPPORT SCHEMES IN THE MEMBER STATES
The Member States have established different forms of support for electricity generation from
renewable energies; some of them were already established in the 1990s before the 2001/77/EC
Directive was adopted. The most commonly used measures for promoting electricity generation