German Norwegian Energy Forum Conference 2012 in Berlin

1. Michael Börner
Guarantees of Origin and their
Implementation in Germany
German Norwegian Energy Forum 23 October 2012

2. Guarantees of Origin and their Implementation in Germany
German Federal Environment Agency – Umweltbundesamt (UBA)
Central authority on environmental matters
Largest scientific environmental agency (1550 employees)
Statutory mandate: Implementation of Environmental Laws
German Norwegian Energy Forum 23 October 2012

3. Guarantees of Origin and their Implementation in Germany
German Federal Environment Agency – Umweltbundesamt (UBA)
Location: Dessau
(Saxony-Anhalt)
Dessau
German Norwegian Energy Forum 23 October 2012

4. Guarantees of Origin and their Implementation in Germany
Structure
1. Legal Fundamentals
2. German GO System
3. Issuance and Transfer
4. Use and Cancellation
5. Import and Export
German Norwegian Energy Forum 23 October 2012

5. Guarantees of Origin and their Implementation in Germany
1. Legal Fundamentals – European Community Law
Directive 2009/28/EC (“Renewable-Energy-Directive“)
Art 2 (j):
• electronic Document
• proof that a given share or quantity of energy has a special
quality
• Quality = electricity was produced from Renewables
• 1 MWh = 1 GO
German Norwegian Energy Forum 23 October 2012

6. Guarantees of Origin and their Implementation in Germany
1. Legal Fundamentals – European Community Law
Directive 2009/28/EC (“Renewable-Energy-Directive“)
Art 15 (1):
“ …Member States shall ensure that the origin of electricity
produced from renewable energy sources can be guaranteed “
Art 15 (2):
“To that end, Member States shall ensure that a guarantee of
origin is issued in response to a request from a producer of
electricity from renewable energy sources “
German Norwegian Energy Forum 23 October 2012

7. Guarantees of Origin and their Implementation in Germany
1. Legal Fundamentals – German Law
Renewable-Energy-Sources Act (EEG 2011)
EEG implements European Community Law (2009/28/EC)
Art 55 EEG governs GO in Germany
UBA is competent body
Energy-Industry Act (EnWG 2011)
Art 42 EnWG rules electricity labelling in energy suppliers bills
UBA-GO must be used for disclosure
mandatory only for Electricity from Renewable Sources that was
not supported by feed-in tariff or market premium in Germany
German Norwegian Energy Forum 23 October 2012

8. Guarantees of Origin and their Implementation in Germany
Outline Legal Fundamentals German GO System:
2009/28/EC 2009/72/EC
RES-Act (EEG) Energy Industry Act
HkNV
Herkunftsnachweis- Fee regulation (HkNKostV)
Durchführungsverordnung
(Executive regulation)
German Norwegian Energy Forum 23 October 2012

9. Guarantees of Origin and their Implementation in Germany
2. Outline German GO System:
German Norwegian Energy Forum 23 October 2012

10. Guarantees of Origin and their Implementation in Germany
3. Issuance and Transfer of GO
scheme of GO in Germany is voluntary for plant operators
• either GO
• or EEG-feed-in tariff or market premium
for reasons of correctness of the register
• some plants need an audit by environmental auditors
• UBA issues on electricity production data of grid operators
GOs are tradable
• trading activities in Germany, European Union, European Economic
Area (= Norway) and Switzerland
German Norwegian Energy Forum 23 October 2012

11. Guarantees of Origin and their Implementation in Germany
4. Use and Cancellation of GO
Basic rule: GO in Germany “has the sole function of providing proof […] for
the purpose of electricity labeling […] that a given share or quantity of
electricity was produced from renewable energy sources” (Art 3 Nb 4c EEG)
Use:
Declaration of an energy supplier…
… to use GO for the disclosure of a specific amount of electricity in a
specific year
Use only for calender year of electricity production
German Norwegian Energy Forum 23 October 2012

12. Guarantees of Origin and their Implementation in Germany
4. Use and Cancellation of GO
Basic rule: GO in Germany “has the sole function of providing proof […] for
the purpose of electricity labeling […] that a given share or quantity of
electricity was produced from renewable energy sources” (Art 3 Nb 4c EEG)
Cancellation:
must be requested when GO is used
cancelled GO cannot be transferred or used anymore
German Norwegian Energy Forum 23 October 2012

13. Guarantees of Origin and their Implementation in Germany
4. Use and Cancellation of GO
Only energy suppliers are allowed to use and cancel GO
Energy suppliers need their own account, but can make use of service
providers
Production period: 1 month
Life period: 12 months after end of production period
German Norwegian Energy Forum 23 October 2012

14. Guarantees of Origin and their Implementation in Germany
5. Import and Export
Art 15 (9) Directive 2009/28/EC:
“Member States shall recognise guarantees of origin issued by other
Member States in accordance with this Directive […].”
Germany will recognise GO from EU, EEA and Switzerland, when in
line with Directive 2009/28/EC
• no well-founded doubts about accuracy, reliability or veracity
• safe and reliable GO system in exporting country
• electricity is not disclosed as Renewable Energy in exporting
country
German Norwegian Energy Forum 23 October 2012

15. Guarantees of Origin and their Implementation in Germany
5. Import and Export
UBA-register is only for GO for Electricity from Renewable Sources
No other renewable energy cerficates accepted
No certificates for fossil, nuclear or other forms of energy
technical implementation: in discussion with AIB about conditions of
using AIB hub for international transfer
German Norwegian Energy Forum 23 October 2012

16. Guarantees of Origin and their Implementation in Germany
5. Import and Export – Role of Norway
Source: AIB Newsletter, Vol 5, 06.07.2012
German Norwegian Energy Forum 23 October 2012

17. Guarantees of Origin and their Implementation in Germany
5. Import and Export – Acceptance of Norwegian GO
Avoidance of double counting of GO
GO in Norwegian register can be transfered to a foreign country,
although they were already used for the residual mix calculation
Possibilty that these GO were used again for disclosure in a foreign
country (double counting)
Flanders regulator refused Norwegian GO that were exported after
being used for Norwegian electricity disclosure
Recommendation: export to Germany should be finished before the
date of usage in Norwegian register (28 February)
German Norwegian Energy Forum 23 October 2012

18. Guarantees of Origin and their Implementation in Germany
German Register for Guarantees of Origin for Electricity from
Renewable Sources – Herkunftsnachweisregister (HKNR)
www.hknr.de
German Norwegian Energy Forum 23 October 2012

19. Guarantees of Origin and their Implementation in Germany
Thank you for your attention!
German Norwegian Energy Forum 23 October 2012