Open letter of NGOs about the project of “National action plan on renewable energy sector till 2030”

We, men and women, representatives from Ukrainian civil society, fairly welcome the completion of “National Action Plan of development of renewable energy sector till 2030”.

The proclamation of ambitious national objective in renewable energy sector is key factor of fulfillment of Ukrainians obligations within Paris climate agreement on decrease of carbon emissions by 65% compared to 1990 by 2030 already, as it is precisely energy sector that generates 67% of total carbon emissions and thus provokes the most dramatic climate change. As a country that approaches the integration in energy market of European Union, we likewise have to properly fulfill our obligations towards Energy Community: improve energy efficiency and increase renewables share in total energy bulk. Though, we, the representatives from publicity, are deeply concerned, as objectives set in draft Plan by State Energy Efficiency Agency are not ambitious enough and do not consider Ukraine’s full potential regarded to transition to renewables. In last five years renewable energy technologies turn out to become world’s cheapest energy sources, therefore, ambitious objectives on renewables are economically, not only ecologically, justified. Renewable energy branch means new vacancies and less energy dependence. The development of renewable energy sources is set prior within Ukraine’s Strategy of energy security, approved by the government in 2021.

Proceeding from above-said, we insist on review of objectives regarded to renewable energy sector and set forth in draft National action plan on renewable energy sector till 2030, and update to more ambitious ones. Additionally, we propose the following measures to be included in action plan:

  1. Increase of renewables share by 30% in end-user consumption

The development of renewable energy sector in Ukraine has to be more ambitious. The EU, even before announcing Green Deal in 2020, has set renewables share at level of at least 40% by 2030, that may be reviewed and increased. Ukrainian objectives on renewables by 2020 were 11%, similar as, for example, in Malta and Liechtenstein, and significantly less than in other EU countries. Increase of renewables share within energy system has no technological limits, what is proved by Germany with its eighty million people, as for now country’s renewables share makes up 48%, and there are days when 100% electricity is produced from renewables. Considering this, we propose increased renewables share by 2030 for end-user consumption at level of at least 30%. Accordingly, renewables share in electricity production has to make up at least 30% by 2030. Considering Ukrainian government obligations to refuse from coal power stations by 2035, renewables share in heat generation must be at least 30% and 15% for traffic.

According to the research «Ukraine’s transition to renewable energy by 2050» completed by scientists from Institute of economics and prognostication, Ukrainian National Academy of Sciences, initiated and supported by Ukrainian office of Heinrich Boell Fund, the revolutionary scenario says that science-based renewables share for end-user consumption is 91% by 2050.

  1. Achievement of objectives on renewables technically expedites refusal from coal

Ukraine has proclaimed before world community the refusal from coal in energy sector and shutdown of obsolete, worn-out, insecure and unprofitable coal power facilities. Recently Ukraine has joined Powering Past Coal Alliance (PPCA), and named year 2035 — ultimate deadline for refusal from coal. Consequently, it is necessary to start replacing coal with facilities of other kinds. In 2020 Ukrainian power stations have produced 27,2% electricity. And the most profitable is precisely the replacement with renewable power.

This step is appropriate not only within climate framework, but within economical one, too. Solar and wind energy is 2,5 times cheaper than generated from coal, and more than 4 times cheaper than nuclear power. Ukraine has high potential to develop solar and off-shore wind energy sectors. The use of energy accumulation systems and anticipated synchronization with ENTSO-E will substantially simplify integration renewable facilities in grid.

  1. Development of decentralized energy generation and implementation of brand new development of renewable energy generation, as stipulated by obligations before the EU

As stated in draft “National action plan on renewable energy sector till 2030”, private generation of renewable energy makes up only 2,5% of country’s renewables facilities. At the same time, EC’s 4th Energy Package, which is soon to be implemented in Ukrainian legislation within obligations on EU association, names decentralized generation among the basic components of European Green Deal.

For now, the only way to support renewables power stations under 1 MW of capacity is «green» fee, which expires in 2030. But this is insufficient to strengthen private producers of clean electricity, especially when stable purchasers remain in debts for produced electricity.

Also, we propose to supplement list of actions within the Plan with development and implementation of guarantees for “green” electricity through establishing corporate РРА (power purchase agreement) and net energy billing. These tools belong to worldwide practice.

Considering the above-mentioned, we utter our concern about insufficiently ambitious objectives on renewable energy sources set forth in draft “National action plan on renewable energy sector till 2030” and claim for more transparent completion of energy-related documents – like NAP RES and climate, Ukrainian energy strategy 2050 – with involving broad publicity in elaboration of their updated versions.

zvernennia-nats-plandiy-vde-12-2021 (download letter)

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