SuperNode has responded to the European Commission’s consultation on the draft Delegated Regulation on the Emissions Trading System (ETS). The Delegated Act governs the rules for the ETS Innovation Fund, including the evaluation criteria for qualifying technologies.
The Innovation Fund is the flagship funding device of the European Green Deal and is intended to fund commercial demonstration of innovative low-carbon technologies and industrial solutions to decarbonise Europe. SuperNode, along with currENT, the Brussels-based association of innovative grid technology companies, has repeatedly called for adjustments to be made to better support innovation in electricity transmission technology.
Welcoming the revision, SuperNode writes in its submission:
“There is strong need for applying far more flexibility in the evaluation criteria, which mandate detailed avoidance of greenhouse gas emissions (GHG). These are almost impossible to assess in the case of enabling technologies such as innovative grid technology based on superconductors. The result is a sometimes arbitrary project and technology selection process that ignores the long term benefits and carbon reduction potential of many enabling grid technologies.”
“Applying the GHG emission reduction criteria of Delegated Regulation 2019/856 simply does not return the needed thresholds with high enough confidence, because electricity grids are enabling technologies. Carbon emitting technologies with emission reduction potentials such as for CCS and hydrogen technologies are the main beneficiaries of EU funding.”
SuperNode points to analysis showing that “of the €3.1 billion allocated since 2020, 74% of total funding has gone to Hydrogen (24%) and CCUS (50%) Projects, while Renewables and Storage has only received a combined 18 % of funding.
Enabling technologies like grid innovations face challenges in meeting the GHG avoidance criteria, despite playing a pivotal role in driving the energy transition towards decarbonisation. The Innovation Fund needed a revision to provide better access to these enabling technologies. In this regard, SuperNode welcomes the proposed addition to Article 11, introducing the possibility of sector specific calls with altered criteria. These sector-specific calls could possibly offer a broader pathway for qualification, opening the door for critical enabling technologies.
The current criteria in Article 11 do not fit enabling technologies, including innovative grid technologies, which are viewed by the European Commission to be one of eight technologies, vital for delivering on Europe’s carbon mitigation and energy independence efforts.
SuperNode would have ideally liked to see the introduction of a new additional Article (Article 11a) for enabling technologies, that excludes the 2 existing GHG avoidance criteria. The current revision proposes ‘…additional award criteria or requirements’, which would be considered alongside the 5 current criteria. SuperNode proposes that this language is replaced by ‘…adjusted award criteria or requirements..”. This would exclude the two GHG avoidance criteria, providing much more clarity and stronger engagement signals to grid innovation companies.
SuperNode also welcomes the addition to Article 11, 1(d) which now reads (addition in bold):
“technical and market potential for widespread application or replication, or for future cost reductions; and in terms of the proposed projects’ potential to address multiple environmental impacts and its contribution to the EU’s zero pollution and circularity objectives;”
This broadens the scope of the criteria from focusing on cost reductions to technologies that have wider environmental impact. This a positive move and more in line with the goals of the Green Deal and the Net Zero Industry Act.
SuperNode’s superconducting transmission technology offers huge benefits beyond just cost reductions with the capacity to deliver bulk power with reduced losses, costs, space, materials, infrastructure and environmental footprint compared to conventional cables.
You can view SuperNode’s full response here: Draft Delegated Act: Innovation Fund
You can view the EU Delegated Act Document here: EU Delegated Act on the ETS Innovation Fund