Dentons Guide To Investing in Renewable Energy Projects in Europe 2022 - English (5400772.1)

Investing in
renewable energy
projects in Europe
Dentons’ Guide 2022
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Welcome
2021 was a year of unprecedented, There is no easy or quick remedy

even surprising developments in the to address all these developments.
European energy sector. Renewable It requires persistence and effort, with
energy investments continued their important solutions already in our
strong growth while the EU presented hands: an improved playing field for
a new, comprehensive framework: subsidy-free RES generation assets,
the “Fit for 55” legislative package— increasingly paired with storage
which encompasses numerous tools and sector-coupling solutions, rapid
and solutions to achieve the tougher market development for corporate
emissions reduction targets set for PPAs and the maturing use of
2030, to bring climate neutrality goals hydrogen as a stabilizing fuel, which
within reach by 2050 and to deliver eventually will support replacing
on the European Green Deal. natural gas as a transition fuel to
achieve full carbon neutrality.
Almost immediately that vision was
tested by European energy markets, I trust that our Guide—this time
and by Q4 2021 the rising global covering 24 jurisdictions—and
demand for energy gave a huge Dentons’ energy lawyers across
boost to gas and power prices. Europe will help you achieve your
It clearly evidenced how susceptible goals, navigating through the fast
markets are to CO2 and other changing and challenging yet very
decarbonization costs and how much promising European environment
our future depends on a diverse, yet of renewable investments.
stable, fossil-free generation base.
Arkadiusz Krasnodębski
The challenge remains how to shape
Co-head of Europe Energy group,
it without jeopardizing the security
Dentons
and sustainability of energy supplies
that, so far, in many regions has
resulted in falling back on fossil
fuels and nuclear.
dentons.com • 3
Let’s help Europe go electric
People are thinking about energy If we want to decarbonize our

more than ever. economies and be less dependent
on imported oil and gas, we have
The rise in energy prices has really
to increase electricity’s share of
focused minds, both in governments
our energy mix. Electric cars.
and on the streets. Everyone is clear.
Electric heat pumps in our homes
High natural gas prices are the
and offices. Electric boilers in our
problem. That is what has pushed
heating systems. And manufacturing
up electricity prices. Europe is
powered by electricity.
consuming and importing too
many fossil fuels. And we cannot The European Union fully understands
let that continue. this. They want electricity to be three
quarters of our energy mix by 2050.
We need more renewables, and
They want our transport, buildings
we need them quickly. The climate
and industry to run 57 percent on
crisis only reinforces this urgency.
electricity, with another 18 percent
We certainly have the ability to meet
running on hydrogen produced
this challenge.
from electricity.
Renewables now represent around
And where is all this electricity going
40 percent of the electricity we
to come from? The EU wants half
consume in Europe. That isn’t bad.
of it to come from wind. This gives
But electricity is still only one quarter
us huge opportunities and a huge
of all the energy we consume.
responsibility. The EU wants a huge
The rest is the petrol we put in our
increase in offshore wind. And an
cars, the gas boilers that heat our
even bigger increase in onshore wind.
homes, the fossil fuels that still power
much of our industry, our ships All of this is affordable. We have the
and our airplanes. technology. The financing is available.
By the end of 2021 Europe will have
4 • dentons.com
installed around 16 to 19 GW of wind Then, we need to help those energy
capacity, on- and offshore combined. consumers who want to go electric.
That is better than the 14.7 GW in First, the industries that want to
2020. But that is still not enough. decarbonize and that are knocking on
our door looking to sign PPAs.
The European Commission says we
In 2021 alone, we have seen more
need 374 GW of onshore wind and
than 6 GW of PPAs signed
79 GW of offshore wind to deliver the
—one-third of the total cumulative
EU’s 55 percent emissions reduction
contracted capacity in Europe.
by 2030. So the EU27 will need to
And we are seeing more industries
add on average 30 GW of on- and
than ever before getting involved,
offshore capacity every year by 2030.
including rail, steel and paper, as well
We expect to install about 20 GW
as public authorities.
across all of Europe in 2022, of which
15 GW will be in the EU27. This means We also need to help those who are
that the European Union needs to building the infrastructure to electrify
double its annual installation rate. transport and heating, and the
hydrogen providers who want to run
The main challenge is the
their electrolyzers on wind.
permitting—we need simpler rules
and procedures and more staff in These people want wind.
the permitting authorities. We also Governments want more wind.
need to invest more in grids. And we Communities want wind.
need to take care of our supply chain
Let’s make it happen.
and invest in our workforce and skills
to ensure that Europe continues to Let’s help Europe go electric.
benefit from the energy transition,
Giles Dickson
both in terms of the environment
CEO, WindEurope
and society in general.
dentons.com • 5
2021: A record-breaking year
for European solar, time to give
ambition full rein!
Solar power in the European Union France (2.5 GW). In a surprise for the
has once again turned in a stellar sector, the Netherlands overtook
performance in 2021, despite Germany for installations per capita,
adverse market conditions on various reaching 765 W/capita, 42 percent
fronts—the continued negative up from 2020.
effects of COVID-19 on our daily
In 2021, the Top 5 solar PV markets
lives, PV product supply shortages
in the EU stayed the same, and
as well as consequent solar module
among the Top 10, there are only
price hikes.
two newcomers, both from northern
Demand for solar power in the Europe (Denmark and Sweden),
European Union has grown replacing two established PV markets,
significantly in 2021. The 27 member one in western Europe (Belgium), the
states of the European Union other in the south (Portugal). In 2021,
together saw around 25.9 GW 25 of 27 EU member states deployed
of new solar PV capacity connected more solar than the year before.
to their grids in 2021, an increase of
For most member states, we again
34 percent over the 19.3 GW installed
expect more power additions
the year before. This growth makes
in our four-year installation
2021 not only another record year for
forecasts. Backed by the ambitious
solar in the EU, it was also the best
announcement from Germany’s
year in history, breaking the decade-
new government to double its solar
long record from 2011, which saw
2030 target to 200 GW, Europe’s
21.4 GW installed.
leading market will become even
Germany is again Europe’s major more central to the continent’s solar
solar market in 2021 with 5.3 GW of sector. Germany is expected to install
newly installed capacity, followed 47.7 GW by 2025, almost as much
by Spain (3.8 GW), the Netherlands as we forecast for the three following
(3.3 GW), Poland (3.2 GW) and
6 • dentons.com
solar markets combined—Spain, the solar sector. By 2030, the EU needs
Netherlands and France. to operate 870 GW of solar capacity
across the continent to enable the
Our PV market scenarios 2022 to
most cost-efficient trajectory to
2025 show continuous, two-digit
climate neutrality in 2050 and meet
annual growth rates that are all
the 1.5°C Paris target. To achieve
slightly higher than in our previous
this, the EU must adopt a minimum
edition. The medium scenario now
45 percent renewable energy target
forecasts 18–20 percent growth rates
by 2030, up from the European
compared with 16–17 percent levels
Commission’s 40 percent target
last year, adding around 162.7 GW,
proposed in the revised Renewable
and with cumulative EU solar capacity
Energy Directive. A higher renewables
reaching 327.6 GW by the end of
target can be met through effective
2025. According to our modelling of
implementation of the EU’s Clean
the medium scenario up to 2030, the
Energy Package and by introducing
total solar fleet in the EU will continue
policies that reflect the European
its strong growth to 672 GW by the
Green Deal ambitions. We have no
end of the decade, with the annual
time to lose in the green transition,
installation rate reaching more
we must increase our ambitions and
than 85 GW.
accelerate the move to renewable
European solar continues to outshine energy—starting with a European
expectations; 2021’s achievements 45 percent renewables target
also extended to breaking a decade- for 2030.
long record to connect 25.9 GW to
Walburga Hemetsberger
the grid. We estimate that Europe’s
CEO, SolarPower Europe
solar fleet will double in only four
years, reaching 327.6 GW by 2025.
If we are to learn from these
numbers, it is only realistic to be
more ambitious. While many member
states are already on track to hit their
National Energy and Climate Plans
(NECPs) solar targets, we can and
must push those goals further.
That is why we call on the European
Commission and the member states
to put much more ambition into the
dentons.com • 7
New energy transition investment in Europe (EU-27, UK, Norway and Switzerland)
Including CCS, electrified heat, electrified transport, energy storage, hydrogen, nuclear,
sustainable materials, renewable energy
Source: BloombergNEF
US$ billion
197,75
200,00
176,07
150,00
99,39
100,00
90,99
86,26
84,67
74,72 73,07
69,07
50,00 49,40
0,00
12
13
14
16
17
18
19
20
12
1
20
20
20
20
20
20
20
20
20
20
Germany United Kingdom France Spain Netherlands Sweden Italy Finland
Norway Poland Denmark Others
8 • dentons.com
New energy transition investment in Europe (EU-27, UK, Norway and Switzerland), 2021
US$ billion
50,00
47,45
40,00
31,02
30,00
26,66
20,82
20,00
11,22 10,92 10,89

10,39
10,00
8,32 7,88
6,82
5,36
0,00
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CCS Electrified heat Electrified transport Energy storage Hydrogen
Nuclear Sustainable materials Renewable energy
dentons.com • 9
Floating offshore energy
technologies: Unlocking
the potential
The main factor driving floating to creating a model for FOW
offshore wind (FOW) is society’s need deployment. We at Ocean Winds
to rapidly decarbonize in the face of (OW) have been working in this
rising climate change concerns. To direction for 10 years, from our first
meet current and future emissions operational FOW farm in Europe,
reduction targets all renewable Wind Float Atlantic (25 MW, Portugal)
energy sources have to be deployed, to our most recent Leucate (30 MW,
including offshore wind, which enjoys France) project which is about to
the highest load factors among all begin construction. OW has a huge
technologies and can be rolled out development portfolio of floating
without the constraints so often projects and we are now looking
found onshore. FOW unlocks the at GW-scale projects, such as our
potential of wind resources in deep recent bid in ScotWind to produce
waters and will open up opportunities a combined capacity of 6 GW.
locally and globally across different
A number of trends and some major
supply chains.
developments can already be seen.
FOW needs to shift to a commercial Bankable projects are emerging
scale in order to achieve cost that meet the lending standards
reductions. In the 2020s, total of financial institutions. The UK,
offshore wind installed capacity France and Norway are launching
must increase fivefold, from 26 GW Contracts for Difference (CfDs)
today to 111 GW, with the growth rate and lease auctions for commercial-
accelerating rapidly after 2030. scale ventures. This is the result of
appropriate site selection, reliable
Government action is crucial
technology and the expertise of
to achieve the right conditions
the developers and construction
for scaling up, and pioneering
firms involved.
commercial projects are key
10 • dentons.com
Moreover, new FOW technologies As bottlenecks are expected when
are developing worldwide. At OW, competing with the current up-
we monitor all developments: thus cycle of the maritime and oil and
far we have assessed more than gas industries due to the move to
18 concepts and are keeping our commercial scale, to overcome
eyes on more than 40 emerging challenges on the supply side, we
technologies. This overview is should explore FOW concepts that
essential for selecting the best rely on additional industries (e.g.,
technologies for the local conditions. tubular manufacturing, concrete and
We participate in R&D and are active fiber manufacturing).
members of several working groups.
Industry and experts agree that the
These are vital to developing best
cost of FOW could be in the range
practices in the sector, setting
of €53–76 per MWh by 2030, less
standards, understanding in detail
than half the cost of today. The
the driving loads and fostering
main drivers for this cost reduction
enabling technologies. The industry
include leaner floater and mooring
is gearing up for large-scale
designs, optimized manufacturing
commercial projects planned
and assembly, and moving from
for the 2030 timeline.
“one-off” production series to serial
To improve planning certainty and production. But to achieve an even
help industry achieve economies of playing field where bidders can
scale, governments should allocate choose foundations based on site
sufficient space for projects in their conditions—without technology
renewable energy targets and set access being a constraint—will
a clear schedule to auction them require technology-specific auctions
(combined with remuneration in the first place.
schemes to stabilize revenues).
Grzegorz Górski
This would give a clear signal to make
COO, OW Ocean Winds
investments in new technologies,
production sites, infrastructure
upgrades, operational capacities, etc.
dentons.com • 11
Corporate PPAs are now
a must-have
Corporate Power Purchase Germany, Denmark, and with further

Agreements (CPPAs) are on the rise new CPPA deal activity also in Poland,
in Europe. Despite the COVID-19 France and Italy.
pandemic and unprecedented
Secondly, the customer landscape
price volatility in European energy
and needs are broadening.
markets, the European CPPA market
Historically, large tech companies
is booming. A total volume of 8.6 GW
such as Amazon, Google and
of CPPAs were signed in 2021 in
Microsoft and a few large industrials
Europe (according to BloombergNEF),
have dominated and driven the
surpassing the 7.2 GW volume of
European CPPA market on the
CPPAs that were closed in Europe
demand side. Now, though, there is
in 2020.
a far more diverse group of corporate
The European CPPA market is buyers—including consumer goods
evolving along three dimensions: companies, chemical companies
Firstly, it has diversified and various heavy industries. With
geographically. Historically, the ambitious sustainability targets, their
Nordics were the largest and renewable energy demand is high.
most dominant CPPA markets in
Thirdly, corporates increasingly
Europe. But in the last two years
value sophisticated aspects, such
Spain has taken over the leading
as additionality and time-matching,
European CPPA market position
to achieve the best green credentials.
with a CPPA volume of 2.2 GW
Additionality implies that the
in 2021, mostly from solar. Other
CPPA is key to the realization of
European CPPA markets also
new renewable assets, while time-
showed growing momentum in
matching means that contracted
2021, with deal volumes increasing
electricity is supplied at the same
in the Netherlands, UK and Ireland,
time it is consumed.
12 • dentons.com
Corporate PPA volumes in Europe (EU-27, UK, Norway and Switzerland), 2021
Onsite PPAs not included
MW
3,000
2,198
2,000
1,678
1,251
1,000
711
631
574
292 273
243 240
217 200
87
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dentons.com • 13
Summing up, CPPAs have These types of partnerships are
evolved from a “nice-to-have” to therefore a great opportunity for
a “need-to-have” for offtakers, while society. Not least since they can
also offering an attractive alternative accelerate the transition by supplying
to state subsidies for developers the needs for renewable energy
(subsidies are often constructed like outside of government tenders
a PPA with the state). CPPAs enable to, for example, fuel electrolysis
the developer to de-risk the growing for hydrogen and green fuels. The
European pipeline of merchant next step then is to unlock grid and
projects and secure fixed revenue permitting bottlenecks. Why not give
streams, which make merchant consumer-developer partnerships
projects investible. For the corporate access to sites if they can organize
buyer, CPPAs secure their supply the matching of supply and
of green and affordable energy, demand with minimal impact
allowing them to stay competitive in on the transmission grid?
a world that increasingly demands
CPPA partnerships between offtakers
green products. And for society,
and developers have evolved to
they offer a powerful supplement
a “must-have” to drive the energy
to state-sponsored buildout of
transition. Corporate-developer
renewable energy.
partnerships now need to jointly
Let’s look at an example: BASF and work together to identify new sites
Ørsted have concluded a 25-year for renewable energy projects,
fixed-price CPPA, under which BASF where grid connections between
will offtake the output of 186 MW from offtakers and renewable electricity
Ørsted’s planned 900 MW Borkum producers can be made with minimal
Riffgrund 3 offshore wind farm in the need for further reinforcements of
German North Sea. This CPPA, plus the surrounding transmission grid.
CPPAs with other corporate buyers In addition, new CPPA product
such as Amazon, Google, EHA/Rewe structures will enable European CPPA
Group and Covestro, enabled Ørsted markets to keep up their growth
to take the final investment decision momentum and to thrive.
on Borkum Riffgrund 3, the first
Ulrik Stridbæk
offshore wind project to bid zero in an
Vice President,
auction in Europe, and to jointly drive
Head of Regulatory Affairs,
the buildout of new renewable assets
Ørsted
and the energy transition.
14 • dentons.com
New renewable energy investment in Europe (EU-27, UK, Norway and Switzerland), 2021
US$ billion
14,00
12,35
12,00
10,00
9,53
8,00
7,17
6,29
6,08 6,03
6,00
5,70
4,64
4,00 3,85
2,06
2,00 1,68
0,05
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Biofuels Biomass and waste Geothermal Small hydro Solar Wind
dentons.com • 15
EU regulatory overview
2021 marks a major regulatory shift procurement of strategic gas stock.

in the European Union’s climate In parallel, the European Commission
policy, mapping the path to a climate- and EU member states struggled to
neutral Europe. Without waiting find an immediate response to the
for the outcome of global climate exceptional rise in global energy
negotiations, the EU, in June 2021, prices, affecting both citizens and
fixed in law its goals of climate businesses across the region.
neutrality by 2050 and a 55 percent
reduction in greenhouse gas Toward a climate-neutral,
emissions by 2030. A few days later, electrified society
the European Commission unleashed and economy
a torrent of legislative proposals to
The European Climate Law, adopted
provide a regulatory framework for
in June 2021, set into law the goal
achieving these targets—the
for a climate-neutral EU society
Fit for 55 package. By December
and economy by 2050 and an
2021, the legislative train counted
intermediate binding EU target for
19 proposals of the initial package.
reducing net greenhouse gas (GHG)
This was extended by a set of
emissions by at least 55 percent by
additional proposals to decarbonize
2030, compared with 1990 levels. To
the EU’s gas market through the
achieve that, Fit for 55 goes beyond
uptake of renewable and low
the mere restructuring of the energy
carbon gases, including hydrogen,
market and fostering RES generation
as well as by cutting down methane
development. Building on the
emissions, and including sector
European Green Deal, first presented
coupling of electricity, gas and
in December 2019, the European
hydrogen in the member states’
Commission aims to expand the
National Energy and Climate Plans
decarbonization effort to the
(NECPs). Several contemplated
broader economy.
measures should increase the overall
energy security of the EU, including
the proposed voluntary joint
16 • dentons.com
Fit for 55 marks the first substantiated from renewable sources by 2030
effort to trace and price the carbon against the current 32 percent.
footprint in the global supply chain The long-term target of the offshore
through a Carbon Border Adjustment wind strategy, initially estimated
Mechanism. It includes more at 300 GW of capacity in 2050, was
direct measures involving maritime increased to between 280 GW and
transportation, aviation, revised 450 GW. Faster upscaling intensified
targets for cars and vans, expanding the discussion on regional (basin)
the EU Emissions Trading System cooperation and development of
(ETS), further decarbonizing the hybrid offshore systems, clusters
heating sector, increasing energy and energy islands, marine spatial
efficiency and improving the energy planning and sharing of marine
performance of buildings. A new resources, as well as security and
forestry strategy and amendments defense aspects of the offshore
to the GHG removal framework were investments. To coordinate efforts, in
also proposed. Finally, the European H2 2021, the European Commission
Commission addressed the broader established a dedicated working
social impact of the climate neutrality group on offshore renewable energy.
effort, focusing on policies fostering
The proposed updated 2030 RES
employment opportunities, social
goals include greater GHG reduction
potential of the green transition
targets for transportation, setting out
and its fairness.
a 13 percent target for the reduction
of the emissions intensity of transport,
RES and climate targets
including international aviation and
As predicted in 2020, the European maritime transport. By 2030 new
Climate Law increased the reduction cars could be required to reduce
target for GHG emissions by 2030 average emissions by 55 percent
from 40 to 55 percent. To reach and new vans by 50 percent
that goal the European Commission compared with 2021 levels. By 2035
proposed setting an increased target the European Commission envisages
to produce 40 percent of energy zero emissions from new cars.
dentons.com • 17
An increased effort in putting electric toward meeting the principal RES
charging and hydrogen fueling points consumption targets.
will be required to meet those targets.
Work on the Fit for 55 legislative
The European Commission is pushing package is expected to continue
for increased use of advanced at a significant pace throughout 2022.
biofuels, renewable hydrogen and
hydrogen-based synthetic fuels, Funding
proposing a target of at least
EU funding remains at the heart of
a 50 percent renewable share in
policies supporting a fair transition
industrial hydrogen consumption.
and comprehensive framework
In buildings, it wants to set at least
leading toward climate neutrality.
a 49 percent renewable share in
The Recovery and Resilience
the energy used, further amplifying
Facility entered into force on
the need for investment in new
February 19, 2021, financing reforms
renewable generation capacity.
and investments in member states
In this context, additionality and from the start of the pandemic
temporal correlation will become in February 2020 until December 31,
the key concepts for the successful 2026. In the associated plans, member
development of RES investment states allocated close to 40 percent
strategies. One EU priority is to of the €723.8 billion in loans and
develop renewable hydrogen grants toward climate neutrality
produced mainly with the help of measures against the expected target
wind and solar energy, supporting of 37 percent. The EU made up to
decarbonization of the economy, 13 percent of funds available already
especially in those sectors where in 2021 as advance contributions
electrification would prove difficult to kick‑start the recovery effort.
or not viable. For this purpose, Further disbursements will be made
additional RES generation capacity available to member states up to twice
will be required on top of the a year upon completion of agreed
renewable electricity generated milestones and targets.
18 • dentons.com
The Just Transition Fund was finally EU emission allowances and
set at €17.5 billion (in 2018 prices) energy prices
within the EU’s cohesion policy
Prices of EU emission allowances
framework, addressing disparities
soared to unprecedented levels
in regions most affected by
in 2021, rising more than double
decarbonization and the transition
year-on-year to hit more than €90
toward climate neutrality—
per tonne in December 2021. This
€7.5 billion will be financed under
was accompanied by a sharp spike
the EU’s 2021–2027 budget, while
in global energy prices, reversing the
the remaining €10 billion will be
2019–2020 trend and requiring the
made available from 2021 to 2023
European Commission to compile
as part of the European Recovery
a toolbox of short-term measures,
Instrument framework.
including emergency income
Finally, the European Commission support, state aid for companies
proposed a Social Climate Fund, and targeted tax reductions aimed
financed from the new EU Emissions at mitigating the impact on retail
Trading System for buildings prices. Toward the end of 2021
and road transport, which would member states struggled to adopt
mobilize €72.2 billion to address the a comprehensive policy response
impact of emissions trading in road to this situation.
transport and buildings on vulnerable
Michał Motylewski
households, micro-enterprises and
Europe Energy Practice Development
transport users.
Counsel, Warsaw
Dentons
dentons.com • 19
Azerbaijan
Azerbaijan has always been a key oil and gas jurisdiction and it
has great potential for RES. That said, the legal framework has
been slow to develop. But a law on renewable energy sources
was finally adopted in 2021 and landmark projects in the wind
and solar sectors were signed. RES are also being used under
a broader program of infrastructure renewal.
Share of renewable energy in electricity generation capacity

in 2020 – 17 percent*
Azerbaijan national target by 2021 – 22 percent*
Share of electricity generated from RES in total electricity
production in 2020 – 1.3 percent*
Drivers other support mechanisms, such

as scientific research and the
In July 2021 a new law, “On the Use
promotion of active consumers.
of Renewable Energy Sources in the
It provides incentives including
Production of Electricity” No. 339-VIQ,
guaranteed offtake, guaranteed
dated May 31, 2021, was signed by
connection, priority in transmission
the president of Azerbaijan and
and long-term land leases.
published. It addresses guaranteed
tariffs, foreign investment and
* Figures from Azerbaijan’s Ministry of Energy and State Statistics Committee
20 • dentons.com
Investors are selected through and operation of a 230 MW solar PV
auctions or direct negotiations, but plant. Gamma Solutions (Spain) with
the regulatory basis for RES auctions support from the Asian Development
has yet to be adopted. Direct Bank signed a pilot floating solar PV
negotiations, with the consent of project on Lake Boyukshor as part
the president, apply to pilot projects, of the regional Floating Solar Energy
projects of strategic importance or if Development Systems project.
an auction has been unsuccessful.
In the aftermath of the 2020 war in
Tariffs for electricity are calculated Nagorno-Karabakh, a “Green Energy
for each kWh transmitted to the Zone” was declared for infrastructure
network. Electricity generated development in certain regions.
from RES is sold at wholesale tariffs A concept paper for the zone was
determined by the Tariff Council prepared by TEPSCO (Japan), and
of Azerbaijan, except where the a masterplan is in progress.
investor was selected through an
Azerbaijan has committed to
auction. In that case tariffs based on
reducing its GHG emissions by
the winning (lowest) bid apply or, if
35 percent by 2030 under the Paris
through direct negotiations, will be
Agreement and, more recently,
negotiated directly with the Ministry
at COP26 it undertook additional
of Energy. Investors will be required
voluntary obligations to reduce GHG
to obtain a permit for the generation
emissions by 40 percent by 2050.
of electricity in excess of the limits
set by the Cabinet of Ministers
Constraints and risk factors
of Azerbaijan, and the design,
construction and installation of a RES Although a framework law on
facility is subject to the Town Planning renewable energy sources has
and Construction Code, together been adopted, there is lingering
with other normative legal acts and uncertainty due to the lack of
technical norms. implementing rules and regulations,
including for renewable energy
In late 2020, ACWA Power
auctions. Particular challenges relate
(Saudi Arabia) signed an investment
to the competitiveness of tariffs,
agreement, a power purchase
technology transfer issues, the need
agreement and a transmission
for more incentives and a lack of
connection agreement for a 240 MW
available financing.
onshore wind project. In April 2021,
Masdar (UAE) signed project
documents for the construction
dentons.com • 21
Belgium
Energy policy in Belgium is set at both federal and regional levels.

While all policy levels acknowledge and remain committed to
the stated RES objectives, Belgium is lagging on setting a clear
timetable to achieve them. In the meantime, the Belgian Capacity
Remuneration Mechanism (CRM) has been launched.
Share of renewable energy in gross final energy consumption

in 2020 – 13 percent
Belgium national target by 2020 – 13 percent, with a long-term
goal of 17.5 percent by 2030
Drivers 2021, Belgium, Denmark and

Germany formalized their plans to
The largest RES component in
establish a grid connection between
Belgian energy generation remains
these three countries to distribute
hydropower, which is still smaller than
energy generated by Denmark’s
the nuclear component. 2021 saw
Bornholm Energy Island. Furthermore,
construction finish for the first wind
the EU positively advised on Belgium’s
energy zone in the Belgian North Sea.
plans to construct a multifunctional
As a result, 10 percent (in total 8 TWh)
energy island in the North Sea.
of total electricity demand is now
generated by offshore wind capacity. In November 2021, a CRM auction,
A tender procedure will commence totaling an estimated €140 million
in the next few years for the Princess was launched to ensure the security
Elisabeth Zone, which has a planned of energy supply in the coming years.
capacity of 3.15–3.5 GW. In November
22 • dentons.com
In line with plans for the development In relation to solar PV, the Belgian
of an Ostend hydrogen port, Belgium regions, which have competency over
has adopted a formal strategy to turn matters of energy policy, have begun
it into a renewable hydrogen hub. to end the existing compensation
This includes plans for large-scale schemes. This is accompanied by
export capacity for hydrogen from a gradual reduction in the number
the port of Antwerp, and several of green energy certificates.
agreements have already been
signed to supply third countries Constraints and risk factors
with hydrogen.
Despite stated commitments of the
The continued use of PPAs by Belgian governments at multiple
companies to mitigate potential levels, Belgium has not succeeded in
costs was also a feature of 2021. establishing a clear path to achieve its
ambitious energy policy. In the wake
The regulatory framework remains
of COP26, the federal and regional
largely unchanged, including the
governments did not manage to
systems for tradable renewable
reach a binding agreement on
energy certificates in all three regions
how the climate efforts for Belgium
(Brussels, Flanders and Wallonia).
in the context of Fit for 55 would
The federal government’s
be distributed.
competence covers matters related
to energy supply, nuclear plants, Against the background of a political
offshore wind farms and large energy standstill, Belgium has dropped from
infrastructure projects. Belgium 40 to 49 in the 2020 ranking of the
has signed the COP26 statement Climate Change Performance Index
signaling its commitment to adhere (CCPI), behind China and India.
to the maximum warming limit
of 1.5°C.
dentons.com • 23
Bulgaria
After a long standstill, the RES market in Bulgaria began to

recover in 2018. From 2017, the RES share increased from
18.7 to 21.6 percent, with the RES electricity share increasing
by 4.5 percent and the share for heating and cooling by more
than 5 percent. The European Commission describes Bulgaria’s
National Energy and Climate Plan (NECP) as “adequate.” Fit for 55
requires a further increase in the RES share, to be driven mainly
by RES electricity generation, from the current RES electricity
pledge of 30.33 percent provided in Bulgaria’s NECP 2030 to
37.5 percent under Fit for 55. This should boost the development
of large-scale solar PV and onshore wind projects in the
coming years.

in 2020 – 23.3 percent
Bulgaria national target by 2020 – 16 percent, with a long-term
Drivers prices are the lowest. Therefore, the

pledge under Fit for 55 to increase
At 20.9 percent Bulgaria’s share
RES electricity by 14 percent between
of GDP spent on energy system
2020 and 2030 will be driven by
services in 2020 is the highest in the
levelized costs of energy (LCOE).
EU, although household electricity
Aging lignite power plants face
24 • dentons.com
increasing economic pressure, Currently, district heating systems are
opening a window for future 65 percent gas-fired, while the share
zero‑emission generation. Renewable of solid biomass in heat generation
options compete with the extension is more than 30 percent. Highly
of the 2 GW Kozloduy nuclear efficient cogeneration plants are
power plant. However, Kozloduy rare. Bulgaria has an issue with its air
faces serious security issues and quality and has old-growth forests
still lacks a financial model for its to be protected. Urgently required
modernization. The country has modernization of centralized district
recently shown interest in extending heating systems will face economic
the partnership between Romania problems resulting from a predicted
and the U.S. to commission small population decline of half a million
modular reactors. Nevertheless, by 2030. For this reason, further
large‑scale solar PV and large exploitation of biomass in centralized
onshore wind farms with low LCOE district heating systems might not
should have a competitive advantage. be an option. Alternatives include
Bulgaria’s NECP will introduce a RES decentralized low temperature
tender support system to boost grids with heat generation by heat
renewable power deployment. pumps, which will drive demand for
Offshore wind could also become an cheap electricity.
option to replace lignite. According
to the TSO, Bulgaria will increase Constraints and risk factors
the installed capacity for renewable
Bulgaria’s grid network must
energy from 1.8 GW to 4.3 GW
be modernized before further
by 2024.
deployment of utility-scale renewable
In 2020, Bulgaria liberalized its energy generation can be carried
power market, and since October out. Requests for grid connection by
2020 all non–residential electricity RES quadrupled between 2020 and
customers have been required to buy 2021. The share of network charges
electricity through the Independent in household electricity prices is the
Bulgarian Energy Exchange (IBEX). lowest in the EU, so new investments
In October 2021, IBEX also introduced in grids will be driven by EU grants.
day-ahead market coupling with
Romania to increase competition.
dentons.com • 25
Croatia
The RES market in Croatia is one of the best developed

in the region. While the overall RES share has stayed constant
at 27.3 to 29 percent over the last five years, the RES electricity
share increased between 2017 and 2019 by 3.4 percent to
almost one-half of power generated. The European Commission
describes Croatia’s National Energy and Climate Plan (NECP)
as “sufficiently ambitious,” which is unique for Central, Eastern,
and Southeastern Europe. Fit for 55 requires an increase in the
RES share, to be mainly driven by RES electricity generation, up
from the current RES electricity pledge of 63.8 percent, provided
in Croatia’s NECP 2030, to 70.8 percent under Fit for 55. Good
news for large-scale solar PV and onshore wind projects in the
coming years.

Croatia national target by 2020 – 20 percent, with a long-term
Drivers Krško in Slovenia and one hard

coal‑fired power plant. Liquidity of the
Croatia’s capacity portfolio is
Croatian power exchange CROPEX
characterized by intermittent hydro,
increased significantly, following the
with some gas-based capacities.
connection of day-ahead markets
Conventional baseload plays only
at the border between Croatia and
a small role—there is a co-owned
Slovenia. Market integration activities
nuclear power plant located in
should continue, with the aim of
26 • dentons.com
achieving full integration into the EU and cooling using waste heat from
internal market, primarily through rivers, lakes and sea water in Adriatic
integration with the highly priced waterfront areas. Decarbonization of
Hungarian day-ahead market. Market district heating will drive deployment
integration with Serbia and Bulgaria of decentralized low-temperature
should be achieved in a relatively grids with heat pumps as the
short time. Onshore wind and solar energy source.
PV capacities have been growing
E-mobility is also a big topic, partly
robustly in recent times, to more than
driven by Rimac Automobili, a major
700 MW in onshore wind farms and
automotive producer in Croatia.
about 100 MW in solar PV plants. For
Direct electrification of heat and
2020–2030, the combined feed-in
transport should boost electricity
and premium tariff quotas are set
demand in the coming decade
at 2,265 MW (total connection power
although the 2030 forecast in
of production facilities eligible to
Croatia’s NECP is less ambitious.
bid for incentives). Of this, 1,075 MW
The Croatian government initiated
is reserved for solar and 1,050 MW
a procedure to adopt the country’s
for wind power plants. However,
hydrogen strategy for 2021–2050.
a support system to stimulate
Also, offshore wind could eventually
investments in large RES plants
play a role, as LIDAR measurement
is not yet in place.
devices have now been installed in
District heating systems are the North Adriatic to measure wind
85 percent gas-fired with additional speed and direction.
heat generation delivered by oil
boilers. Renewable energy does Constraints and risk factors
not play a role in heat generation.
Administrative barriers and an
However, Croatia is a target country
incomplete regulatory system remain
for the Upgrade DH project of
major issues for the development
the European Commission and is
of RES projects in Croatia. Sector
currently preparing its first project in
associations maintain that grid
Sisak, where thermal storage units
infrastructure is not ready for wind
and solar thermal collectors will be
and solar power potential, which,
joined to the existing system in an
studies say, could range between
effort to reduce fossil fuel use and
7 GW and 9 GW, and planned
reduce heat losses. Additionally, the
investments in infrastructure are
Croatian government issued a public
insufficient for such deployment.
call for projects to provide heating
dentons.com • 27
Czech Republic
In 2020, RES hit a 17.3 percent share of gross final energy

consumption in the Czech Republic, surpassing the national
target for 2025. To attain the national goal of 22 percent by 2030,
expenditure of €25.5 billion will be needed (with €6.2 billion from
public funds). In Q4 2021, the newly passed Promoted Energy
Sources (Amendment) Act established the rules for supporting
the future development of solar PV, wind, small hydro and
biomass power plants. Moreover, the launch of allocations from
the EU Modernization Fund will result in massive financial support
for the sector, setting the stage for robust RES growth.

Czech Republic national target by 2020 – 13 percent, with a long-term
goal of 22 percent by 2030
Drivers new non-fueled RES, modernize heat

supply networks, improve energy
The EU Modernization Fund supports
efficiency and reduce industrial GHG
the transition of 10 states to climate
in installations included in the EU ETS.
neutrality. The Ministry of the
The second project registration wave
Environment of the Czech Republic
is open until February 2022 and the
has released the first batch of funds
third is expected in H1 2022.
to subsidize projects that will develop
28 • dentons.com
It is estimated that in 2021–2030 One notable development occurred
up to CZK 150 billion (€5.72 billion) in the hitherto quiet PPA market. In
will be made available from the 2021, the first major corporate PPA
EU Modernization Fund to public was concluded between ŠKODA Auto
and private investors, with at least and Ambient Energy. This agreement,
CZK 58 billion (€2.23 billion) allocated signed by the largest employer in
to RES. The final amount will depend the country, has the potential to
on multiple factors, including accelerate the PPA market in the
fluctuation in the price of emission Czech Republic. In light of this we may
allowances, as their sales finance expect an upward trend in this area,
the fund allocations. The amount considering the presence of other
and wide availability of EU funds will relevant market stakeholders that
therefore make the Czech Republic could clearly benefit from PPA deals.
an attractive market for investing
in RES. Constraints and risk factors
An amendment to Act No. 165/2012 The amended Promoted Energy
Coll., the Promoted Energy Sources Sources Act addresses the issue of
Act, introduces new types of overcompensation, especially for RES
incentives for RES in the Czech projects commissioned before 2016.
Republic, such as (i) a subsidy for The appropriateness of subsidies
the use of biomethane in transport will be re-evaluated based on their
and (ii) auctions for annual or internal rate of return (IRR) in RES;
hourly bonuses. to be considered appropriate for
compensation the IRR must not
In Q2 2021, the government adopted
exceed values of between 8.4 and
a national hydrogen strategy—its
10.6 percent for the duration of
main goals are to reduce GHG
the right. The exact cap values for
emissions and support economic
individual types of RES are yet to be
growth, signaling that there is plenty
established. To determine the IRR,
of room for future investments.
the Ministry of Industry and Trade
Although the strategy is not legally
of the Czech Republic will review
binding, it should serve as a basis for
performance at both sectoral and
shaping hydrogen-related legislation
individual project levels, potentially
in the years to come.
resulting in an adjustment of
subsidy amounts or, in some cases,
an obligation to reimburse the
subsidy received.
dentons.com • 29
France
Photovoltaic electricity has finally taken off in France reaching

more than 18 percent of installed capacity in 2021. However,
France is still far from meeting its targets, with an attainment
rate of 16 percent for its 2023 solar PV power goal—only
hydroelectricity and methanization targets are on track.
France has also committed to reach carbon neutrality
by 2050, but how to achieve this goal depends on political
choices, and most political parties favor nuclear energy.

France national target by 2020 – 23 percent, with a long-term
Drivers mechanisms to guarantee the

traceability of hydrogen and support
In November 2021, the French
the production of decarbonized
government announced it would
hydrogen through competitive
inject €1.9 billion over five years into
procedures. Enactment decrees are
decarbonized hydrogen (as part
expected shortly. Meanwhile, GRTgaz
of the “France 2030” plan), adding
has identified 90 potential hydrogen
to the €7.2 billion strategy already
production and consumption sites.
presented in September 2020.
Ordinance No. 2021-167 sets up
30 • dentons.com
The European Commission approved Constraints and risk factors
state aid to the Normandy offshore
Social acceptance of wind farms
wind farm (1,050 MW of installed
is not improving. In October 2021,
capacity) in November 2021,
a survey found that only 64 percent
to take the form of a premium
of the French population have
granted following a call for tenders.
a “good image” of wind power.
The process is ongoing, and the
Tensions remain very high between
winner will be announced at the
offshore wind farm developers
end of 2022. From 2023, according
and fishermen, especially in
to the Multiannual Energy Program
Saint‑Brieuc Bay in Brittany, where
(MEP), a 1 GW tender will be launched
fishermen organized a number
every year.
of demonstrations and initiated
Solar PV capacity is increasing several lawsuits.
sharply, with a sustained pace for
As elsewhere in the EU,
tenders, and the feed-in tariff is
electricity prices peaked in
now available “on demand” for roof-
Q3 2021. The increase is partly
based PV plants of up to 500 MWp
attributable to the development
per installation.
of RES and associated grid operation
While the grid connection process costs. In the meantime, France’s
is usually quite lengthy, the 2019 transmission system operator, RTE,
Energy-Climate Law introduced released its report “Energy Futures
a “regulatory sandbox” mechanism in 2050,” which presents six potential
order to facilitate the implementation scenarios for reaching carbon
of innovative projects. The law neutrality in 2050. All six share
authorizes the French Energy common features (notably
Regulatory Commission (CRE) or a decrease in final energy
administrative authorities to grant consumption), but they set out
exemptions to the conditions for contrasting trends for nuclear power
use of and access to electricity and in the electricity mix. Most political
gas networks. The first applications parties are in favor of the most
concerned areas essential to the nuclear-intensive one, including
national objectives of carbon President Emmanuel Macron,
neutrality, such as electricity storage, who announced in November 2021
electric mobility, synthetic methane his plan to restart construction
injection or local flexibilities. of nuclear reactors in the country.
dentons.com • 31
Georgia
Georgia launched a large-scale energy sector reform in 2017,

when it joined the Energy Community. The reform committed
the country to move toward an alignment of its energy sector
with European Union energy market rules, and it is progressing
toward fully exploiting its energy potential and strengthening
energy security. The reform seeks to boost competition and
protect consumer rights in terms of safe, uninterrupted delivery.
The Georgian Energy Exchange will be launched at full capacity,
ensuring competitive and open market principles. From 2021 to
2026, large consumers will gradually gain exposure to the market,
depending on their size and consumption voltage.
Georgia ambitiously undertakes to increase the share of renewable

energy in total energy generation to 87 percent by 2030
Drivers the Paris Agreement and the UN

Framework Convention on Climate
In April 2021, the government of
Change. Under the NDC, Georgia is
Georgia approved the updated
fully committed to an unconditional
Nationally Determined Contribution
limiting target of 35 percent below
(NDC), with the 2030 Climate
the 1990 level of domestic total
Change Strategy and Action Plan for
GHG emissions by 2030 and plans
determining the mitigation measures
to mitigate GHG emissions
to achieve the commitments and
by 15 percent from the energy
mitigation targets envisaged under
32 • dentons.com
generation and transmission sector. A study on prospects for developing
Fulfilment of this goal is envisaged green hydrogen is to be launched
by facilitating RES generation and within the scope of the Declaration
increasing its integration capacity in of Intent signed between the MESD
the power grid. The state will provide and the German Development Bank
continuous technical and procedural (KfW) in November 2021. A pilot
support for generation, and for project will act as a pathfinder for the
implementation of the Ten-Year development of clean and renewable
Network Development Plan, energy in the country.
approved in February 2021.
New tariffs for all regulated activities
In July 2021, the Ministry of Economy were approved as of January 2021.
and Sustainable Development of Electricity tariffs for residential
Georgia (MESD), with support from consumers increased on average
the European Bank for Reconstruction by 19 percent and by 70 percent for
and Development (EBRD) and the commercial end-users.
Secretariat of the Energy Community,
signed a Memorandum of Constraints and risk factors
Understanding on Liberalization and
2021 demonstrated the risk popular
Digitalization of Commodity Markets
support poses to new projects.
in Georgia. The Memorandum aims
Namakhvani HPP—a major energy
to ensure the long-term sustainability
project with direct foreign investment
of Georgia’s energy sector and
of US$800 million—was suspended
intensify the efforts to liberalize
in May 2021 for further investigation
the energy market.
after the local population robustly
The five-year program, Securing objected the hydro dam. The Turkish
Georgia’s Energy Future, with investor Enka pulled the plug on the
a budget of US$15.7 million, is being project in September 2021.
launched with the help of the U.S.
government. The project seeks
to create an attractive, flexible,
professional and transparent market
for private investors.
dentons.com • 33
Germany
RES power generation capacity in Germany keeps growing.
However, the share of RES in the German power mix declined
notably in 2021, reaching approximately 45.7 percent for the
year. The domestic CO2 pricing regime came into effect in 2021.
Following a judgment by the Federal Constitutional Court,
the Federal Climate Protection Act was amended and emission
reduction targets were massively increased, making the target
for 2030 65 percent, with climate neutrality to be achieved
by 2045. Parts of the Renewables Energies Act (EEG) were
reformed to help RES grow faster. With the new government
having a strong climate and energy focus, there will be an even
more ambitious buildout of renewables in Germany
in the years ahead.

Germany national target by 2020 – 18 percent, with a long-term
RES capacity expanded by around Drivers

7 GW in 2021, mainly driven by some
The energy transition in Germany is
5.2 GW of solar PV and 1.8 GW of
accelerated by the plans of the new
onshore wind. No offshore wind
German government. Besides the
came to grid this year. Average
already implemented phaseout of
remuneration following RES auctions
nuclear, the phaseout of coal-fired
in 2021 was close to 6 Ct/kWh for
power plants will be accelerated
onshore wind and around 5 Ct/kWh
and may possibly reach completion
for solar PV.
by 2030.
34 • dentons.com
The tripartite coalition agreement, The strong buildout of renewables
signed in November 2021, provides will be accompanied by energy
for RES in the electricity sector to efficiency measures and the launch
reach 80 percent by 2030 (and of a hydrogen economy, with the
assumes a massively increased main focus on green hydrogen.
overall demand of 680–750 TWh). The National Hydrogen Strategy,
To achieve this goal, the permitting first presented in June 2020, aimed
process will be modified to clearly to create 5 GW of electrolyzer
prioritize the renewables buildout capacity by 2030. This target will
while 2 percent of Germany’s surface now be increased to 10 GW. In 2021,
will be reserved for onshore wind the strategy was put into action
installations. The installed solar PV whereby some €8 billion of public
capacity will be increased to 200 GW money was awarded in IPCEI tenders
by 2030 (currently at about 54 GW). for hydrogen-related projects. In
Rooftop solar will become mandatory addition, an amendment to the
on commercial buildings. In the Energy Industry Act created the first
coalition agreement, the target for regulatory basis for a pure hydrogen
the buildout of offshore wind by 2030 network infrastructure.
was raised from 20 GW to 30 GW.
By 2045 a total of 70 GW of offshore Constraints and risk factors
wind capacity will be installed (an
• Insufficient transmission grid
increase of 30 GW on the former,
expansion against the growing
already ambitious, target).
volumes of RES
Germany already holds a central
• Lengthy permitting process
position in the development of
hybrid offshore wind installations • Regulatory hurdles for
and cross-border integration of RES, corporate PPAs
both in the North Sea and Baltic Sea
With the government aiming for an
basins. In May 2021, the 1,400 MW
even stronger buildout of RES and an
NordLink interconnector to Norway
easier permitting process, Germany
was launched. 2021 was also the first
should continue to be an attractive
full year of operation of the Kriegers
market for investments in renewables.
Flak Combined Grid Solution,
commissioned in December 2020,
providing valuable lessons for future
hybrid projects.
dentons.com • 35
Hungary
In 2021, solar PV generation continued to be the most popular

RES technology in Hungary. Corporate PPA structures are starting
to appear on the market. As always, the electricity market (the
RES market in particular) is challenged by constant regulatory
changes and dynamically evolving market conditions.

Hungary national target by 2020 – 13 percent, with a long-term
Drivers impressive interest in the third tender

too, as this auction was almost three
The METÁR support scheme still plays
and a half times oversubscribed,
a decisive role on the RES market. It is
and the lowest bid price was far
primarily based on a price-premium
below expectations (HUF 15.73/kWh,
type of subsidy, awarded through
approximately €43.09/MWh). In
auctions. After the success of the
December 2021, the official auction
first and second METÁR auctions,
results were published; of the 183
the third METÁR tender took place in
proposals submitted, 57 successful
July 2021. Support, to be distributed
tenderers (all solar projects, with
each year of the 15-year subsidy term,
a total capacity of 183 MW) were
was capped at HUF 450 million
awarded and the weighted average
(€1.2 million) and 300 GWh. Projects
winning bid price was HUF 16.99/kWh,
up to a maximum of 20 MW of built-in
approximately €46.55/MWh.
capacity were admitted. There was
36 • dentons.com
PPA projects are attracting growing In 2021, Hungary approved its
attention, but these projects are still National Hydrogen Strategy,
in the negotiation and preparation paving the way to launch
phase, and an established practice low-carbon hydrogen in the economy
has yet to be set down in Hungary. by 2030 and supporting the
Pioneering projects (primarily on- following objectives: i) production
site, behind-the-meter projects) of large volumes of low-carbon and
only began to appear on the market decentralized carbon-free hydrogen,
in 2021. These projects are still in ii) industrial decarbonization, iii) green
preparatory phases (drafting and/or transportation, and iv) supportive
negotiation), but customer interest infrastructure for electricity and
seems to be on the rise, due to natural gas.
high energy prices and demanding
corporate ESG requirements. These Constraints and risk factors
types of projects still face certain
Network capacity allocation rules
regulatory uncertainties, and the
for power plants to be connected
associated bankability requirements
to the medium or high-voltage grid
are yet to be developed.
are currently subject to a conceptual
As of January 2021, an energy transition in Hungary. In the future,
efficiency obligation scheme was DSOs and TSO will publish every
introduced in Hungary, requiring six months the available capacities
electricity and gas traders, universal and applicable conditions on their
service providers and fuel distributors networks. Capacity requests will be
to achieve energy savings until 2030 ranked by set criteria, and requests
in a yearly varying percentage of the that fall outside the capacity cap
volume of energy sold in Hungary to based on their ranking will be
final customers. The savings are to rejected. The execution rules for the
be made through energy efficiency new capacity allocation procedures
measures/investments implemented are yet to be released (nor are ranking
in relation to customers’ final energy criteria available), but financial
consumption. In line with this, security will be required to request
a new market segment is emerging, new network capacities on the
including a secondary market of medium or high-voltage grid.
certified energy savings.
dentons.com • 37
Ireland
The trend for accelerated growth in Ireland’s renewable energy

sector continued in 2021. In tandem with the ambitious global
plans set out in COP26 for a greater focus on RES and creating
a sustainable environment, Ireland is setting its sights on
completely transforming its energy production and consumption
by 2050. Wind power has continued to play a pivotal role,
accounting for almost 40 percent of electricity used in Ireland
in 2020. With new supportive regulations affecting offshore
wind and a significant increase in private investment in RES, this
figure is set to grow rapidly. Following the success of the first
Renewable Electricity Support Scheme (RESS) auction in 2020 in
which 82 RES projects were approved (34 percent of these were
solar), Ireland is also set to hold its second RESS auction in May
2022, as part of the government’s Climate Action Plan 2021.

Ireland national target by 2020 – 16 percent, with a long-term
Drivers reach net zero emissions by 2050.

The Climate Act put Ireland on
In July 2021, Ireland signed into law
a legally binding path to transition
the Climate Action and Low Carbon
into an environmentally sustainable
Development (Amendment) Act (the
economy, with far-reaching
Climate Act), an ambitious plan to
ramifications. One key target is to
38 • dentons.com
achieve a 51 percent reduction in companies—EDF Renewables,
emissions by 2031, to be attained the French energy giant, has also
by an increased reliance on RES. confirmed plans to build one of the
Accordingly, the Irish government is country’s largest offshore wind farms
moving to rapidly accelerate growth in the coming years. These large-
in sustainable energy production. scale developments boost Ireland’s
status as a profitable location of
Offshore wind development has
choice within the RES market.
become the energy-production
method of choice, but it has
faced numerous regulative and
administrative challenges due to One of the biggest challenges
the complex regulatory regime that Ireland faces is balancing the rapid
is currently in place. The incoming investment in offshore wind farms
Maritime Area Planning (MAP) Bill is with the evolving legislation that will
currently passing through parliament, aim to balance upward investment
but a few core aspects of the bill in sustainable forms of energy with
have been revealed. One of the ensuring the sustainability of Ireland’s
main objectives of the MAP Bill is maritime landscape. However, the
to integrate consent regarding new challenges posed by increased
developments into the planning demand and a changing energy
permission system, thereby landscape will need to be met with
streamlining the offshore wind stringent measures to ensure the
market. The MAP Bill also includes viability of Ireland’s renewable energy
a provision to establish a new targets. Although in its infancy,
agency, the Maritime Area Regulatory green hydrogen has the possibility
Authority, which will regulate offshore of becoming a driving force in the
development, and ultimately allow renewable energy sector. Private
for faster realization of offshore entities such as Gas Networks Ireland
wind farms. and Hydrogen Mobility Ireland are
currently examining opportunities for
During 2021, there has been
large-scale hydrogen development,
substantial private investment in
but it remains to be seen whether this
offshore wind projects. Energia, the
will be met by state-backed support
largest supplier of green energy in
and greater market regulation.
Ireland, is due to begin work on two
€2 billion offshore wind projects.
Investment in offshore wind projects
is also arriving from international
dentons.com • 39
Italy
The government of Italy moved to revise the Integrated National

Energy and Climate Plan, published in 2020, originally envisaging
adding 40 GW of renewable energy generation capacity by
2030. The revised EU targets will likely require Italy to increase
the target of additional generation capacity from 40 GW to
60 GW by 2030. The new installations will be mostly solar PV
plants, followed by wind farms. The 2021 National Recovery and
Resilience Plan allocates €68.6 billion to the Green Revolution
and Ecological Transition and €31.4 billion to sustainable mobility
infrastructure. Part of the funds are dedicated to green hydrogen,
and the government’s draft hydrogen strategy targets achieving
investments of around €10 billion by 2030.

Italy national target by 2020 – 17 percent, with a long-term
Drivers In July 2021, the “Simplifications

Decree BIS” became law and, in
Since Italy has fallen behind schedule
November 2021, legislative decree
to achieve its RES capacity targets,
No. 199 (“RED II Decree”)
in 2021 the Italian government
implemented the European RED
passed legislation to accelerate
II Directive. As a result, agrivoltaic
permitting processes, provide access
plants can now access public
to incentives and enhance the
incentives and development and
development of storage and green
repowering works are subject to
hydrogen facilities.
40 • dentons.com
a simplified permitting regime. An Constraints and risk factors
expedited centralized Environmental
Long, complex permitting procedures
Impact Assessment procedure was
are a serious obstacle to RES growth
introduced for large projects and—in
rates in Italy. In practice, developers
the event of inertia by regional or
encounter considerable resistance
local administration—substitution
among regional and local authorities,
powers can be triggered. Moreover,
who are mindful of the historical,
the time limit on revoking unlawful
artistic, touristic and agricultural value
administrative acts (including awards
of the local territory and are reluctant
of incentives) was reduced to
to issue permits as obliged by law.
12 months, giving investors greater
legal certainty. Delays in permitting often make it
impossible or risky for developers to
A new incentive scheme looks set
apply for incentives. Moreover, they
to continue government support
force developers to renegotiate land
after the expiry in 2021 of the 2019
agreements and bear increased costs
FER1 Decree. The 2019 FER1 Decree
when originally negotiated option
aimed to support the development
rights expire before the permits
of generating capacity, but it was
are granted.
largely undersubscribed due to
permitting problems. The national government has
attempted to legislate away
Greenfield development continues
permitting delays with the
to boom, especially in wind and
Simplifications Decree BIS and the
solar PV, and many projects are
Red II Decree—2022 will show how
reaching ready-to-build status. On
effective these measures are.
the offtake side, there is strong
To unlock the potential of offshore
appetite for physical and financial
wind, the Ministry for Ecological
PPAs (or a combination) from both
Transition of Italy has initiated a round
utilities and traders, often from
of consultations with companies
outside Italy. Corporate PPAs are
that have expressed interest in
gaining momentum, with utilities or
building offshore plants using floating
traders bridging the regulatory and
technology. In the meantime, the
knowledge gap between the RES
first park in the Mediterranean
producers and corporate offtakers.
Sea (Taranto) is expected to start
operations in Q1 2022.
dentons.com • 41
Kazakhstan
The share of RES in Kazakhstan’s energy mix remained on the

upswing during the COVID-19 pandemic. This trend is expected
to continue as the country’s goal is to reach carbon neutrality by
2026; moreover, leading state-owned companies were instructed
to implement RES projects more actively.
Share of renewable energy in gross energy generation

Kazakhstan national target by 2020 – 3 percent, with a long-term goal
of 50 percent by 2050
Drivers The president has instructed the

government to draw up a new law
Kazakhstan continues to provide
on support of alternative energy
strong support for RES. During the
and develop a concept for carbon
COVID-19 pandemic RES developers
neutrality by 2060. The president
commissioned around 2,600 MW of
wants the scope of the new law to
RES capacity and another 380 MW
extend to all types of alternative
was planned to be commissioned
energy (not just RES), covering
in 2021. This is twice the amount
hydrogen, industrial gases, coal bed
commissioned in the five years before
methane, biofuel and municipal
the onset of the pandemic.
solid waste.
42 • dentons.com
In June 2021, the government KazMunaiGas also announced plans
adopted the Rules on provision of to sign long-term offtake contracts
state financial support to the Financial with RES generators.
and Accounting Center on support
of renewable sources of energy (the
offtaker), which aim to strengthen the There is a growing problem of
financial standing of the offtaker. intermittency in the national grid,
caused by aging infrastructure
In line with the government’s policies,
and newly installed RES assets.
state-owned companies are showing
Increasingly, the National Electricity
strong support for the RES sector and
Grid Operator is investigating the
are integrating ESG principles into
support currently provided to
their strategies. In 2020, the United
RES generators and insisting that
Nations included the sovereign
preference be given to hybrid power
Samruk-Kazyna wealth fund in
plants. This attitude plus the absence
its list of 20 advanced funds that
of a legal framework and adequate
support sustainable development.
tariff for hybrid power plants is
2021 saw the all-important first
negatively affecting the attractiveness
step in developing hybrid power
of the RES sector.
plants—a Memorandum of
Understanding for the development The offtaker’s financial standing
of a hybrid wind generation and and its ability to pay on time remain
storage system signed by the an issue, as the Rules on provision
Ministry of Energy of Kazakhstan, of state financial support set out
Samruk-Kazyna JSC, state-owned a time‑consuming procedure to
KazMunaiGas JSC and Total Eren. obtain state support.
In 2021, Samruk-Kazyna, Abu Dhabi’s Even though a variety of plans have
holding company ADQ and energy been announced, implementation
company TAQA signed an agreement rules are sometimes lacking.
to construct a 2 GW solar PV plant For example, it is still unclear how
and a 2 GW wind farm. These steps KazMunaiGas will select RES projects
are of particular interest, because the for long-term offtake contracts.
government’s position previously was
not to enter into direct negotiations
with respect to individual renewable
energy projects.
dentons.com • 43
Luxembourg
The Luxembourg Green Exchange celebrated its fifth

anniversary in September 2021, with more than 1,000 durable
debt securities issued by 200 issuers from 40 different countries.
Using its prominence as a financial center, Luxembourg is a key
destination for investments in renewable energy projects and
plays a significant and growing role in green finance.

Luxembourg national target by 2020 – 11 percent, with a long-term
Drivers The production of energy from

RES is promoted through subsidies
Grid access for RES electricity is
as well as feed-in and premium tariffs
subject to general law provisions
for electricity.
applicable to electricity. The share
of renewable energy in gross final Charges and fees for self-consumed
energy consumption is constantly electricity were removed in January
growing and auto-consumption 2020 and self-consumption is proving
is widely encouraged. Since 2019, to be economical and an asset in
solar PV capacity has been growing the current context of rising energy
steadily and major retail and prices. This explains the growth in the
industrial actors in Luxembourg have share of renewable energy in gross
established large solar PV plants. final energy consumption.
44 • dentons.com
Collective auto-consumption has also must be removed and government
been possible since a law effective backing and assistance is required
as of February 3, 2021 (part of the for Luxembourg commercial and
implementation of the draft National industrial consumers to sign PPAs.
Energy and Climate Plan (NECP) of
Luxembourg) through the creation Constraints and risk factors
of legal entities called “renewable
Luxembourg’s energy system remains
energy communities.”
highly dependent on imports and
In February 2021, the government fossil fuels. Oil is the dominant energy
presented its hydrogen strategy, source, and in 2020 Luxembourg still
which forms part of Luxembourg’s imported more than 80 percent of its
ambition to achieve climate neutrality national consumption of electricity
by 2050. It proposes seven key and gas, mainly from Germany.
measures to promote the production, The level of auto-consumption,
import and use of renewable although increasing, remains low.
hydrogen and thereby reduce These, plus the challenges presented
GHG emissions. by rapid population growth and
an expanding economy, may have
Under the NECP, Luxembourg
a negative influence on meeting the
intends, together with the European
government’s ambitious targets.
Investment Bank (EIB), to promote
a de-risking instrument for long-term
RES power purchase agreements
(PPAs) at European levels, in
order to make green electricity
contracts cheaper for industrial
companies and SMEs. However, the
Luxembourg industry federation
noted that international barriers
dentons.com • 45
The Netherlands
The Dutch Climate Act aims to cut emissions of CO2 and other
GHG by at least 49 percent by 2030 compared with 1990 levels.
At the end of 2020, the country was on track for reductions
of 30 to 40 percent by 2030. By the end of 2021, estimated
reductions were trending toward 38 to 48 percent, under the
adopted and planned policies. Another 3 to 25 Mt CO2 equivalents
are required to hit the target.

The Netherlands national target by 2020 – 14 percent, with a long-term
Drivers Biomass, with around a 50 percent

share, is still by far the largest source
The use of RES energy increased
of RES in the Netherlands, followed by
steadily in 2020 and 2021, especially
wind power at 23 percent. The total
RES electricity. Production of RES
installed capacity of wind turbines
energy grew by 13 percent in 2021.
went from 4,500 MW at the end
More than 12.5 percent of all energy
of 2019 to 6,600 MW at the end of
now comes from renewable sources,
2020. Solar energy, which has shown
compared with 11.5 percent in 2020,
the second-fastest growth in 2021
while more than 33 percent of
after offshore wind, has a 25 percent
electricity was renewable in 2021.
share. The Netherlands currently sits
in the No. 2 position worldwide for
46 • dentons.com
per capita installed capacity of solar 2021, with an action plan for
energy. However, growth is hampered 2022–2025, with a look ahead
by a lack of available grid capacity, to 2030. The government asked
which leads to restrictions on Gasunie, the operator of the national
connecting solar (and wind) projects gas transport network, to take on the
to regional electricity grids. development of the transport network
for hydrogen and to release gas pipes
Under the SDE++ subsidy scheme
for reuse.
introduced in 2020, projects
compete based on “avoided CO2 and The Dutch government plans to open
other greenhouse gases,” instead the next offshore wind auction for
of “generated renewable energy,” bids on April 14, 2022. The tender will
as previously. This broadened the close on May 12, 2022, and the winner
SDE++ scheme, in combination with is expected to be announced in the
the new CO2 tax for heavy industry, third quarter of 2022. This will be the
has resulted in a structural decrease first time a financial bid by a potential
in projected GHG emissions. As of developer has been added to the
January 1, 2021, a CO2 tax imposes selection process. The financial bid in
a minimum price for GHG emissions this tender is capped at €50 million.
on industrial companies that fall
under the EU Emissions Trading Constraints and risk factors
System, and a number of sources
In June 2021, the highest Dutch
outside the EU ETS.
administrative court ruled on
In spring 2021, the District Court of environmental standards for wind
The Hague ordered Royal Dutch Shell turbines in response to the Nevele
to adopt corporate policies to reduce judgment of the Court of Justice of
its CO2 emissions by 45 percent the EU. The Dutch administrative
(net) by 2030 against 2019 levels. court ruled that an Environmental
In imposing this obligation, the Court Impact Assessment must be drawn
considered the substantial size of up for wind turbine standards under
Shell’s CO2 emissions (both directly the Activities Decree and the Activities
and through its products) to be of Regulation. In the meantime, the
great importance. Shell has lodged current wind turbine standards cannot
an appeal. be used as a basis to issue permits
for new wind farms. It is still uncertain
Hydrogen is a very important topic
what impact this ruling will have on
at present. The National Hydrogen
operational wind projects that have
Program was published in summer
irrevocable permits.
dentons.com • 47
Poland
2021 brought major developments to the Polish RES market—

the European Commission both approved the 10.9 GW support
scheme for offshore wind and extended the auction-based
scheme for onshore installations until 2027. The country
finalized its 2040 Energy Policy, and non-binding sectoral
deals were concluded by public and private stakeholders on
the development of offshore wind, hydrogen economy and
photovoltaic projects, among others.

Poland national target by 2020 – 15 percent, with a long-term
Drivers The dedicated Offshore Wind

Act was approved by the European
In 2021, numerous Polish government
Commission in May 2021, with a total
initiatives aimed at stimulating RES
maximum budget of €22.5 billion
growth came to fruition. An additional
and a maximum Contract for
round of onshore auctions was
Difference (CfD) reference price
organized in December 2021 and the
set at PLN 319.60 per MWh
overall scheme was extended until
(€71.82 per MWh); in the first phase
2027, with state aid clearance from
of the scheme, covering up to 5.9 GW
the European Commission. Many
of capacity, the first eight projects
improvements were introduced
received provisional CfD premium
including those related to interim
awards in June 2021. Investors
settlements. Multi-year budgets are
continued to prepare those projects
expected in 2022, providing investors
for individual grant approvals by the
with greater transparency.
48 • dentons.com
European Commission, while the installations in 2022. Development
government finalized seabed lease in the rooftop installation sector
tender conditions for the second continued its lightning pace, still
round of projects. Tenders for enjoying the generous government
10–11 locations are anticipated in support program launched in 2019
H1 2022, with support available for and capturing around 75 percent of
up to 5 GW in auctions planned already installed capacity. This will
for 2025 and 2027. change from 2022, with extended
return times for small rooftop solar
The onshore wind and solar PV
PV investment tipping the scales
projects saw success in onshore
in favor of commercial and utility-
auctions and continued to develop
scale projects.
robustly, with more projects reaching
financial closing. The market saw
a further concentration of commercial
solar PV portfolios (<1 MW) and Lessons learned from auctions held
increased development in utility-scale in 2018–2021 and the extension of the
projects (over 1 MW), with around scheme to 2027 provide assurance
90 projects successful in the June about the investment landscape for
2021 auction. onshore RES installations. The key
remaining limitation is the onshore
Interest in long-term offtake
wind distance law, which affects the
contracts continued to grow,
development of new locations while
with a number of closings of both
favoring utility-scale solar PV projects.
physical deliveries and virtual PPAs.
The rapid pace of new installation
In reaction to the soaring power
development added pressure on
prices in H2 2021, investors looked for
network operators and on the
PPAs supporting both auction-based
availability of connection capacity
projects and merchant development
in some locations. The government
and adopted various price-capture
responded by initiating work on
strategies for projects reaching
various mitigation measures, including
commercial operation.
discussing greater availability of
Solar PV projects continued to grow direct line connections for industrial
the fastest, with installed capacity offtakers, cable pooling and on-site
doubling in 2021 to exceed 7 GW generation structures.
in aggregate against the current
2030 target of 5–7 GW. Solar PV
plants may surpass onshore wind
dentons.com • 49
Romania
After years of stagnation investments in renewable energy

projects in Romania are enjoying their fastest growth rate ever.
Thanks to the Fourth Energy Package and European Green
Deal, Romania sits in the spotlight of the European renewable
energy market.

Romania national target by 2020 – 24 percent, with a long-term
Drivers energy law that is currently under

parliamentary review, and is working
The national target set for 2030
on amending the current Electricity
requires the development of 7 GW
and Gas Law 123/2012 with a view to
of renewable energy projects, but
transposing EU Directive 2019/944
contemplated RES developments
to allow bilateral long-term electricity
are already close to 30 GW. This
supply contracts.
overwhelming investment stream
puts the Romanian government In October 2021, the government
under pressure to accelerate the of Romania approved the National
design and implementation of the Energy and Climate Plan (NECP).
new support scheme based on In line with Fit for 55, Romania’s
Contracts for Difference (CfDs) in NECP elaborates on the policies to
the next two years. The government support RES and energy efficiency
has also initiated an offshore wind investments, anticipating significant
50 • dentons.com
growth in both the wind energy investments in both transmission
sector (from 2.6 GW in 2020 to and distribution networks, especially
5.3 GW in 2030) and solar power in and around the Dobrogea region,
sector (from 1.3 GW in 2020 to which hosts the vast majority of
5 GW in 2030). EU funds will also Romania’s wind energy, amounting to
be available from 2022 for RES 2.6 GW of installed capacity.
development through the EU
On the legislative side, Parliament
Modernization Fund and the National
is being urged to confirm the
Plan for Recovery and Resilience,
promising measures taken by the
which has been approved by the EU.
government in 2020, allowing for
The positive trend is confirmed by the the conclusion of (single-buyer)
fact that bank financing is on the rise market PPAs for RES projects
after a long period of reluctance on commissioned after June 1, 2020.
behalf of the main financial institutions The government is also expected
to finance RES projects in Romania. to apply as soon as practicable for
European Commission approval of
Hydrogen is still in its infancy.
its support scheme based on CfDs.
As a next step, Romania intends
These expected legislative measures
to develop a National Strategy for
somewhat conflict with other recently
Hydrogen to underpin its hydrogen
enacted legislation capping electricity
investment support legislation.
prices and concerning tax revenues
from, among others, RES producers
in the context of the current energy
Timely evacuation of increasing RES crisis. Investors hope, however,
electricity production will require that these measures are temporary
substantial investment in grid in nature and will not last beyond
infrastructure. As such, grid operators March 2022.
are under pressure to accelerate grid
dentons.com • 51
Russia
Russia is gradually transforming from a primarily

oil-and-gas country to a more diversified energy portfolio.
As at January 1, 2021, hydro, solar and wind power accounted for
21.47 percent of Russia’s total installed power capacity of 245 GW.
That said, local experts are still arguing about how fast the Russian
economy should undergo its energy transition and what the
balance between fossil fuel use and renewables should be.

Russia national target by 2025 – 4.5 percent, with a long-term
Drivers mainly relates to large hydro, while

wind, solar and medium-size hydro
The last competitive selection
together account for 1 percent. The
of projects under CSA RES 2.0
government is looking to raise this
(capacity supply agreement for RES)
to 4.5 percent by 2025. Forecasts
demonstrates a significant increase
by the Russia Renewable Energy
in selected installed capacity
Development Association (RREDA),
compared with 2020: solar, 775 MW
however, indicate that it will barely
(up from zero); wind, 1.85 GW
exceed 1 percent by 2025 and
(up from 192.5 MW); hydro, 96 MW
2.62 percent by 2036, instead
(up from 45.6 MW).
of the targeted 6 percent.
Of Russia’s total installed power
Russia adheres to global trends
capacity of 245 GW, the RES share
and is implementing ESG principles
amounts to 21.47 percent, which
in its energy agenda. The Russian
52 • dentons.com
government’s Decree No. 2162-p Federation and requirements for
(August 2021) introduced a plan to verification of sustainable and/or
develop hydrogen energy by 2050, green development projects in the
with four scenarios for economic Russian Federation” (“ESG Decree”)
development, based on different further developed green goals
approaches to decarbonization and introduced the concept of
and investments in the sector. It sustainable finance instruments and
provides for the development by criteria for such instruments, which
2035 of export-oriented hydrogen may be issued in the form of green
production from fossil fuels based on bonds or green facilities (loans).
nuclear power, and from water using
The main players in the renewables
electrolysis based on nuclear plants,
sector in Russia remain the same:
hydro plants and RES.
JSC VetroOGK (controlled by
As part of the ESG agenda, Rosatom), Fortum Energy Ltd
in December 2021, Federal Law (a JV between Fortum and Rosnano),
No. FZ-296 “On Limiting Greenhouse and PJSC Enel Russia.
Gas Emissions” entered into force.
The Emissions Law introduces Constraints and risk factors
(i) “carbon units” (CU) and the option
• The highly regulated state unified
of CU trading, (ii) mandatory and
energy system controls an
voluntary reporting of emissions,
overwhelming part of the sector.
and (iii) emission reduction targets
for certain industries. Mandatory • The sector is highly turbulent,
reporting will apply to regulated so it is crucial to stay abreast of
organizations starting from 2023. regulatory developments.
The law targets the energy sector
• In June 2021, the Russian
and should accelerate the transition
government reduced support
from traditional energy sources
of the national RES program from
to RES.
RUB 437 billion (€5.02 billion)
Resolution of the Russian government to RUB 360 billion (€4.14 billion).
No. 1912-r of July 2021 established This almost 20 percent reduction
general green goals and defined the may become an additional
criteria for green projects. Decree constraint for the sector,
of the Russian government No. 1587 considering the recent extension
of September 2021 “On approving of the RES program from
criteria for sustainable and/or green 2024 to 2035.
development projects in the Russian
dentons.com • 53
Serbia
The RES market in Serbia is accelerating. Since 2009 the RES

share has kept stable at around 20 to 22 percent. The RES share
in heating and cooling has been stable since 2013. The power
market is characterized by two dominant power sources: lignite,
mostly commissioned between 1960 and 1980 with a share of
70 percent in power generation, and hydro. There has been
almost no change in the capacity mix in recent years, except
for a minor expansion of onshore wind recently. The new RES
support system is expected to change the energy sector soon.

Serbia national target by 2020 – 27 percent; its long-term
goal by 2030 is not yet determined
Drivers consumers and households are

entitled to tariff supply. The state-
With a market share of 98 percent,
owned utility Elektromreža Srbije
state-owned utility Elektroprivreda
(EMS) is Serbia’s TSO and will invest
Srbije (EPS) dominates power
in modernizing grids and market
supply to customers (industry, small
integration with neighboring
consumers and households). That
countries in the coming decade.
said, market liberalization exists in
A roll-out of smart meters is
law—all consumers are allowed to
also planned.
choose their supplier, while small
54 • dentons.com
The Serbian government permit, and the commercial operation
is currently designing a tender date (including grid connection
support system and, in April 2021, and obtaining a generation license)
parliament adopted a new Law on should occur within the next three
the Use of Renewable Energy years, to be extended by one
Sources. Finalization of the bylaws additional year if construction works
for implementation of this law is are finished. At entry into the support
planned in early 2022. The tender system, successful bidders have to
system envisages support by pay on a monthly basis a cash deposit
a 15-year Contract for Difference for dismantling the RES installation,
(CfD) floating market premium for amounting to €0.02/kW for solar PV,
RES generators (generally a 500 kW €0.066/kW for onshore wind and
minimum capacity, onshore wind €0.033/kW for other RES plants.
with a minimum 3 MW capacity) and
a maximum bid of €55.7 per MWh for Constraints and risk factors
onshore wind with 400 MW auction
Extension of Serbia’s grid
capacity, to be awarded at the first
infrastructure is a precondition
auction. Auctions are organized by
for deployment of intermittent
the Ministry of Energy and Mining.
renewables. Without EU grants, the
Worth noting is that a project does
costs involved might result in a sharp
not have to bid with its entire planned
increase in electricity costs and
capacity. To prequalify for auction
energy poverty.
a wind farm project must be at an
advanced development stage with
the following in place: an energy
permit for the plant, valid location
conditions or construction permit /
approval of performance of works
and grid connection approval.
To participate in an auction, each
bidder must place a bid bond of
€30/kWh; this will be doubled if the
project is awarded at tender. The CfD
will be settled against the market-
wide day-ahead base price at the
Serbian power exchange SEEPEX.
Following the auction, the project has
two years to obtain a construction
dentons.com • 55
Slovak Republic
Major legislative changes are expected in Slovakia in 2022,

including in RES legislation. In June 2021, the government
adopted its National Hydrogen Strategy, which looks ahead to
a booming hydrogen industry with a special emphasis on green
hydrogen. The related action plan is expected in early 2022.

Slovak Republic national target by 2020 – 14 percent, with a long-term
Due to its historical energy mix, Drivers

Slovakia is a special case as regards
After 2023, when support for domestic
RES. The most common RES are
coal mining ends, the energy mix will
biomass and solar energy, although
rely only on nuclear, hydro and RES.
there is interest in heat pumps
In Slovakia, the restriction on
as well. Biomass and hydrogen are
connection to the electricity grid for
considered the most prospective
new sources of electricity generation,
RES. Long underdeveloped due to
as well as on increasing the capacity
the natural conditions of the country,
of existing facilities (the so-called
the wind energy market has restarted
stop-state), will soon end. Lifting of
with new projects, especially in
the stop-state will free up 1,870 MW
Western Slovakia.
of capacity in the system. Of this,
more than 400 MW is dedicated to
intermittent sources, i.e., solar PV
56 • dentons.com
and wind power plants, and this The Nuclear Energy Society of
capacity is already fully taken up, Slovakia (JESS) is currently preparing
especially in Western Slovakia. for the construction of a solar park.
It is also working on a large hydrogen
The government adopted the
project, which has been included
National Hydrogen Strategy in
among the hot candidates to obtain
summer 2021, setting out the
the status of Important Projects of
strategic role of the state in hydrogen
Common European Interest (IPCEI).
technologies. Its 2030 target for the
The project intends to produce
promotion of hydrogen from RES is
green hydrogen through electrolysis,
to achieve 100 percent coverage of
thereby contributing to the
the country, with hydrogen refueling
decarbonization of public transport
stations and partial substitution in
in the Trnava region.
industry of hydrogen from fossil fuels.
The National Hydrogen Strategy aims
to increase the competitiveness of
the Slovak economy and contribute • All auctions were postponed until
to a carbon-neutral society in after the COVID-19 crisis.
accordance with the Paris Climate
• Lack of charging infrastructure is
Agreement. It is envisaged to create
a major obstacle to the spread of
a framework for the use of hydrogen
e-mobility.
in its entire chain (production,
transport, distribution and storage, • Most photovoltaic sources
including all necessary safety features connected to the grid in
and components). The upcoming 2010–2012 will lose financial
action plan envisages the installation support in 2025–2027 and are
of electrolyzers across Slovakia for expected to be disconnected.
the production of green hydrogen
• The permitting process is lengthy.
with a capacity of several kW.
• Barriers remain in the form
If Slovakia’s industrial demand
of connection charges,
exceeds its ability to produce green
G-components and a lack
hydrogen from its own sources, the
of prepared infrastructure of
action plan foresees primarily imports
distribution companies, triggering
from countries with a high demand
the risk that many RES projects will
for green hydrogen.
not be implemented.
• Slovakia does not have a special
regulation on corporate PPAs.
dentons.com • 57
Spain
The Spanish renewable energy market remains attractive for

foreign investors. Acquisition of portfolios at an early stage of
development together with call for tenders of new capacity in
transmission grids will provide new opportunities for investors.

Spain national target by 2020 – 20 percent, with a long-term
Drivers for continuity of the development

and can have substantial
There is still great demand for RES
cost implications.
projects in Spain. It is still a seller’s
market, with buyers taking on risk New capacity in the transmission grid
at earlier stages. Investors are is to be auctioned in future public
currently focusing on the acquisition tenders, expected to be called by
of RES projects at an early stage early 2022. Regulations set out the
of development, with portfolios requirements, which may favor large
frequently including projects that investors—at the cost of others.
have secured land rights and are Investors prepare for a call of tenders
in the process of obtaining the by securing land rights in suitable
administrative permits. It is not terrains. Some are already in the
unusual for environmental permits process of acquiring and legalizing
to be missing—which are crucial land rights for development.
58 • dentons.com
Capacity released in nodes previously Constraints and risk factors
engaged by large coal-fueled
Scarcity of connection capacity
generation plants is preserved for
in the distribution and transmission
connection of new renewable energy
grids remains the major barrier for
generation facilities and is starting
developing RES projects in Spain.
to be auctioned off. The first tender
Even if the suspension (moratorium)
has been called for capacity of over
on the right to request capacity in
1,200 MW.
the grid were lifted by the middle
A new auction for subsidized capacity of 2022, most of the capacity
was called in late 2021, awarding in the transmission grid has been
more than 3,100 MW at an average preserved, to be auctioned off in
price of €30.56 per MWh, guaranteed future public tenders. This will remain
by the supporting mechanism the situation until such tenders are
approved by the Spanish government called and awarded. This is keeping
in late 2020. the RES project market a seller’s
market, as the price of connection
Regulatory development of capacity
and development permits is still
mechanisms is ongoing; public tenders
rather high.
will be called to allow RES producers to
participate in Spain’s backup system, New urgent legislation passed
mainly by installing storage facilities. in Q3 2021 introduced some
uncertainties in electricity market
Much of the country’s storage needs
rules. This regulation purports to
will be addressed by hydrogen
redistribute some alleged windfall
projects associated with RES
profits of nonmarginal utilities, but it
generation facilities, as projects
has generated great unrest among
are increasingly being developed.
utilities and in the PPA market in
Regulations are in preparation to
general, mainly in connection with
channel EU Recovery and Resilience
change-in-law provisions.
funds into hydrogen projects.
As a general framework for all of the
above, the Spanish parliament passed
Act 7/2021 on Climate Change and
Energy Transition, approving a wide
range of public policies favoring an
environmentally sustainable energy
transition and efficient climate
change measures.
dentons.com • 59
Turkey
Mostly due to the desire to reduce dependence on energy

imports, Turkey remains committed to increasing the share
of renewables in electricity generation. Although the RES
sector has had its share of delays and challenges due to the
COVID-19 crisis, the policy of supporting renewables and using
locally manufactured equipment has stayed put. A new RES
support mechanism entered into force in respect of renewables
commissioned from July 1, 2021. The Ministry of Energy and
Natural Resources of Turkey announced the new YEKA tenders,
with those relating to wind projects to be held on April 27, 2022
and those relating to solar to take place on May 31, 2022.
Share of renewable energy (including hydro) in electricity generation

in 2020 – 42.5 percent*
Turkey national target for RES (including hydro) in electricity generation
by 2023 – 38.8 percent*
Drivers FIT varies depending on the source

and the amount and type of local
For RES, Turkey offers a system
content. Renewable energy projects
that is part feed-in tariff (FIT) and
commissioned by June 30, 2021 enjoy
part feed-in premium, whereby the
U.S. cent–denominated FIT.
guaranteed prices apply for 10 years
The terms of the new support
after commissioning. The level of
* Annual Electricity Sector Report 2020 issued by the Turkish Energy Market Regulatory Authority
60 • dentons.com
mechanism that will apply to In view of the net-zero carbon
renewable projects commissioned target by 2053, it is expected that
after June 30, 2021 were announced the commitment to fully realize the
in January 2021. In the new potential for RES will be even stronger
mechanism the FIT is Turkish Lira– than before and the green hydrogen
denominated and the FIT prices will market (currently in its infancy) will
be updated quarterly in accordance be increasingly more important in the
with the consumer price index (CPI) country’s agenda.
and US$/TL and €/TL exchange rates
based on a formula specified in the Constraints and risk factors
relevant legislation.
• Grid capacity for connecting wind
The Ministry of Energy and and solar power plants outside
Natural Resources of Turkey the scope of YEKAs is limited.
announced that the next round The Turkish Electricity Market
of wind YEKA applications (Turkish Regulatory Authority (EMRA) has
acronym for RES-designated areas) not yet announced any date for
for an aggregate capacity of 2 GW collection of preliminary license
are to be submitted on April 27, 2022, applications for solar and wind.
for 42 wind mini-YEKA tenders This, together with the ban on
(each with a capacity of 20–90 MW). sales of electricity generated by
The next round of solar YEKA unlicensed projects, limits the
applications, for 76 tenders each with potential for corporate PPAs
an installed capacity of 10–30 MW, in respect of solar and wind.
will be collected on May 31, 2022
• Uncertainty regarding the terms
for an aggregate capacity of 1.5 GW.
of the FIT mechanism to apply to
The tenders will be held by way of
projects commissioned after June
reverse auction, with a ceiling price
2021 has been a constraint. With
of 45 kuruş/kWh for wind tenders
this uncertainty now eliminated, the
and 40 kuruş/kWh for solar tenders.
initial reaction from sector players
The guaranteed purchase is for
has been of cautious optimism due
the first 35 GWh in respect of wind
to TL FIT prices having the prospect
projects and for the first 23 GWh for
of adjustment according to CPI and
solar projects, released to the grid
hard currency exchange rates.
after commissioning.
The longer-term reaction in light
Turkey ratified the Paris Climate of currency fluctuations remains
Agreement in October 2021 and to be seen.
signed the Glasgow Climate Pact.
dentons.com • 61
Ukraine
In 2021, 731 MW of RES power capacity was awarded, despite

retroactive cuts in feed-in tariffs (FITs) in 2020 and existing debt
owed to producers with awarded FIT. Total RES power capacity
with an established FIT in Ukraine has now reached 8.5 GW.
Share of renewable energy in final energy consumption

Share of renewables in overall electricity production
at the end of 2020 – in excess of 13.9 percent
Drivers synchronize its power system with

that of the EU. The Ukrainian energy
FITs for wind projects with “pre-PPAs”
regulator increased tariffs for ancillary
signed with the state before 2020,
services to incentivize private
as well as for small solar (in particular
players to develop energy storage
rooftop), biogas and biomass projects
infrastructure, giving RES producers
continue to drive projects to be
the opportunity to upgrade their
commissioned in Ukraine in 2022.
power plants by installing energy
These FITs are fixed (EUR-linked), with
storage facilities and to become
a state power purchase guarantee
market players on the ancillary
until the end of 2029.
services market.
Plans for state companies to build
Rising electricity prices triggered
energy storage infrastructure,
a boom in RES self-consumption
to facilitate balancing RES and
projects, in particular solar plants.
enhance energy security, are in line
Notably, in certain periods prices
with the country’s preparations to
62 • dentons.com
for electricity considerably exceeded to be injected into the gas system
the current solar FITs. Higher prices without the downsides related
also led to the development of the to transmitting pure H2.
first projects with physical corporate
PPAs for electricity from RES. Constraints and risk factors
As a new trend, investors have Auctions designed to replace FITs
become interested in renewable did not take place in 2021, and
gases, such as biomethane and there is no certainty whether any
hydrogen, to fill the gap in Ukrainian will be announced in 2022. Despite
gas supplies in light of decreasing the increasing penetration of RES
volumes of gas transit through the in the energy mix and the need in
country and its possible termination the power system for up to 2 GW of
in 2024, as well as rising gas prices highly flexible generating and energy
and EU appetites for renewable storage facilities, no respective
gases. Thus, 2021 saw some auctions have been announced, and
pioneering biomethane projects it is unclear when they will take place.
oriented at biomethane export in
Regulatory barriers, high transmission
development, with an eye to unlock
and distribution charges, isolation of
Ukraine’s potential, estimated
most of the Ukrainian power system
at more than 100 billion kWh a year.
from ENTSO-E, lack of liquidity and
Some 10 hydrogen projects were significant debt in the electricity
initiated in 2021; the long-term goal is market are creating challenges for
to install up to 10 GW of electrolyzers. structuring the first corporate PPAs.
The European Commission views There are delays with adopting the
Ukraine as a priority partner for green new legislation for energy storage
hydrogen production, thanks to RES facilities, and apparently, investors
availability combined with developed will need to rely on merchant revenue
gas transport and storage systems. streams.
Its hydrogen strategy is currently
Finally, upgrading of the grid system
under preparation with expected
and synchronization with ENTSO-E
adoption in 2022.
are proving complex and lengthy.
The Ukrainian government is also
considering hydrogen methanation
using, in particular, CO2 as a by-product
of biogas production. This would allow
for produced synthetic natural gas
dentons.com • 63
United Kingdom
In the first half of 2021, calm weather and outages reduced UK

renewable electricity generation by 13 percent (against H1 2020).
Installed capacity increased by 0.7 percent. However, official
figures indicate that projects under construction will increase
RES capacity by almost a fifth. There is a healthy project pipeline,
particularly for offshore wind, into the middle of the decade.
Drivers The UK government has published

a detailed, 10–15 year hydrogen
Leading by example as host of
strategy. The Scottish government
COP26 in Glasgow, the UK set itself
has set out a draft five-year hydrogen
goals of reducing GHG emissions
action plan. Early UK goals include
(from 1990 levels) by 68 percent by
establishing a Contract for Difference
2030 and by 78 percent by 2035.
(CfD)-based support scheme to
Its Net Zero Strategy stated that,
mitigate potential price and volume
by 2035, the UK would be “powered
risks that UK producers of blue/green
entirely by clean electricity, subject
hydrogen may face, with the first
to security of supply.” This will
contracts to be let in 2023.
require a massive expansion
Scotland emphasizes the potential
of RES generation capacity (e.g.,
for exporting low carbon hydrogen
an additional 30 GW of offshore
to EU markets.
wind by 2030). As well as meeting
direct electricity demand, this Clear signs of market enthusiasm
will support decarbonization of for UK offshore wind include: the
heat and transport, where rapid option fees paid in a recent England
progress is needed. and Wales seabed lease auction (up
to £154,000/MW); the results of the
64 • dentons.com
ScotWind leasing round announced budget are ring-fenced for floating
in January 2022 (including £700 offshore wind and for tidal stream
million of option fees and plans for projects (representing a fraction of
more than 14 GW of floating projects); the support available for fixed-bottom
£1 billion invested in UK offshore offshore wind).
wind manufacturing facilities in
2021; and offtakers’ strong appetite Constraints and risk factors
for long-term PPAs with offshore
The UK government can scarcely
projects. There has also been more
be faulted for its net-zero ambitions.
involvement of international oil and
Delivering the regulatory and physical
gas players than previously.
infrastructure necessary to achieve
Groups aiming to invest in UK them will certainly be challenging.
hydrogen projects have raised However, there is a strong focus
significant capital. A number of the on most of the key areas, including
UK’s proposed carbon capture and offshore network reform.
storage-based industrial clusters now
Consenting policy and processes
include plans for green as well as blue
remain a concern in some parts
hydrogen production. Credible
of the sector (including restrictive
plans are in play in both England
approaches to onshore wind projects
and Scotland to combine GW-scale
in England and stakeholder pressure
offshore wind, green hydrogen
around onshore infrastructure for
and oil and gas activities.
offshore projects). As RES penetration
“Subsidy-free” onshore wind of the UK grid increases and weather
and solar projects have been patterns underline the seasonal
progressing across the UK, with imbalances between wind and solar
some underpinned by PPAs with generation and electricity demand,
corporate offtakers; moreover, these the lack of regulatory support
sectors should still receive a welcome adapted to the needs of longer-term
boost from CfD Allocation Round 4. and larger-scale energy storage
Results are due in mid-2022, with facilities may become more of
support available for up to 5 GW a concern. Finally, the energy sector
of projects using these and other is subject to a new UK regime that
“Pot 1” technologies for delivery in requires mandatory notification and
2023–2024 and 2024–2025 (for other approval for M&A transactions on
technologies, projects for delivery national security grounds in a number
in 2025–2026 to 2026–2027 will be of sensitive sectors.
supported). Portions of this round’s
dentons.com • 65
Uzbekistan
Uzbekistan firmly supports a policy of using renewable energy

by increasing the share of renewables (excluding hydropower)
up to 25 percent by 2026. The country also aims to reduce
greenhouse gas emissions per unit of gross domestic product
by 35 percent by 2030.
Share of renewable energy (excluding hydropower) in total power

generation in 2019 – 0 percent
Uzbekistan national target by 2021 – generation of 0.2 GW electricity
from RES (solar), with a long-term goal of 25 percent by 2026
(solar and wind)
Drivers There are several thermal, solar and

wind power plants being put into
Uzbekistan aims to increase wind
operation in the Bukhara region
power capacity to 3,000 MW
including the following power plants:
and solar to 5,000 MW by 2026.
In addition, the government of • 270 MW thermal power plant in
Uzbekistan recently unveiled plans to Bukhara district commissioned on
build 20+ hydroelectric power plants December 31, 2021
with a total capacity of 740 MW in
• 500 MW wind power plant in
five years. In 2022, the country plans
Peshku district to be commissioned
to build five solar power plants with
in December 2023
a total capacity of 900 MW.
• 500 MW wind power plant
in Gijduvan district to be
commissioned in December 2023
66 • dentons.com
• 250 MW solar PV power plant in Research Institute of Renewable
Olot district to be commissioned in Energy, under the Ministry of Energy
December 2024. of Uzbekistan, to support the
country’s renewables and hydrogen-
The majority of recent RES projects in
energy policies.
Uzbekistan are structured as public-
private partnerships (PPP). In January The Ministry of Energy of Uzbekistan
2021, the PPP Law of Uzbekistan was and the World Bank plan to conduct
amended to enhance the bankability an assessment of blue hydrogen in
of PPP projects implemented in the Uzbekistan in 2022, with a view to
country. In particular, the amended identifying comparative advantages
law allows, based on decisions of and deficiencies of production.
the president of Uzbekistan, to peg They will then prepare a roadmap
prices for goods (works, services) for the development of green and
sold under PPP projects with foreign blue hydrogen.
investments to foreign currencies
and conventional units. The first Constraints and risk factors
tender for a wind power project in
One constraint is the change-in-law
Uzbekistan was conducted as a PPP,
protection under the PPP Law, which
with support from the European Bank
does not apply to changes in taxes
for Reconstruction and Development.
and duties after conclusion of a PPP
The results of the tender were
agreement, except for discriminatory
announced in September 2021
changes in relation to certain PPP
with the winning bidder, ACWA
projects. Other constraints exist in
Power, bidding a record low tariff
Law No. 598 of the Republic
of US$0.025695 per kWh.
of Uzbekistan “On investments
Uzbekistan also plans to and investment activities”
extend incentives provided in relation to international arbitrations.
to individuals and entrepreneurs The law includes a provision
for the installation of wind farms on multi-tiered dispute resolution,
in small hydropower plants. which envisages that only after
negotiations, mediation and local
In April 2021, the president of
court litigation have failed,
the Republic of Uzbekistan
can an investment dispute
approved the establishment of the
be referred to international arbitration.
Interdepartmental Commission for
This mechanism limits investor
the Development of Renewable and
access to international arbitration.
Hydrogen Energy and the National
dentons.com • 67
Contacts
Arkadiusz Krasnodębski Giles Dickson
Poland Managing Partner CEO
Co-head of Europe Energy group WindEurope
Dentons D: +32 2 213 18 11
D: +48 22 242 56 63 info@windeurope.org
arkadiusz.krasnodebski@dentons.com
Walburga Hemetsberger Grzegorz Górski

CEO COO
SolarPower Europe OW Ocean Winds
T: +32 27 09 55 20 Media contact:
w.hemetsberger@solarpowereurope.org communication@oceanwinds.com
Ulrik Stridbæk James Hogan

Vice President Senior Partner, Baku/Paris
Head of Regulatory Affairs Dentons
Ørsted D: +994 12 4 90 75 65
Media contact: D: +33 1 42 68 48 65
Michael Korsgaard Nielsen james.hogan@dentons.com
mikon@orsted.com
Edward Borovikov Petr Zákoucký

Belgium Managing Partner Czech Republic Managing Partner
Dentons Dentons
D: +32 2 552 29 05 D: +420 236 082 280
edward.borovikov@dentons.com petr.zakoucky@dentons.com
Marc Fornacciari Otar Kipshidze

Partner, Paris Georgia Managing Partner
Dentons Dentons
D: +33 1 42 68 45 44 D: +995 32 250 93 00
marc.fornacciari@dentons.com otar.kipshidze@dentons.com
Thomas Schubert Dr. Gabriele Haas

Partner, Berlin Partner, Frankfurt
Co-head of Europe Energy Dentons
Regulatory practice D: +49 69 45 00 12 393
Dentons gabriele.haas@dentons.com
D: +49 30 26473 430
thomas.schubert@dentons.com
68 • dentons.com
Anita Horváth Eszter Zádori
Partner, Budapest Partner, Budapest
Co-head of Europe Energy Sector Dentons
group, Dentons D: +36 1 488 5256
D: +36 1 488 5221 eszter.zadori@dentons.com
anita.horvath@dentons.com
Peter O’Brien Dr. Carsten Steinhauer

Partner, Dublin Partner, Rome
Dentons Dentons
D: +353 1 5828103 D: +39 06 809 120 19
peter.obrien@dentons.com carsten.steinhauer@dentons.com
Birzhan Zharasbayev Christel Dumont

Office Managing Partner, Nur-Sultan Senior Counsel, Luxembourg
Dentons Dentons
D: +7 7172 55 2151 D: +352 46 83 83 211
birzhan.zharasbayev@dentons.com christel.dumont@dentons.com
Jan Jakob Peelen Marcel Janssen

Partner, Amsterdam Partner, Amsterdam
Dentons Dentons
D: +31 20 795 38 00 D: +31 20 795 3423
janjakob.peelen@dentons.com marcel.janssen@dentons.com
Agnieszka Kulińska Michał Motylewski

Partner, Warsaw Europe Energy Practice
Dentons Development Counsel, Warsaw
D: +48 22 242 57 40 Dentons
agnieszka.kulinska@dentons.com D: +48 22 242 56 66
michal.motylewski@dentons.com
Dr. Christian Schnell Claudiu Munteanu-Jipescu

Partner, Warsaw/Munich Partner, Bucharest
Coordination SEE Dentons
Dentons D: +40 21 371 5402
D: +48 22 242 51 36 claudiu.munteanu@dentons.com
christian.schnell@dentons.com
Chapters on Bulgaria, Croatia, and Serbia were prepared in collaboration with
external law firms in these jurisdictions. Please direct any questions regarding
these jurisdictions to Christian Schnell at christian.schnell@dentons.com.
dentons.com • 69
Contacts
Alexei Zakharko Evgenia Teterevkova
Russia Managing Partner Partner, St. Petersburg
Dentons Dentons
D: +7 495 644 0500 D: +7 812 325 84 44
alexei.zakharko@dentons.com evgenia.teterevkova@dentons.com
Katarína Pecnová Fermín Garbayo

Counsel, Bratislava Partner, Madrid
Dentons Dentons
D: +421 220 660 220 D: +34 91 43 22 188
katarina.pecnova@dentons.com fermin.garbayo@dentons.com
Barlas Balcıoğlu Maksym Sysoiev

Partner, Istanbul Partner, Kyiv
Balcıoğlu Selçuk Ardıyok Keki Dentons
Attorney Partnership D: +380 44 494 4774
D: +90 212 329 30 00 maksym.sysoiev@dentons.com
bbalcioglu@baseak.com
David Cruickshank Charles July

Partner, Edinburgh Partner, London
Dentons Dentons
D: +44 131 228 7219 D: +44 207 246 7654
david.cruickshank@dentons.com charles.july@dentons.com
Lucille De Silva Louis Skyner

Partner, London Partner, London
Dentons Dentons
D: +44 20 7320 3795 D: +44 20 3530 3723
lucille.desilva@dentons.com louis.skyner@dentons.com
Adam Brown Eldor Mannopov

Managing Practice Development Uzbekistan Managing Partner
Lawyer, London Dentons
Dentons D: +99 878 150 31 05
D: +44 20 7246 7014 eldor.mannopov@dentons.com
adam.brown@dentons.com
70 • dentons.com
Sources of official data used in this publication
• BloombergNEF
• Communication from the Commission to the European Parliament, the European

Council, the Council, the European Economic and Social Committee and the
Committee of the Regions, on tackling rising energy prices: a toolbox for action
and support, October 13, 2021
• Communication from the Commission to the European Parliament, the Council,

the European Economic and Social Committee and the Committee of the Regions,
on “Fit for 55”: delivering the EU’s 2030 Climate Target on the way to climate neutrality,
July 14, 2021
• Communication from the Commission to the European Parliament, the Council, the
European Economic and Social Committee and the Committee of the Regions, on an
EU Strategy to harness the potential of offshore renewable energy for a climate-neutral
future, November 19, 2020
• Communication from the Commission to the European Parliament, the Council,

the European Economic and Social Committee and the Committee of the Regions,
on a hydrogen strategy for a climate-neutral Europe, July 8, 2020
• Communication from the Commission to the European Parliament, the European

Council, the Council, the European Economic and Social Committee and the Committee
of the Regions, on the European Green Deal, December 11, 2019
• Directive (EU) 2018/2001 of the European Parliament and of the Council of

December 11, 2018 on the promotion of the use of energy from renewable sources
• Directive 2009/28/EC of the European Parliament and of the Council of April 23, 2009
on the promotion of the use of energy from renewable sources
• Eurostat data on the share of renewable energy in gross final energy consumption
as of January 2022
• National Energy and Climate Plans
• Regulation (EU) 2021/1119 of the European Parliament and of the Council of June 30, 2021
establishing the framework for achieving climate neutrality and amending Regulations
(EC) No 401/2009 and (EU) 2018/1999 (“European Climate Law”)
• SolarPower Europe
• European Commission
• European Parliament
• Council of the European Union
• WindEurope
dentons.com • 71
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Investing in

2021 was a year of unprecedented, There is no easy or quick remedy

People are thinking about energy If we want to decarbonize our

Germany United Kingdom France Spain Netherlands Sweden Italy Finland

Norway Poland Denmark Others

11,22 10,92 10,89

CCS Electrified heat Electrified transport Energy storage Hydrogen

Nuclear Sustainable materials Renewable energy

Corporate Power Purchase Germany, Denmark, and with further

Biofuels Biomass and waste Geothermal Small hydro Solar Wind

2021 marks a major regulatory shift procurement of strategic gas stock.

Share of renewable energy in electricity generation capacity

Drivers other support mechanisms, such

* Figures from Azerbaijan’s Ministry of Energy and State Statistics Committee

Energy policy in Belgium is set at both federal and regional levels.

Share of renewable energy in gross final energy consumption

Drivers 2021, Belgium, Denmark and

After a long standstill, the RES market in Bulgaria began to

Share of renewable energy in gross final energy consumption

Drivers prices are the lowest. Therefore, the

The RES market in Croatia is one of the best developed

Share of renewable energy in gross final energy consumption

Drivers Krško in Slovenia and one hard

In 2020, RES hit a 17.3 percent share of gross final energy

Share of renewable energy in gross final energy consumption

Drivers new non-fueled RES, modernize heat

Photovoltaic electricity has finally taken off in France reaching

Share of renewable energy in gross final energy consumption

Drivers mechanisms to guarantee the

Georgia launched a large-scale energy sector reform in 2017,

Georgia ambitiously undertakes to increase the share of renewable

Drivers the Paris Agreement and the UN

Share of renewable energy in gross final energy consumption

RES capacity expanded by around Drivers

In 2021, solar PV generation continued to be the most popular

Share of renewable energy in gross final energy consumption

Drivers impressive interest in the third tender

The trend for accelerated growth in Ireland’s renewable energy

Share of renewable energy in gross final energy consumption

Drivers reach net zero emissions by 2050.

The government of Italy moved to revise the Integrated National

Share of renewable energy in gross final energy consumption

Drivers In July 2021, the “Simplifications

The share of RES in Kazakhstan’s energy mix remained on the

Share of renewable energy in gross energy generation

Drivers The president has instructed the

The Luxembourg Green Exchange celebrated its fifth

Share of renewable energy in gross final energy consumption

Drivers The production of energy from

Share of renewable energy in gross final energy consumption

Drivers Biomass, with around a 50 percent

2021 brought major developments to the Polish RES market—

Share of renewable energy in gross final energy consumption

Drivers The dedicated Offshore Wind

After years of stagnation investments in renewable energy

Share of renewable energy in gross final energy consumption

Drivers energy law that is currently under

Russia is gradually transforming from a primarily

Share of renewable energy in gross final energy consumption

Drivers mainly relates to large hydro, while

The RES market in Serbia is accelerating. Since 2009 the RES

Share of renewable energy in gross final energy consumption

Drivers consumers and households are