ClientEarth’s feedback to the Renewable Energy Directive revision Inception Impact Assessment

ClientEarth supports a combination of regulatory and non-regulatory measures to revise the Renewable Energy Directive (REDII) to align with the European Green Deal. The organization advocates for a 2030 emissions reduction target of at least 65%, the exclusion of non-renewable hydrogen from support, and the removal of biomass from the category of renewable energy sources due to its impact on climate, health, and biodiversity.

• ClientEarth supports 'Option 5' of the Inception Impact Assessment, which combines non-regulatory measures, raising REDII target ambition levels, and translating European Green Deal actions into legal measures.
• The organization argues that the EU's proposed 2030 greenhouse gas emissions reduction of at least 55% compared to 1990 levels is insufficient, recommending a target of at least 65% that excludes carbon sink offsetting in the land use sector.
• To facilitate offshore renewable energy, ClientEarth suggests revising REDII Articles 9 and 13 to better support regional cooperation and shared infrastructure, such as hybrid assets that function as both interconnectors and transmission lines.
• ClientEarth requests that any support for hydrogen under the revised REDII be limited strictly to completely renewable hydrogen, explicitly excluding 'electricity-based hydrogen', 'fossil-based hydrogen', 'fossil-based hydrogen with carbon capture', 'low carbon hydrogen', and 'hydrogen-derived synthetic fuels'.
• The organization emphasizes that Member States must fully transpose Articles 21 and 22 of REDII to enable renewable energy communities, noting that some states have only transposed the definition of these communities rather than the full enabling framework.
• ClientEarth argues that biomass should be excluded from renewable energy sources because its combustion contributes to global temperature increases and causes significant air pollution, specifically particulate matter (PM2.5), which is linked to premature deaths in the EU.
• The document calls for emergency measures regarding biomass, including rethinking subsidies for biomass projects as 'solid green investments' and tightening sourcing rules to align with the 2030 Biodiversity Strategy.

APA

ClientEarth (n.d.). ClientEarth’s feedback to the Renewable Energy Directive revision Inception Impact Assessment. https://www.clientearth.org/media/qu5orsol/2020-09-20-feedback-to-the-renewable-energy-directive-revision-inception-impact-assessment-ce-en.pdf

Chicago

ClientEarth. ClientEarth’s feedback to the Renewable Energy Directive revision Inception Impact Assessment. n.d. https://www.clientearth.org/media/qu5orsol/2020-09-20-feedback-to-the-renewable-energy-directive-revision-inception-impact-assessment-ce-en.pdf.

Wikipedia

{{cite press release |author=ClientEarth |title=ClientEarth’s feedback to the Renewable Energy Directive revision Inception Impact Assessment |url=https://www.clientearth.org/media/qu5orsol/2020-09-20-feedback-to-the-renewable-energy-directive-revision-inception-impact-assessment-ce-en.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{clientearthndclientearths, author = {{ClientEarth}}, title = {{ClientEarth’s feedback to the Renewable Energy Directive revision Inception Impact Assessment}}, publisher = {ClientEarth}, url = {https://www.clientearth.org/media/qu5orsol/2020-09-20-feedback-to-the-renewable-energy-directive-revision-inception-impact-assessment-ce-en.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }