On June 30th, the long-announced but swiftly implemented amendment to the Renewable Energy Sources Act (EEG) 2012 and some other legislative texts on the energy transition were passed by the Bundestag. First of all, my congratulations. In spite of this, the legal texts have been heavily criticized in some cases by several associations from the renewable energies sector. Since wind energy was able to avert some drastic cuts at the last second, the bioenergy sector in particular sees itself as the bigger loser of the EEG amendment. This is what at least one of the most influential experts in the biogas industry in Germany, Josef Pellmeyer, President of the Biogas Association, puts it. What points of criticism are there and what disadvantages are expected from the EEG Novell 2012 for the biogas industry?
What criticism is there from the associations of the bioenergy industry regarding the EEG amendment?
The trade association for biogas, the federal association for bioenergy and the Draft law the biogas council also spoke very actively. This list shows that mainly the gaseous bioenergy is affected by the EEG amendment.
It has often been criticized that the EEG amendment is knitted with a very hot needle. Of course, as a federal government you can never make it right for everyone, and the rapid course of action was primarily intended to accelerate the energy transition and the exit from nuclear energy. Nevertheless, at the rapid pace, some things could not be thought through to the end or at least could no longer be taken into account in the wording of the legal text.
Impact of the 2012 EEG amendment on the biogas industry
Hopefully, the criticisms raised can still be adjusted in subsequent improvements. If not, then the development of gaseous bioenergy in Germany will be burdened more by the following requirements in the future.
Too high requirements for the heat quota for biogas plants
According to the opinion of the Biogas Association, the required heat utilization for biogas plants is clearly too high. Accordingly, a biogas plant should only receive the remuneration premium if, in addition to the amount of electricity produced, 60% of the heat generated is used. For new systems, however, there is a grace period for the first two years of operation, during which only a 25% heat use has to be proven.
Such a high heat rate would jeopardize the further expansion of biogas plants because the risk arising from the additional requirements could be too high for many lending banks. It remains to be seen whether the two-year grace period is sufficient to reassure investors. The financing of new biogas projects should at least not necessarily be made easier.
If you consider the current acceptance and approval problems for new biogas plants, project implementation will be a tough challenge.
In addition, the requirements for the use of heat also place further obstacles in the way of achieving the targets for the feed-in of biomethane (Article on barriers to biomethane feed-in).
Although there is great disappointment with these high energy efficiency requirements for biogas plants, I would like to refer to an older article in which 12 innovative Heat utilization concepts for biogas plants to be introduced. This list will probably have to be even more innovative in the future.
One can also ask whether 60% of the heat used is very much? Ideally, of course, all energy should be able to be used, but in reality this is not always easy with decentralized forms of energy, which include rural biogas plants.
This also gives the problem a negative flavor, since there are no such heat utilization rates for central coal-fired power plants. So what justifies such high standards for an industry that inherently imposes high environmental standards? Difficult problem!
Remuneration rates for biogas reveal a gap between theory and practice
The federal government would like to adjust the biogas tariff (see Article compensation system counteract the development of monocultures (maize) and sharply increased rental prices for agricultural land in the EEG 2011). Two undesirable developments that should be corrected and that have been criticized especially by food farmers, environmentalists and residents.
Clearly understandable approaches that one also has to endure as a biogas plant operator in a democracy. But HOW exactly do you change the remuneration rates for biogas in order to correct the undesirable developments on the one hand and not to disadvantage other groups too much at the same time?
In the run-up to the amendment to the Renewable Energy Law, the Biogas Council had expressed clear criticism of the planned change in the remuneration rates for gaseous bioenergy. The entire calculation of the change rates was criticized as being out of practice and a real dispute arose with the leading biomass institute in Germany, the DBFZ.
The German Biomass Research Center has prepared the report for the Federal Ministry for the Environment, which contains the change scenarios for the EEG amendment. The biogas council mainly criticized the data basis on which the DBFZ report is based and which means that the subsidy rates for biogas and biomethane are insufficient.
In this regard, Reinhard Schultz, Managing Director of the Biogasrat eV, spoke very clearly about the draft law.
"The draft law lacks the 2–3 ct / kWh for biogas and biomethane power generation, which decide whether this market will still exist from 2012 or not."
These are very warning words from someone who knows the biogas industry very well. The complete press release from the biogas council on the EEG draft law Is there ... here.
Even after the legal text was passed, Josef Pellmeyer, President of the Biogas Association, confirmed that "Too low remuneration for feeding biogas into the natural gas network will block the switch to regenerative power supply."
Future use of animal components endangers old systems
Another point of criticism from Josef Pellmeyer is that “in the future, substrates with animal components can also be used in agricultural plants with energy crops (NawaRo plants). This removes the input materials from the existing biogas plants that ferment residues, because new plants for the same substrates can receive significantly higher remuneration. This jeopardizes the existence of old systems and unnecessarily increases the EEG surcharge. ” More information can be found in the Statement by the Biogas Association.
I can understand the Federal Government's approach, since this measure enables the fermentation of residues to be made more widespread, travel distances shortened and the ecological balance of the bioenergy source improved. However, special protection of existing systems should be taken into account in the event of such a change, since their existence could otherwise be threatened.
There are also advantages for that Biogas industry through the EEG amendment 2012?
It is the duty of associations to do the best they can for the interests of their industry. Sharp criticism, also of the legislative texts that have been passed, must be allowed. Fortunately, despite all the criticism, there were also some words of praise for the EEG amendment. The following points are rated as positive:
- Reduction of the eligible biogas plant size from 150 kW and the creation of a new remuneration class up to 75 kW. With this change, new "mini systems" can now also be supported (see Articles on 75 kW slurry systems). However, 80% of these small biogas plants have to use liquid manure as an input material. A nice development for a decentralized energy source (!), Which could lead to a further increase in the number of biogas plants in Germany.
- A flexibility premium for the construction of storage capacities is introduced. This is intended to promote the position of bioenergy as balancing energy and to contribute to an efficient electricity mix from renewable energies.
- In addition, the flexibility premium is now also available for existing systems. The construction of biogas storage facilities and additional engine capacities (generators) are therefore also approved for old systems. However, this funding is limited to plants that are ready to switch to direct marketing. More information on direct marketing, market premium and flexibility premium here.
- The newly introduced market premium is paid to the operator of the biogas plant who markets the biogas electricity produced himself and would receive a lower price than the secured EEG remuneration. In this case, the difference should be paid out.
- The biogas feed-in bonus is increased to a capacity of up to 700 standard cubic meters of biomethane per hour.
Limiting the eligible use of the input material maize to 60% of a biogas plant is, in my opinion, very difficult to assign clearly to the advantages or disadvantages of the EEG amendment, since this measure depends very much on the individual perspective.
It is to be hoped that some subtleties of the legal text will be improved after a longer review and that the biogas industry will otherwise be creative and can integrate the changes well into the existing infrastructure. In the medium term, the high demands will only make bioenergy better and more competitive than fossil fuels!
What is your opinion on the EEG amendment?