Time for a technology-specific approach

In order to strengthen resilience in the wind and solar supply chains, the Net-Zero Industry Act (NZIA) must develop a technology-specific approach to pre-qualification and non-price award criteria in government auctions, in recognition of the very different starting points in both technologies’ supply chains. 

WindEurope and SolarPower Europe fully subscribe to the EU’s Green Deal Industry Plan objectives to strengthening European supply chains in strategic Net-Zero technologies like wind and solar. The Net-Zero Industry Act is a cornerstone of this agenda. We fully support the NZIA provisions on market access and in particular Art 20, leveraging government auctions to advance these objectives via pre-qualification and non-price award criteria. It is, however, of utmost importance that the application of such criteria, and the share of the auction market to which these can apply, is set on a technology-specific basis. 

For wind, pre-qualification criteria related to responsible business conduct, cybersecurity and data security and ability to deliver the project fully and on time should apply to 100% of the auctions from the start as per the Wind Power Package. For solar, the share of auctions applying pre-qualification and non-price award criteria should be spelled out in an Implementing Act within 9 months following the adoption of the NZIA and correspond to auctioned volumes of around 5GW in 2025 and 30GW in 2030. 

Such a tailored approach is essential and inevitable given the very different supply chain starting points between wind and solar, as well as with any other strategic Net Zero technologies. It is impossible to apply a one-size fits all solution here. 

• For solar PV: today’s reality is that EU-produced components in the solar PV module value chain are not yet available in relevant volumes. Less than 3% (1.5 GW) of the expected 2023 solar module deployments of 54 GWdc can be fully made in Europe today. We, therefore, ask for specific “resilience auctions” for solar PV corresponding to auctioned volumes of around 5GW in 2025 and 30GW in 2030. This proposal is also supported by the European Solar PV Industry Alliance (ESIA).*
• For wind: the European supply chain can ramp up to meet the volumes needed provided governments apply the measures set out in the Wind Power Package on permitting, auction design – notably the indexation of auction tariffs - and visibility on future volumes.

We therefore call on policymakers involved in the NZIA trilogue negotiations to adopt the following amendment to the Council Article 20.4.

Council's General Approach, Art. 20.4: "4. Paragraphs 1 to 3 shall apply to at least 20% of the volume auctioned per year per Member State. Upon entry into force of the implementing act as referred to in paragraph 5, paragraphs 1 to 3 shall apply to the volume auc!oned per year per Member State as defined in the implementing act referred to in paragraph 5.”

Proposal for amendment to the Council’s General Approach, Art. 20.4: "4. Paragraphs 1 to 3 shall apply on technology-specific basis. For wind power, pre-qualification criteria listed in paragraph 1 point a) shall apply to all the volume auctioned by entry into force of this Regulation. For other technologies, in particular for solar, the share shall be defined by the Implementing Act as referred to in paragraph 5.”

*European Solar Industry Alliance, November 2023: https://solaralliance.eu/wp-content/uploads/2023/11/Recommendations-for-an-effective-and-practical-implementation-of-non-price-criteria.pdf 

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