Public consultation process on the EBRD draft Energy Sector Strategy

SEE SEP is a group of 17 partners who work together on a multi-country, multi-year, EU funded programme entitled South East Europe Sustainable Energy Policy (SEE SEP).

Representatives from our group recently attended the EBRD public consultation hearing in Belgrade on the 4th of September and, while we are assured that all the comments made at that consultation will be posted in full on the EBRD website and considered, we wished to embody in written form some of the key issues and points which we believe are critical to the EBRD Energy Strategy and the EBRD’s future consultative processes.
We strongly believe that in future all consultation meetings should include senior decision makers and board members from the EBRD in order for those who are most responsible for the strategy to be accountable to the public rather than less senior staff having to answer for decisions that they may not have had a strong influence on.

We are deeply concerned that EBRD does not have clear models and scenarios on how its countries of operations will achieve the necessary GHG emissions reductions in line with IPCC recommendations, nor on how they could manage energy demand and achieve the transformation to 2 energy-efficient, renewable energy-based economies. From this it follows that the EBRD has no clear picture of what its contribution needs to be to achieve these goals. Nor does it have a bank-wide climate target, which we believe is essentially especially for the accession and pre-accession countries of our region and we urge the EBRD to evaluate all energy projects in the context of the EU 2020 targets, forthcoming 2030 targets and 2050 Roadmaps in order to avoid investing in future stranded assets.
We were disappointed that while the EBRD has announced that it will establish a shadow carbon price this figure or even range was not available during the public consultation, which makes its impact unclear. We urge the EBRD to adopt a shadow carbon price at the same level as the EIB’s.
Given the insufficient attention paid in the strategy to how a transition to energy efficient, renewables-based economy can be achieved, we urge the EBRD to establish an emissions performance standard at the level of 350 gCO2/kWh to prevent investments into carbon-intensive energy generation infrastructure.

In our recent publication “Invest in Haste, Repent at Leisure” we pointed out that the EBRD’s investments in energy efficiency in the Western Balkans between 2006 and 2012 was approximately 12% of the bank’s energy sector investment portfolio, according to our project classification.
Among these investments there were very few residential energy efficiency investments or projects in public buildings, and we would like to see an increase in such projects. As we suggested at the public consultation – we would as a gesture of cooperation be interested in joining a brainstorming workshop or some such mechanism to see how to unblock greater latent potential for investment in energy efficiency and savings in our region.