Date:

2013 June 24

Dossier:

BBPZ/MCal/SGar/13-149

To: the EU Commissioner for Trade Koningin Julianaplein 10 CC: the EU Commissioner for the Environment, the EU Commissioner for Employment, Social Affairs and Inclusion, the EU Commissioner for Energy 2595 AA Den Haag Postbus 93121 2509 AC Den Haag

088 233 37 00 aedes@aedes.nl www.aedes.nl

Issue:

KvK 40478218

Duties solar panels

Dear Commissioner De Gucht, Aedes, Woonbond, Vereniging Eigen Huis, E-decentraal and Natuur & Milieu are deeply concerned with the anti-dumping duties on Chinese photovoltaics (PV) introduced by the European Commission. We expect this to have a detrimental impact on investments in solar PV in the housing sector. Affordability and energy poverty The Commissions decision not only raises the consumers cost of installing solar panels up by 25%1. It also creates concerns about the significance of the EUs energy policy. In line with the EU 2020 energy goals, many governments have invested public resources in campaigns and have set up financial support schemes to convince households and social landlords to invest in solar PV. Punitive import duties on solar PV have a detrimental effect on the ability to engage consumers and investors on crucial climate and energy issues. It disseminates a wrong message and creates uncertainty for investment projects in renewable energy. Also, price increases hurt local green jobs. Starting a trade conflict in this sector is even less understandable since the Commission itself points at the fact that: Sub optimal administrative arrangements clearly raise the costs of renewable energy and their removal normally has low fiscal implications () reduction in uncertainty and regulatory risk for investors can significantly reduce the cost of capital.2 The anti-dumping duty means a blow to a potentially large but not yet stable market. It will shake the entire solar industry; consumers and market players do not know what to expect in the near future. This has direct consequences for investments: return on investment decreases, self-sufficient schemes become dependent on subsidies, energy from solar PV becomes less affordable and in the end the fight against energy-poverty is hampered.

A.K. Hatt (Minister for Energy in Sweden) & G. Barker (Energy and climate change minister in the United Kingdom), The knock-on effects of solar panel tariffs will be huge. The Telegraph, 5 June 2013. 2 Commissions Renewable energy progress report, COM/2013/0175

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Slowdown of the energy revolution The Europe 2020 goals and 2030 framework for climate and energy policy targets acknowledge the need to invest in sustainable energy like solar power. Whereas buildings are responsible for 40% of CO emission, the reduction of greenhouse gases in this sector is indispensable . In the Netherlands one can speak of a true housing energy revolution. Dutch home owners and social landlords have shown their will to improve the energy performance of their dwellings by investing in refurbishments of the housing stock and in the transition towards renewable energy sources. The potential for PV in the housing sector is enormous. In the EU the installed capacity of solar panels has doubled in just two years. In the Dutch social housing sector the installation of PV solar panels even doubled in just one year3. Still, it only represents a relatively small (5%) share of the social housing stock of 2.4 million homes.

Dutch homeowners have installed thousands of solar power systems in recent years. As of early 2011, it is more beneficial in the Netherlands for households to generate solar power than to make use of traditional energy sources4. Current investment plans to greatly enhance solar power in the housing sector are put at risk if investment costs for PV panels are raised. The Commission seems to underestimate the wave of impending civil and local (bottom-up) initiatives that benefit from solar PV to empower themselves. These initiatives also enhance the support for renewable energy policy at large, and are important to overcome resistance against large scale renewables. Recommendation The much needed energy revolution is being delayed by the Commissions steps. Raising these import duties is a self-inflicting policy. It harms the EUs economic, social and environmental interests and undermines its 2020 energy goals. Therefor we ask the Commission to review its position on anti-dumping measures for solar panels and let European households benefit from affordable solar panels. We call on the Commission to better take into account the wider social and environmental consequences and prevent more uncertainty and price increases. We remain at your entire disposal to discuss these points. For more information please contact Sbastien Garnier, s.garnier@aedes.nl or +32 488 343 575. Yours sincerely,

Marc Calon Chairman of Aedes Dutch Association of social housing organization

Aedes members manage 2.4 million dwellings, constituting 34 percent of the total housing stock in the Netherlands.

3 4

Aedes Energy database SHAERE DNV Kema; http://www.dnvkema.com/nl/news/articles/2013/Belang-zonne-energie-voor-Nederlandseeconomie-neemt-aanzienlijk-toe.aspx

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Tjerk Wagenaar Director of Natuur & Milieu (Nature & Environment) Natuur & Milieu is a 40-year old Dutch environmental organization, working on affordable renewable energy for all.

Ronald Paping Director of De Nederlandse Woonbond

De Nederlandse Woonbond - the Dutch Union of Tenants - represents more than half of all the Dutch tenants. They are living in 1.5 million dwellings.

Rob J. Mulder Director of Vereniging Eigen Huis Dutch Association of Home Owners

Consumer organisation Vereniging Eigen Huis serves the interests of Dutch homeowners and especially members interests regarding all aspects of present and future home ownership. Vereniging Eigen Huis is a not-for-profit organisation with approximately 700.000 members

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Hans van der Vlist Chairman of e-Decentraal e-Decentraal is an interest group in which more than 400 initiatives in local energy initiatives are united. This real bottom up movement is working on better business cases, creating a level playing field and exchange of know how.