Report Denmark 2015-En

December 2015
Danish report under Directive 2009/28/EC concerning progress in the use and promotion of energy
from renewable sources
Introduction
Article 22 of Directive 2009/28/EC requires Member States to submit a report to the Commission on
progress in the promotion and use of energy from renewable sources by 31 December 2011, and
every two years thereafter. The sixth report, to be submitted by 31 December 2021, shall be the last
report required.
This report is the third Danish submission and follows the template prepared by the Commission for
this purpose. The template comprises a series of questions from 1 to 12, with accompanying tables
and guideline text in italics.
Denmarks Renewable Energy Action Plan was submitted to the Commission in June 2010. This
action plan was most recently updated through the Energy Policy Agreement of 2012, which sets out
specific energy policy initiatives up until 2020 (see Annex 1).
This progress report contains a description of the situation in 2013 and 2014. The figures have thus
been calculated for the 2013 and 2014 calendar years, and the information contained in the report
focuses on the period up to and including 2015. This report updates the Renewable Energy Action
Plan and the implementation thereof.
All figures have been calculated in the same way as in Denmarks Renewable Energy Action Plan, i.e.
in ktoe, MW, GWh, etc., as required by the Commission. In addition, the figures are also presented in
TJ.
In Denmark, sustainability criteria have been introduced for the use of wood pellets and wood chips
for electricity and district heating in a voluntary industry-level agreement (see Annex 2). The
agreement has been drawn up by Dansk Energi (the Danish Energy Association) and Dansk
Fjernvarme (the Danish District Heating Association) and has the backing of the Danish Government.
Through the industry-level agreement, the energy companies have committed themselves to
documenting that the wood biomass used complies with international standards for sustainable
forestry and contributes to high CO2 displacement from the whole of the biomass supply chain. The
sustainability criteria in the industry-level agreement follow the Commissions recommendations
from 2010 and 2014, and are also inspired by the legislation in the United Kingdom.
Denmark was asked to enclose a description of how Denmark is complying with the Aarhus
Convention in the implementation of obligations under Directive 2009/28/EC. According to the
Aarhus Convention, the process must include reasonable time-frames for public participation. The
requested description is enclosed as Annex 3.
1. Sectoral and overall shares and actual consumption of energy from renewable sources in the
preceding 2 years (n-1; n-2 e.g. 2010 and 2009) (Article 22(1)(a) of Directive 2009/28/EC).
Please fill in the actual shares and actual consumption of renewable energy for the preceding
2 years in the suggested tables.
Table 1: The sectoral (electricity, heating and cooling and transport) and overall shares of energy from
1
renewable sources
2013
2
RES-H&C (%)
2014
35.52
43.12
5.59
26.68
RES-E (%)
4
RES-T (%)
5
Overall RES share (%)
38.40
48.48
5.67
28.45
Of which from cooperation mechanism (%)

7
Surplus for cooperation mechanism (%)
Notes to figures in Tables 1, 1a, 1d and 4:

The use of biofuels in the transport sector and of liquid biofuels in the electricity and heating sector
must be sustainable within the meaning of the RE Directive in order to be included. It has not been
verified whether the use of liquid biofuels (bio-oil) in the electricity and heating sector is sustainable.
Liquid biofuel is therefore not included in Tables 1, 1a, 1d and 4.
In the case of undertakings that are covered by quotas, if the CO2 emission factor for liquid biofuels
is to be set to zero, sustainability would have to be documented from 2013 onwards. However, it is
believed that the total quantities will be very small.
With regard to biofuels for transport, the sustainability criteria in the RE Directive have been
implemented in Danish legislation since 1 January 2010. The companies bound by the legislation
added a minimum of 0.55 % sustainable biofuels in the transport sector in 2010. The blending
requirement was increased to 3 % in 2011 and 5.75 % in 2012 (based on energy content).
Renewable energy sources for heating and cooling include an estimate for RE from heat pumps in
Tables 1, 1a, 1c and 1d.
Facilitates comparison with Table 3 and Table 4a of the NREAPs.

Share of renewable energy in heating and cooling: gross final consumption of energy from renewable sources
for heating and cooling (as defined in Article 5(1)(b) and (4) of Directive 2009/28/EC) divided by gross final
consumption of energy for heating and cooling. The same methodology as in Table 3 of NREAPs applies.
3
Share of renewable energy in electricity: gross final consumption of electricity from renewable sources for
electricity (as defined in Article 5(1)(a) and (3) of Directive 2009/28/EC) divided by total gross final
consumption of electricity. The same methodology as in Table 3 of NREAPs applies.
4
Share of renewable energy in transport: final energy from renewable sources consumed in transport (cf.
Article 5(1)c) and (5) of Directive 2009/28/EC) divided by the consumption in transport of 1) petrol; 2) diesel;
3) biofuels used in road and rail transport and 4) electricity in land transport (as reflected in row 3 of Table 1).
The same methodology as in Table 3 of NREAPs applies.
5
Share of renewable energy in gross final energy consumption. The same methodology as in Table 3 of NREAPs
applies.
6
In percentage points of overall RES share.
7
In percentage points of overall RES share.
2
The figures in the tables are based on Energistyrelsens (the Danish Energy Agencys) calculations,
which may differ from the calculations in SHARES.
Table 1a: Calculation table for the renewable energy contribution of each sector to final energy
8
consumption (ktoe)
Ktoe/year
A) Gross final consumption of RES for heating and cooling
B) Gross final consumption of electricity from RES
C) Gross final consumption of energy from RES in transport
D) Gross total RES consumption
2013
2014
2 609
1 329
222.3
4 145
2 572
1 460
229.5
4 246
E) Transfer of RES to other Member States

F) Transfer of RES from other Member States and third countries
G) RES consumption adjusted for target (D)-(E)+(F)
TJ/year
A) Gross final energy consumption of RES for heating and cooling
B) Gross final consumption of electricity from RES
C) Gross final consumption of energy from RES in transport
D) Gross total RES consumption
2013
2014
109 214
55 633
9 309
173 556
107 683
61 147
9 608
177 766
E) Transfer of RES to other Member States

F) Transfer of RES from other Member States and third countries
G) RES consumption adjusted for target (D)-(E)+(F)
Facilitates comparison with Table 4a of the NREAPs.

According to Article 5(1) of Directive 2009/28/EC, gas, electricity and hydrogen from renewable energy
sources shall be considered only once. No double counting is allowed.
9
Table 1b: Total actual contribution (installed capacity, gross electricity generation) from each renewable energy
technology in Denmark to meet the binding 2020 targets and the indicative interim trajectory for the shares of energy
10
from renewable resources in electricity
2013
Hydro11:
non-pumped
< 1 MW
1 MW-10 MW
> 10 MW
pumped
mixed12
Geothermal
Solar:
photovoltaic
concentrated solar power
Tide, wave, ocean

Wind:
onshore
offshore
13
Biomass :
solid biomass
biogas
bioliquids
TOTAL
of which in CHP
2014
MW
GWh
MW
GWh
9
9
5
3
571
571
4 492
3 395
1 096
1 347
1 255
85
7
6 418
1 347
21
21
12
8
518
518
10 585
8 001
2 584
4 330
3 945
384
0
15 454
4 330
9
9
4
4
607
607
4 854
3 583
1 271
1 413
1 318
95
6 882
1 413
20
20
10
10
596
596
12 076
8 914
3 162
4 294
3 844
450
0
16 986
4 294
10
Facilitates comparison with Table 10a of the NREAPs.

Normalised in accordance with Directive 2009/28/EC and Eurostat methodology.
12
In accordance with Eurostat methodology.
13
Takes into account only fuels complying with applicable sustainability criteria, cf. the last subparagraph
Article 5(1) of Directive 2009/28/EC.
11
14
Table 1c: Total actual contribution (final energy consumption ) from each renewable energy technology in
Denmark to meet the binding 2020 targets and the indicative interim trajectory for the shares of energy
15
from renewable resources in heating and cooling (ktoe)
Ktoe/year
Geothermal (excluding low temperature
geothermal heat in heat pump applications)
Solar
16
Biomass :
solid biomass
biogas
bioliquids
Renewable energy from heat pumps:
- of which aerothermal
- of which geothermal
- of which hydrothermal
TOTAL
17
Of which DH
Of which biomass in households
18
2013
2014
24
2 415
2 345
52
18
166
79
69
0
2 609
1 369
963
29
2 367
2 295
55
16
174
85
72
0
2 572
1 383
920
Note: Heat pumps at district heating plants etc. are not broken down by type.
Note: Biomass in households excludes biomass included in the households district heating consumption.
TJ/year
Geothermal (excluding low temperature
geothermal heat in heat pump applications)
Solar
16
Biomass :
solid biomass
biogas
bioliquids
Renewable energy from heat pumps:
- of which aerothermal
- of which geothermal
- of which hydrothermal
TOTAL
Of which DH
17
Of which biomass in households
18
14
2013
2014
114
83
1 015
101 125
98 189
2 181
755
6 960
3 308
2 889
0
109 214
57 337
40 322
1 224
99 082
96 075
2 320
686
7 294
3 559
3 014
0
107 683
57 907
38 520
Direct use and district heating as defined in Article 5(4) of Directive 2009/28/EC.
Facilitates comparison with Table 11 of the NREAPs.
16
Take into account only those complying with applicable sustainability criteria, cf. Article 5(1) of
Directive 2009/28/EC last subparagraph.
17
District heating and/or cooling from total renewable heating and cooling consumption (RES-DH).
18
From the total renewable heating and cooling consumption..
15
Table 1d: Total actual contribution from each renewable energy technology in Denmark to meet the binding
2020 targets and the indicative interim trajectory for the shares of energy from renewable resources in the
19 20
transport sector (ktoe) ,
Ktoe/year
Bioethanol/bio-ETBE
21
Of which biofuels Article 21(2)

22
Of which imported
Biodiesel
2013
2014
46.0
46.0
162.0
44.7
44.7
168.7
162
14.3
14.3
-
168.7
16.1
16.1
-
222.3
229.5
2013
2014
1 927
0
1 927
6 783
1 872
0
1 872
7 063
6 783
7 063
600
0
600
673
0
673
9 309
9 608
23

24
Of which imported
Hydrogen from renewables
Renewable electricity
Of which road transport

Of which non-road transport
Others (as biogas, vegetable oils, etc.) please
specify
25
TOTAL
TJ/year
Bioethanol/bio-ETBE
21

Of which imported
22
Biodiesel
23

Of which imported
24
Hydrogen from renewables

Renewable electricity
Of which road transport
Of which non-road transport
Others (as biogas, vegetable oils, etc.) please
specify
25
TOTAL
Note: Domestic production of biodiesel is confidential and is therefore calculated as imports.
19
For biofuels take into account only those compliant with the sustainability criteria, cf. Article 5(1) last
subparagraph.
20
Facilitates comparison with Table 12 of the NREAPs.
21
Biofuels that are included in Article 21(2) of Directive 2009/28/EC.
22
From the whole amount of bioethanol/bio-ETBE.
23
24
From the whole amount of biodiesel.
25
2. Measures taken and/or planned in the preceding 2 years at national level to promote the
growth of energy from renewable sources taking into account the indicative trajectory for
achieving the national RES targets as outlined in your National Renewable Energy Action Plan.
(Article 22(1)(a) of Directive 2009/28/EC)
See Table 2 at the end of the report.
2.a Please describe the progress made in evaluating and improving administrative procedures to
remove regulatory and non-regulatory barriers to the development of renewable energy.
(Article 22(1)(e) of Directive 2009/28/EC)
One-stop shop for offshore wind turbines
The administrative procedures for licensing offshore wind farms in Denmark have been simplified
and are predictable for businesses wishing to erect offshore wind farms. There is a one-stop shop
procedure which means that all the main licences for preliminary surveys, establishment and power
production are issued by the Danish Energy Agency. The Danish Energy Agency coordinates the
licences with all other relevant authorities, so, for example, terms relating to shipping which come
under Sfartsstyrelsen (the Danish Maritime Authority) are included in the Danish Energy Agencys
licences.
In addition, a new feature for the offshore wind farms that are put out to tender is that an intensive
dialogue is conducted with the tenderers to ensure that the terms of the licences are adapted
insofar as possible to the actual conditions faced by the tenderers when establishing the offshore
wind farm. Furthermore, the licences for preliminary surveys and establishment are prepared in
advance by the Danish Energy Agency so that the licences can be issued as soon as the contract for
the offshore wind farm has been signed. This substantially reduces the administrative burden on the
businesses.
2.b Please describe the measures in ensuring the transmission and distribution of electricity
produced from renewable energy sources and in improving the framework or rules for bearing and
sharing of costs related to grid connections and grid reinforcements. (Article 22(1)(f) of
Directive 2009/28/EC)
Denmark has a tradition of safeguarding the transparent and non-discriminatory connection of
renewable energy installations to the electricity transmission grid. Danish legislation implements
Article 16 of the RE Directive concerning access to and operation of the grids.
Plans for increased connections with neighbouring countries
The growing amount of renewable energy in the electricity system is characterised by being difficult
to regulate. It has to be accommodated in the electricity system in connection with domestic
electricity generating plants, new electricity consumption (heat pumps and electric vehicles) and
exchange opportunities with abroad.
The connections to abroad are particularly important because power stations are closing. There are
currently the following plans for connections:
The connection between eastern Jutland and Germany is being upgraded and a connection
between western Jutland and Germany is being studied.
A connection to the United Kingdom is being studied (Viking Link).
A political decision has been taken on the connection of offshore turbines at Kriegers Flak and
the connection from there to Germany with a view to entering into operation at the end of
2018.
The Cobra connection to the Netherlands is expected to enter into operation in 2019.
7
Smart and flexibly priced electricity consumption

Flexible consumption is expected to become increasingly important in the future. The volume is
currently very small, primarily because the economic incentives are not big enough to shift
consumption. However, there are both economic gains and financial gains for consumers from
shifting consumption from times when the electricity price is high to times when it is low. The
electricity price is typically low when a lot of wind power is produced, and, because the extent to
which power can be stored is limited, consumption should be adapted more to production. The
Danish Ministry of Energy, Utilities and Climate is therefore working to create a better framework
for exploiting the potential. Among other things, the implementation of the wholesale model in
2016 will provide an opportunity for billing of actual hourly consumption for both large and small
customers. In addition, the Danish Ministry of Energy, Utilities and Climate is initiating cooperation
with key stakeholders on smart energy with a view to mapping barriers and finding solutions.
Criteria for downward adjustment
Energinet.dk is responsible for operation of the contiguous electricity supply system and for
maintaining a balance and supply reliability in the grid. Energinet.dk maintains a balance in the grid
by making adjustments (upwards or downwards) to electricity generation at power stations that are
connected to the grid.
As noted in point 4.2.7(b) of the RE Action Plan, downward adjustment in the case of power stations
that use renewable energy sources can only take place subject to certain special conditions. The
criteria for downward adjustment are also handled by the authorities. In the past, competence was
shared between the Danish Energy Regulatory Authority and the Danish Energy Agency. This was
changed by Act No 466 of 18 May 2011 such that the Danish Energy Regulatory Authority alone is
responsible for the task (amendment of the Electricity Supply Act, the Natural Gas Supply Act, the
Heating Supply Act, the Energinet.dk Act and the Act on the promotion of renewable energy).
Provisions concerning reporting in the event of important measures to limit renewable energy
sources and the specification of rectification measures are set out in Order No 891 of 17 August
2011 on transmission system operation and the use of the electricity transmission grid, etc.
Responsibility for and distribution of costs in connection with grid connection and grid
reinforcement/expansion
The conditions are governed by Order No 1115 of 18 September 2015 on the connection of wind
turbines to the grid and premiums for wind turbine-generated electricity, etc. Owners of wind
turbines must pay connection costs through to a certain specified connection point. All costs for grid
reinforcement/expansion are covered by the grid and transmission undertakings.
The Order also contains provisions requiring grid and transmission undertakings to give wind turbine
owners that request a grid connection all the necessary information, including a detailed estimate of
all expenses that would be entailed in the connection process, a reasonable and accurate schedule
for receipt and processing of the application for grid connection and a reasonable schedule for the
grid connection itself.
In the case of power stations that use renewable energy sources other than wind, a similar
information provision is laid down in Order No 569 of 2 June 2014 on conditions and procedures for
the granting of permission to establish new electricity generation stations and important
modifications to existing stations.
3. Please describe the support schemes and other measures currently in place that are applied to
promote energy from renewable sources and report on any developments in the measures used
with respect to those set out in your National Renewable Energy Action Plan. (Article 22(1)(b) of
The Commission reminds Member States that all national support schemes must respect the State
aid rules as foreseen in Articles 107 and 108 of the Treaty on the Functioning of the EU. The
notification of the report in accordance with Article 22 of Directive 2009/28/EC does not replace a
State aid notification in accordance with Articles 107 and 108 of the Treaty on the Functioning of the
EU.
It is suggested that Table 3 is used to provide more detailed information on the support schemes in
place and the support levels applied to various renewable energy technologies. Member States are
encouraged to provide information on the methodology used to determine the level and design of
support schemes for renewable energy.
Table 3: Support schemes for renewable energy
RES support schemes year n (e.g. 2011)
Per unit support
Total (EUR
millions)*
[(sub) category of specific technology or fuel]

Instrument Obligation/quota (%)
(provide
Penalty/Buy out option/Buy out price (EUR/unit)
data as
Average certificate price
relevant)
Tax exemption/refund
Investment subsidies (capital grants or loans) (EUR/unit)
Production incentives
Feed-in tariff
Feed-in premiums
Tendering
Total annual estimated support in the electricity sector
Total annual estimated support in the heating sector
Total annual estimated support in the transport sector
* The quantity of energy supported by the per unit support gives an indication of the effectiveness
of the support for each type of technology
The requested description of support schemes and other measures can be found below under
section 3.0 (3.0.1-3.0.9).
3.0.1 Financial support
Support is provided for electricity generation based on renewable energy and for the use of biogas
for upgrading. Support for upgrading of biogas is laid down in the Natural Gas Supply Act, while the
other support schemes are laid down in the Act on the promotion of renewable energy (the RE Act).
The support is provided in the form of feed-in premiums for:
A. wind turbines (Sections 35a to 43 of the RE Act)
B. biogas, etc. (Sections 43a and 44 of the RE Act and Section 35c of the Natural Gas Supply
Act)
C. biomass (Sections 45 and 46 of the RE Act)
D. other RE plants (Sections 47 and 48 of the RE Act)
In addition, support schemes have been reported for the use of biogas for process purposes,
transport purposes and other purposes not covered by the other support schemes. These support
schemes have not entered into force because they are awaiting the European Commissions
approval under the State aid rules.
9
A. Feed-in premiums for wind turbines

Wind turbines with the exception of offshore turbines put out to tender and domestic turbines:
A feed-in premium will be paid for wind turbines connected to the grid in the period from
21 February 2008 to 31 December 2013 (inclusive) of DKK 0.25 per kWh for electricity generation
corresponding to the first 22 000 hours of generation at the wind turbines installed power rating
(full-load hours) following connection to the grid. Further compensation of DKK 0.023 per kWh will
also be paid for balancing costs for electricity from wind turbines. This compensation is expected to
be adjusted downwards from DKK 0.023 per kWh to DKK 0.018 per kWh to meet the European
Commissions requirement that the compensation must not exceed the average balancing cost.
In the case of wind turbines connected to the grid on or after 1 January 2014, a feed-in premium of
DKK 0.25 per kWh will be paid for electricity generation equivalent to the sum of 6 600 hours of
electricity generation at the wind turbines installed power rating (full-load hours) and electricity
generation based on 5.6 MWh per square metre of rotor area. The feed-in premium will be paid
from the time of connection to the grid. The feed-in premium of DKK 0.25 and the market price
combined must not exceed DKK 0.58 per kWh. The feed-in premium will thus be reduced as the
market price rises above DKK 0.33 per kWh.
Compensation for balancing costs for electricity from wind turbines is also paid. This compensation
is expected to be adjusted downwards from DKK 0.023 per kWh to DKK 0.018 per kWh to meet the
European Commissions requirement that the compensation must not exceed the average balancing
cost.
Offshore wind turbines put out to tender:
For offshore wind farm tenders in Denmark, the price is the critical award criterion. Settlements and
subsidies are therefore not fixed until the tenders have been completed. Creating good competition
for the open tenders ensures that the lowest possible support costs are achieved.
Domestic wind turbines:
A feed-in premium is paid for electricity that is supplied to the electricity distribution grid from a
wind turbine with an installed power rating of 25 kW or less which is connected to its own consumer
installation. For domestic wind turbines connected to the grid no later than 19 November 2012, the
premium is set such that the premium and the market price together amount to DKK 0.60 per kWh.
For domestic wind turbines connected to the grid between 20 November 2012 and 31 December
2015 inclusive, the premium is set such that the premium and the market price together amount to
DKK 2.50 per kWh for wind turbines with an installed power rating of 10 kW or less, and together
amount to DKK 1.50 per kWh for wind turbines with an installed power rating above 10 kW and up
to 25 kW inclusive. A draft law amending the support for domestic wind turbines as of 21 October
2015 has been proposed. According to the draft law, the support for domestic wind turbines will be
reduced gradually between 2016 and 2020, and annual funding pools with expansion limits will be
set up.
Increased premium for offshore pilot projects:
Provisions have been adopted concerning a 50 MW pool for pilot projects involving one or more
offshore turbines which could help to reduce the cost of generating electricity from offshore wind
turbines. These pilot projects can receive a higher feed-in premium which is set such that it and the
market price together amount to DKK 0.70 per kWh. The calculation base is determined on the basis
of the turbines power rating and rotor area, such that for ordinary turbine types it more or less
corresponds to 50 000 full-load hours of electricity generation.
10
B. Premium for biogas etc.

Electricity generation by means of biogas and gasification gas produced using biomass
For electricity generated by plants exclusively run on biogas and gasification gas produced using
biomass, a feed-in premium which when combined with the market price amounts to
DKK 0.793/kWh is paid. The sum of the premium and the market price is adjusted annually on the
basis of 60 % of the net price index.
In addition to the above-mentioned subsidies, premiums of DKK 0.26/kWh and DKK 0.10/kWh
respectively will also be paid. The premium of DKK 0.26/kWh will be adjusted downwards annually
from 1 January 2013 by DKK 0.01/kWh for each DKK/GJ of the amount by which the price of natural
gas in the preceding year exceeds a base price of DKK 53.2/GJ. If the price of natural gas falls below
the base price, the support will be adjusted upwards correspondingly. The premium of
DKK 0.10/kWh will be reduced in stages by DKK 0.02/kWh each year between 2016 and 2020, when
it will be removed completely.
Electricity generation using biogas and gasification gas produced using biomass and other fuels
For electricity generated using biogas, gasification gas produced using biomass and other fuels, a
feed-in premium of DKK 0.431/kWh is paid for the part of the electricity that is generated using
biogas and/or gasification gas. The premium is adjusted annually on the basis of 60 % of the net
price index.
Owners of biogas plants may choose to receive the premium of DKK 0.431/kWh instead of the
premium which when combined with the market price amounts to DKK 0.793/kWh (cf. above). The
choice must be made from the beginning of the year and is binding for one year.
In addition to the above-mentioned subsidies, premiums of DKK 0.26/kWh and DKK 0.10/kWh,
respectively, are also paid for the part of the electricity that is generated using biogas and/or
gasification gas. The two premiums are adjusted as described above.
Support for upgraded biogas supplied to the natural gas network and cleaned biogas supplied to the
town gas network
A premium of DKK 79 per gigajoule (GJ) will be paid for upgraded biogas that is supplied to the
natural gas network. In addition, a premium of DKK 26 and a premium of DKK 10 per GJ of upgraded
biogas supplied will be paid. The DKK 26/GJ subsidy will be adjusted downwards each year from
1 January 2013 by the amount in DKK per GJ that the natural gas price in the preceding year exceeds
a base price of DKK 53.2/GJ. If the price of natural gas falls below the base price, the support will be
adjusted upwards correspondingly. The premium of DKK 10/GJ will be reduced in stages by DKK 2/GJ
each year between 2016 and 2020, when it will be removed completely.
Cleaned biogas supplied to a town gas network will receive the same price premium as biogas
supplied to the natural gas network. The support is in the form of a price premium, so the producer
must sell the upgraded gas itself. The support is set out in Section 35c of the Natural Gas Supply Act.
Alongside the two support schemes described above, Folketinget (the Danish Parliament) has
adopted three support schemes that have not yet entered into force. They are:
11
Support for biogas for transport

A basic subsidy of DKK 39 per GJ of biogas sold for use in transport will be payable. In addition, two
premiums, of DKK 26/GJ and DKK 10/GJ, respectively, will be payable. The two premiums will be
adjusted as described above for upgraded biogas.
Support for biogas for process purposes
A basic subsidy of DKK 39 per GJ of biogas sold for use for process purposes in businesses will be
payable. In addition, two premiums, of DKK 26/GJ and DKK 10/GJ, respectively, will be payable. The
two premiums will be adjusted as described above for upgraded biogas.
Support for biogas for other purposes
For other uses of biogas, two premiums, of DKK 26/GJ and DKK 10/GJ, respectively, will be payable.
The two premiums will be adjusted as described above for upgraded biogas.
C. Premium for biomass
For electricity generated from the burning of biomass, a premium of DKK 0.15 per kWh will be paid,
irrespective of whether the electricity is generated by plants using biomass exclusively or by plants
using biomass in combination with other fuels.
D. Premiums for other renewable energy plants
A premium is paid for electricity generated from plants that exclusively use solar power, wave power
or hydro-electricity, or any renewable energy sources other than biogas or biomass. The premium is
set such that it and the market price together amount to DKK 0.60 per kWh for a period of 10 years
following grid connection and DKK 0.40 per kWh for the subsequent 10 years.
For electricity generated by energy sources other than those referred to above, a premium of
DKK 0.10 per kWh is paid for 20 years from the connection date.
For electricity generated by plants using the above-mentioned renewable energy sources in
combination with other energy sources, there is a premium of DKK 0.26 per kWh for 10 years and
DKK 0.06 per kWh for the subsequent 10 years.
New premiums for solar photovoltaic plants:
Provisions have been adopted concerning increased premiums for solar photovoltaic plants for a
certain period of time (transitional schemes) within an annual funding pool of 20 MW in the period
2013-2017.
Transitional schemes
For electricity generated by certain solar photovoltaic plants that are connected to the grid in the
period from 19 November 2012 to 10 June 2013 inclusive, an increased premium will be paid in
accordance with the transitional schemes of between DKK 0.90 and DKK 1.45 per kWh for 10 years
from the connection date. The same applies to electricity generated by certain plants which are
connected to the grid after 10 June 2013 where the owner has entered into a binding and
unconditional agreement concerning the purchase of the solar photovoltaic plant within certain
specified dates and otherwise fulfils certain specified conditions. The premium will be reduced if the
plant is connected to the grid after 2013.
12
Five-year 20 MW pool
From 2013 to 2017 inclusive, an increased premium of between DKK 0.90 and DKK 1.45 per kWh
(2013 rates) will be payable in relation to a funding pool totalling 20 MW annually. The pool
concerns plants that are connected to domestic households. All increased premiums (DKK 0.901.45 per kWh) will be paid for a period of 10 years from the connection date. The increased
premiums will be reduced each year during which the pool is distributed, so that the premium
gradually approaches the settlement price of DKK 0.60 per kWh.
Other solar photovoltaic plants
In the case of solar photovoltaic plants that are not covered by the funding pool, the premium is set
such that it and the market price together amount to DKK 0.60 per kWh for 10 years after the
connection date and DKK 0.40 per kWh for the subsequent 10 years.
3.0.2 Funding pool for small RE technologies
Subsidies are paid to promote the spread of smaller capacity electricity generating plants comprising
solar photovoltaic, wave power and biogas installations using technologies that are of significance
for the future spread of electricity from renewable sources. Subsidies are dependent on the plant
being connected to the grid.
The pool has been extended in connection with the Energy Policy Agreement of 2012 (cf. Annex 1,
point 2.6). Subsidies amounting to DKK 25 million per year will be paid in the period 2008-2015. The
pool is administered by Energinet.dk, which will invite applications once a year.
3.0.3 Investment grants for the production and sale of biogas
The agreement on Green Growth of 2009 included a start-up funding pool under the Rural District
Programme to which a total of DKK 300 million was allocated for the establishment and expansion of
biogas plants and supplementary investments in the companies supplying biomass to the plants.
The pool was to be distributed via three application rounds in 2010, 2011 and 2012. However, this
was amended, as the application round in 2010 showed, among other things, that it was very
difficult to finance the plants under the operating conditions applicable to biogas production at that
time.
A final round was therefore conducted in 2012, during which the new, improved operating
conditions in the Energy Policy Agreement resulted in a marked increase in interest in establishing
and expanding the plants. During this round, over 50 projects applied for around DKK 850 million in
investment grants. Around DKK 285 million was awarded to eight new joint biogas plants, four new
organic agricultural plants, one new conventional agricultural plant and five expansions to existing
plants. The awards are dependent on compliance with set deadlines.
No new investment grant pools for biogas are planned.
3.0.4 Four schemes for the promotion of onshore wind power
Four new schemes were introduced in the RE Act to promote the expansion of wind turbines. The
schemes are administered by Energinet.dk.
13
The devaluation scheme

The constructor of a wind turbine must pay compensation for the devaluation of residential
properties caused by the erection of the wind turbine. The extent of the devaluation is determined
by a valuation authority.
The purchasing rights scheme
The constructor of a wind turbine is obliged to offer at least 20 % of shares in the turbine to a group
of persons with purchasing rights. All residents over the age of 18 living up to 4.5 km from new wind
turbines may buy into local wind turbine projects. Shares not purchased by residents living within
the 4.5 km limit may be offered to residents elsewhere in the municipality. In the case of offshore
wind turbines, the group of residents with purchasing rights is expanded, so that residents in the
municipality or municipalities that have coastline within 16 km of the new offshore wind turbines
are entitled to buy shares.
The green scheme
With the green scheme, local authorities can apply for support from Energinet.dk for projects that
benefit the landscape and recreational opportunities in the local area and for cultural and
information activities. The funding pool that can be made available to the municipal authority
amounts to DKK 88 000 per MW of new wind turbines actually erected.
The guarantee fund
The guarantee fund was established to support the financing of preliminary investigations etc. by
local wind turbine committees prior to the erection of wind turbines. Decisions concerning the
issuing of guarantees are made by Energinet.dk. Guarantees are given for up to DKK 500 000 per
project.
3.0.5 Demonstration programme and heat pump task force
Demonstration programme
Grants are provided to promote the use of large electric heat pumps for district heating generation.
The demonstration programme shall, through a grant scheme, document the operational and
economic advantages of the district heating plants and kick start the spread of heat pumps so that a
large expansion can begin subsequently.
The Danish Energy Agency will subsidise the eligible costs by 25-40 %. However, the total amount of
support may not exceed DKK 1.5 million per installed MW of thermal output at an aid intensity of
25 %. If the aid intensity is increased, the support per installed MW of thermal output will be
increased in corresponding intervals from DKK 1.5 million to DKK 2.4 million at an aid intensity of
40 %. The total support per project cannot exceed DKK 20 million.
The 2015 Finance Act includes a pool of DKK 27.5 million in 2015 and DKK 27.7 million in 2016,
making a total of DKK 55.2 million. The pool is to be distributed in three application rounds, one in
2015 and two in 2016. However, the funds were rolled back in the 2016 Finance Act and the current
status of the scheme is that there will be only a single application round in 2015, after which the
scheme will be closed on 31 December 2015.
The first application round has been held and applications were received for 22 heat pump projects.
There were applications for the setting up of heat pumps with a total thermal capacity of 52 MW
and a total construction cost of DKK 375 million. Of this, DKK 84 million was sought in grants. On
15 December approval is expected to be granted for projects corresponding to a thermal output of
around 18 MW.
14
Heat pump task force

DKK 4.0 million per year in the period 2015-2017 was allocated for a task force aimed at helping
district heating plants with the specific implementation of heat pump solutions. The task force will
advise the plants on the possibilities of establishing a large heat pump for district heating generation
on the basis of locally available energy resources.
However, the funds were rolled back in the 2016 Finance Act and the current status of the heat
pump task force is that the opportunity to obtain advice will end on 31 December 2015.
3.0.6 Tax relief
The use of fossil fuels for heating and cooling attracts a substantial energy tax. In addition, there are
CO2 taxes which are dependent on the carbon content of the individual fuel. The energy and CO2
taxes on fossil fuels for space heating are around DKK 65 to 70 per GJ in 2015. The rates of energy
tax are indexed to the net price index.
At present there is no energy tax on RE fuels. This means that in 2015 there is a tax advantage of
around DKK 65 to 70 per GJ from using RE fuels rather than fossil fuels.
3.0.7 Phasing-out of fossil oil and gas for heating buildings
From 2013 rules were introduced to ensure that heating in new buildings is based on renewable
energy. These rules are applicable to all new buildings except those built in areas designated for
supply by district heating or which were designated for natural gas supply before 1 January 2013 (cf.
Annex 1, points 3.1 and 3.2). In these buildings, the heating may be based on renewable energy or
on either district heating or natural gas. In other buildings, the building heating must be based on
renewable energy such as wind power, solar energy, heat pumps, biomass, landfill gas, gas from
wastewater treatment plants, biogas and bio-oil.
To support the phasing out of oil and natural gas-fired boilers in existing buildings, a free and
impartial advice service has been introduced to advise building owners on how they can convert
their heating system from oil or natural gas to an RE-based alternative. In addition, various
demonstration projects have been set up with the aim of contributing to the introduction and costreduction of RE-based alternatives to oil and natural gas-fired boilers (see Annex 1, point 3.3).
3.0.8 Support schemes in the transport sector
Support is available via research schemes for electric vehicles. This support amounted to
DKK 10 million per year in the period 2008-2009, and DKK 5 million per year from 2010 to 2015. The
scheme was recently extended to the end of 2015 by point 6.4 of the Energy Policy Agreement of
22 March 2012.
In addition, electric and hydrogen-powered vehicles are exempt from registration tax and green
ownership tax up to the end of 2015. After then, registration tax will be phased in gradually by 2010,
while the exemption from ownership tax will end in 2016.
A total of DKK 70 million was allocated in the Energy Policy Agreement of 22 March 2012 (point 6.1)
for infrastructure for electricity, hydrogen and gas for heavy goods transport in the period 20122015 (DKK 1 million in 2012 and DKK 23 million per year from 2013 to 2015).
15
A support scheme has been introduced for electric buses. The scheme only applies to 2015 and
amounts to DKK 4 million.
In addition, support has been granted for a number of trials using alternative fuels for transport
under the Energy-efficient transport solutions funding pool. The pool was launched in 2009 as part
of a Green transport policy. A total of DKK 200 million was allocated to trial projects. Only a subset
of these concern alternative fuels.
3.0.9 Renewable energy for processing undertakings
Energy consumption by undertakings for processing purposes is largely based on the use of fossil
fuels, but there are insufficient tax incentives for the undertakings concerned to convert to RE. This
is primarily because these undertakings only pay a low energy tax on fossil fuels for process energy.
With the Energy Policy Agreement of 22 March 2012, it was decided to establish an investment grant
scheme for undertakings using process energy that convert from the use of fossil fuels to RE or
district heating. A total of DKK 3.75 billion was allocated for the period 2013-2020 (cf. Annex 1,
point 3.5). The funding pool was subsequently adjusted to DKK 3.65 billion and extended to 2021 as
a result of political agreements.
It is estimated that it will be possible to achieve conversions to renewable energy and district
heating totalling 16 PJ/year with the funds in the pool, the expectation being that the main emphasis
of the scheme will be on conversion to biomass.
The scheme was notified as State aid provided in accordance with Commission Regulation (EC)
No 800/2008 declaring certain categories of aid compatible with the common market in application
of Articles 87 and 88 of the Treaty (General block exemption Regulation).
The aid is calculated on the basis of three criteria:
1. The maximum rates of aid indicated in the General block exemption Regulation
2. A maximum aid amount of DKK 23 per GJ of fossil energy displaced
3. A simple repayment period of at least two years for the supported projects
3.1. Please provide the information on how supported electricity is allocated to final customers for
purposes of Article 3(6) of Directive 2003/54/EC. (Article 22(1)(b) of Directive 2009/28/EC)
The declaration of electricity to consumers (final customers) is governed by Order No 1322 of
16 November 2010 on the declaration of electricity to consumers (the Electricity Labelling Order), as
amended by Order No 403 of 28 April 2011 amending the Order on the labelling of electricity to
consumers.
The Electricity Labelling Order states that the electricity trading company must use either a general
declaration or an individual declaration. The general declaration is drawn up by Energinet.dk on the
basis of the average fuel consumption and environmental impact. The individual declaration must be
supported by guarantees of origin for RE electricity or high-efficiency cogenerated heat that are
cancelled by the electricity trading company. The issuing and cancellation of guarantees of origin is
taken care of by Energinet.dk.
16
4. Please provide information on how, where applicable, the support schemes have been
structured to take into account RES applications that give additional benefits, but may also have
higher costs, including biofuels made from wastes, residues, non-food cellulosic material, and
ligno-cellulosic material? (Article 22(1)(c) of Directive 2009/28/EC)
There is no support for biofuels (other than research and development support from the Energy
Technology Development and Demonstration Programme, EUDP). However, biofuels are exempt
from CO2 tax. Biofuels based on waste, waste products, non-food cellulosic material and lignocellulosic material count double with respect to the Danish blending requirement (part 6).
Support for the use of biogas can partly be justified through its environmental advantages in terms
of improved aquatic environment, reduced greenhouse gas emissions from agriculture, reduced
nuisance caused by unpleasant smells, increased fertiliser value of degasified slurry from livestock
manure, etc.
5. Please provide information on the functioning of the system of guarantees of origin for
electricity and heating and cooling from RES, and the measures taken to ensure reliability and
protection against fraud of the system. (Article 22(1)(d) of Directive 2009/28/EC)
Denmark only operates with guarantees of origin for electricity (not heating or cooling) from
renewable energy sources (see Order No 1323 of 30 November 2010 on guarantees of origin for
electricity from renewable energy sources and Order No 1322 of 30 November 2010 on the
declaration of electricity to consumers).
In Denmark, guarantees of origin can only be issued by Energinet.dk. It is therefore Energinet.dk that
registers and monitors guarantees of origin that have been issued and their transfer or cancellation.
To eliminate the risk of VAT fraud, Energinet.dk sends a request to the Danish Customs and Tax
Administration (SKAT) when accounts are to be created by new market players. SKAT then
investigates whether the player is known within the European tax cooperation for, for example,
carousel fraud.
Energinet.dk must ensure that the records are correct, reliable and safeguarded against fraud.
Guarantees of origin are issued electronically in Denmark, in accordance with the European Energy
Certificate System (EECS), the voluntary common European standard. The standard describes how
guarantees of origin are to be issued, traded and used. Furthermore, all users of the EECS are
contractually obliged to refrain from repeated use of guarantees of origin. Energinet.dk is a member
of the Association of Issuing Bodies (AIB), which drew up the standard. Energinet.dk was audited in
2015 to ensure that its processes comply with the requirements of the standard.
In addition, Energinet.dk uses the cmo.grexel system to administer guarantees of origin. This system
also used by a number of other European countries. It is possible to check information in the
cmo.grexel system, and Energinet.dk also uses a national register of master data to check
information.
Energinet.dk states that the number of guarantees of origin for RE electricity issued and transferred
in Denmark and sold to other Member States has risen considerably over the years. The table below
shows the trend over the period 2011-2015.
17
Table: The trend in issuing, transfer and cancellation

(One guarantee of origin corresponds to one MWh).
1.1.
Year
Issued
Cancelled*
Exported
Imported
2011
2012
2013
2014
6 126 553
1 810 761
5 264 978
1 312 082
9 198 116
2 760 388
6 713 625
2 383 487
12 688 731
3 998 285
8 787 604
1 708 800
16 533 662
8 330 499
7 176 803
2 363 459
2015 (as at
8 Nov.)
15 244 116
12 375 319
7 591 598
4 655 381
Source: www.grexel.com
* Data do not cover guarantees of origin that are cancelled by Energinet.dk because they are more than 12 months old (see
Article 15(3) of the Directive). The data cover cancellations in the Danish registry for consumption in other countries (exdomain cancellation). Cancellations for consumption (sale to end customers) in Denmark have been fairly constant at
around 2 000 000 per year since 2011.
Please see Annex 1 of the 2011 progress report for a more detailed description of the system for
guarantees of origin in Denmark.
6. Please describe the developments in the preceding 2 years in the availability and use of biomass
resources for energy purposes. (Article 22(1)(g) of Directive 2009/28/EC)
Tables 4 and 4a provide more detailed information on the biomass supply.
18
Table 4: Biomass supply for energy use

Ktoe/year, etc.
Amount of
domestic raw
material *
(tonnes)
2013
2014
Primary energy
in domestic
raw material
(ktoe)
2013
Biomass supply for heating and electricity:

Direct supply of
wood biomass
from forests and
other wooded
2 235
1 972
731
land energy
generation
(fellings etc.)**
Indirect supply
of wood
biomass
(residues and
721
591
260
co-products
from wood
industry etc.)**
Energy crops
(grasses, etc.)
and short
rotation trees
(please specify)
Agricultural byproducts /
processed
1 422
1 270
493
residues and
fishery byproducts **
Biomass from
waste
(municipal,
1 073
2 009
494
industrial etc.)
**
Others (please
specify)
Biomass supply for transport:
Common arable
crops for
biofuels (please
specify main
types)
Energy crops
(grasses, etc.)
and short
rotation trees
for biofuels
(please specify
main types)
Others (please
specify)
2014
Amount of
imported raw
material from EU
* (tonnes)
2013
2014
Primary energy
in amount of
imported raw
material from
EU (ktoe)
2013
2014
Amount of
imported raw
material from
non EU *
(tonnes)
2013
2014
Primary energy
in amount of
imported raw
material from
non EU (ktoe)
2013
2014
632
754
682
203
183
55
62
15
17
215
1 845
2 024
581
637
456
500
190
209
440
509
* Amount of raw material if possible in m3 for biomass from forestry and in tonnes for biomass from agriculture and
fishery and biomass from waste.
** The definition of this biomass category should be understood in line with Table 7 of part 4.6.1 of Commission Decision
C(2009) 5174 final establishing a template for National Renewable Energy Action Plans under Directive 2009/28/EC.
19
Table 4: Biomass supply for energy use

TJ/year, etc.
Amount of
domestic raw
material *
(tonnes)
Primary energy
in domestic raw
material (TJ)
2013
2014
2013
Biomass supply for heating and electricity:
Direct supply of
wood biomass
from forests and
other wooded
2 235
1 972
30 597
land energy
generation
(fellings, etc.)**
Indirect supply of
wood biomass
(residues and co721
591
10 889
products from
wood industry,
etc.)**
Energy crops
(grasses, etc.)
and short
rotation trees
(please specify)
Agricultural byproducts /
processed
1 422
1 270
20 625
residues and
fishery byproducts **
Biomass from
waste (municipal,
1 073
2 009
20 683
industrial, etc.)
**
Others (please
specify)
Biomass supply for transport:
Common arable
crops for biofuels
(please specify
main types)
Energy crops
(grasses, etc.)
and short
rotation trees for
biofuels (please
specify main
types)
Others (please
specify)
Amount of
imported raw
material from
EU * (tonnes)
2014
2013
2014
Primary energy
in amount of
imported raw
material from
EU (TJ)
2013
2014
Amount of
imported raw
material from
non-EU *
(tonnes)
2013
2014
Primary energy
in amount of
imported raw
material from
non-EU (TJ)
2013
2014
26 476
754
682
8 500
7 669
55
62
620
694
9 004
1 845
2 024
24 311
26 672
456
500
7 975
8 749
18 409
21 296
With the Energy Policy Agreement of 22 March 2012, it was agreed that the Government would
prepare a study of bioenergy in Denmark. The study was presented in May 2014 and it indicated,
among other things, that there could be increasing challenges in ensuring the environmental
sustainability of imported wood for energy purposes, in particular in the period after 2020. As a
follow-up to the study, and owing to a lack of requirements at EU level, the former Minister for
Climate, Energy and Building called upon the Danish energy industry to present sustainability criteria
for solid biomass in a voluntary agreement.
In December 2014, the organisations Dansk Energi (the Danish Energy Association) and Dansk
Fjernvarme (the Danish District Heating Association) published their Brancheaftale om sikring af
20
bredygtig biomasse (Industry agreement to ensure sustainable biomass). The agreement contains
requirements and criteria that the energy companies will comply with when they use wood biomass
for generating electricity or heating. The agreement specifies, among other things, that biomass
must satisfy the following criteria.
1. Legality The biomass resources must be harvested in a legal way under applicable local and
national forest legislation.
2. Protection of ecosystems Exploitation of wood resources must not adversely affect the
functions of forests in relation to conserving biodiversity.
3. Maintaining productivity Forestry and harvesting of biomass must not adversely affect the
productivity of the forest, i.e. there are requirements that areas are replanted with forest.
4. Health: Forests must be managed in such a way that they are healthy and function well,
including implementing protective measures against fire, disease and illegal logging, etc.
5. Biodiversity: Endangered animals and plants must be protected, and areas designated as
valuable habitats must be conserved.
6. Social rights: The forest usage rights of indigenous people must be respected and complaint
mechanisms etc. must be established. There must be a right to organise labour, and child
labour is not permitted. The health and safety of employees must be protected.
7. CO2 displacement chain (cultivation, transport, power station efficiency, etc.) must be at
least 70 % lower than a fossil reference for energy production in the EU.
Each year the energy companies must present documentation reports explaining how they are
complying with the requirements of the agreement.
Table 4a. Current domestic agricultural land used for production of crops dedicated to energy
production (ha)
Land use
Surface (ha)
1. Land used for common arable crops (wheat, sugar beet, etc.) and
oilseeds (rapeseed, sunflower, etc.) (Please specify main types)
Rapeseed, beet and maize.
2. Land used for short rotation trees (willows, poplars). (Please
specify main types)
Willow, poplar and coppice.
3. Land used for other energy crops such as grasses (reed canary
grass, switch grass, Miscanthus), sorghum. (Please specify main
types)
Miscanthus, reed canary grass.
2013
130 000
2014
125 000
9 014
9 518
85
80
Note: Land used for common arable crops are own calculations on the basis of the biogas census and Statistics Denmark
(yield per ha)
Sources:
Row 1 Beet and maize: Report pursuant to the Order on sustainable production of biogas (Danish Energy Agency).
Rapeseed: Statistics Denmark (Tables hst6 and afg07), Energi fra biomasse Ressourcer og teknologier vurderet i et
regionalt perspektiv (Energy from biomass Resources and technologies assessed from a regional perspective) by
Jrgensen U., Srensen P., Adamsen A.P. and Kristensen I.T. (2008), p. 47, in which it is estimated that 70-80% of rapeseed
production is for biodiesel with simultaneous production of rapeseed cake and glycerine.
Row 2 The Danish AgriFish Agency
7. Please provide information on any changes in commodity prices and land use within Denmark in
the preceding 2 years associated with increased use of biomass and other forms of energy from
renewable sources. Please provide where available references to relevant documentation on
these impacts in Denmark. (Article 22(1)(h) of Directive 2009/28/EC)
It is considered that the change in demand for biomass for energy in the previous two years was
relatively small, so there is no measurable effect on raw materials prices and land use in Denmark.
21
8. Please describe the development and share of biofuels made from wastes, residues, non-food
cellulosic material, and ligno-cellulosic material. (Article 22(1)(i) of Directive 2009/28/EC)
According to the Biofuels Act, 5.75 % biofuel must be added to fuel for road transport. Total
consumption of biofuels (ethanol and biodiesel) amounted to 8.7 PJ in 2013 (corresponding to
around 208 ktoe), of which Article 21(2) biofuels (biofuels from waste, residues, non-food cellulose
or ligno-cellulose) accounted for a small share. The precise amount has not been calculated. Table 5
has therefore not been filled in.
Table 5: Production and consumption of biofuels, cf. Article 21(2) (ktoe)
Article 21(2) biofuels26
Production Fuel type X (Please specify)
Consumption Fuel type X (Please specify)
Total production Art. 21.2. biofuels
Total consumption Art. 21.2. biofuels
% share of Art. 21.2. fuels from total RES-T
Year n-2
0
0
0
0
0
Year n-1
0
0
0
0
0
9. Please provide information on the estimated impacts of the production of biofuels and
bioliquids on biodiversity, water resources, water quality and soil quality within your country in
the preceding 2 years. Please provide information on how these impacts were assessed, with
references to relevant documentation on these impacts in Denmark. (Article 22(1)(j) of
Production has been so limited that, in the opinion of the Danish Energy Agency, there has not been
a significant impact.
10. Please estimate the net greenhouse gas emission savings due to the use of energy from
renewable sources (Article 22(1)(k) of Directive 2009/28/EC).
For the calculation of net greenhouse gas emission savings from the use of renewable energy, the
following methodology is suggested:
For biofuels: In accordance with Article 22(2) of Directive 2009/28/EC.

For electricity and heat it is suggested to use the EU-wide fossil fuel comparators for electricity
and heat as set out in the report on sustainability requirements for the use of solid and gaseous
biomass sources in electricity, heating and cooling27, if no later estimates are available.
If a Member State chooses not to use the suggested methodology for estimating the net greenhouse
gas emission savings, please describe what other methodology has been used to estimate these
savings.
26
Biofuels made from wastes, residues, non-food cellulosic material, and ligno-cellulosic material.
The report is available at:
http://ec.europa.eu/energy/renewables/transparency_platform/doc/2010_report/com_2010_0011_3_report.
pdf.
27
22
Table 6: Estimated GHG emission savings from the use of renewable energy (t CO2eq)
Environmental aspects
Total estimated net GHG emission saving from using renewable energy29
- Estimated net saving from the use of renewable energy for electricity
- Estimated net saving from the use of renewable energy in heating and cooling
- Estimated net saving from the use of renewable energy in transport
2013
Million tonnes
8.9
7.1
0.7
28
2014
Million tonnes
10.0
7.0
0.7
11. Please report on (for the preceding 2 years) and estimate (for the following years up to 2020)
the excess/deficit production of energy from renewable sources compared to the indicative
trajectory which could be transferred to/imported from other Member States and/or third
countries, as well as estimated potential for joint projects until 2020. (Article 22(1)(l) and (m) of
28
The calculation of greenhouse gas savings for renewable energy for heating and cooling has been adjusted
relative to the RE progress report for 2013.
29
The contribution of gas, electricity and hydrogen from renewable energy sources should be reported
depending on the final use (electricity, heating and cooling or transport) and only be counted once towards
the total estimated net GHG savings.
23
Table 7: Actual and estimated excess and/or deficit (-) production of renewable energy in
Denmark compared to the indicative trajectory which could be transferred to/from other Member
States and/or third countries (ktoe)
Ktoe/year
Estimated excess as stated
in the National Renewable
Energy Action Plan
Estimated deficit as stated
Energy Action Plan
Total gross consumption of
energy (H)
Proportion of gross
consumption of energy
from renewable energy
sources
([Table 1a D)]/[H]%)
Indicative trajectory for
renewable energy sources
relative to the 2020 target
(%)30
Actual excess production
relative to indicative
trajectory
2010
2011
2012
694
834
2013
2014
2015
2016
2017
2018
2019
2020
1 123
1 106
833
928
552
619
63
15 549
14 928
26.7
28.4
19.6
19.6
20.9
20.9
22.9
22.9
25.4
25.5
30.1
30
895
1 126
30
The guideline development for the proportion of renewable energy sources is presented in Table 3 of the RE
Action Plan of June 2010 and was most recently updated in a memorandum sent to the Commission in April
2011.
24
Table 7: Actual and estimated excess and/or deficit (-) production of renewable energy in
Denmark compared to the indicative trajectory which could be transferred to/from other Member
States and/or third countries (PJ)
PJ/year
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
Estimated excess as stated

Energy Action Plan
Estimated deficit as stated
Energy Action Plan
Total gross consumption of
energy (H)
Proportion of gross
consumption of energy
from renewable energy
sources
([Table 1a D)]/[H]%)
Indicative trajectory for
renewable energy sources
relative to the 2020 target
(%)29[sic]
Actual excess production
relative to indicative
trajectory
29
35
47
46
35
39
23
26
651
625
26.7
28.4
19.6
19.6
20.9
20.9
22.9
22.9
25.4
25.5
30.1
30
37
47
11.1. Please provide details of statistical transfers, joint projects and joint support scheme
decision rules.
As stated in the RE Action Plan of June 2010, the Danish Government expects to be able to fulfil its
commitments for expansion with renewable energy up to 2020 through national measures. On this
basis, it will probably not be necessary to use the RE Directives cooperation mechanisms for
statistical transfers between countries in order to ensure Danish compliance with the objectives.
However, the Danish Government is prepared to make the expected excess of renewable energy
available to other countries in the period up to 2020, during which time the share of renewable
energy is expected to be above the indicative trajectory every year.
In October 2014 the Danish Energy Agency projected Denmarks energy consumption up to 202531.
According to this projection, the share of RE in 2020 is expected to be around 38 %, so Denmark will
exceed its binding 2020 RE target of 30 % by around 8 percentage points.
Denmark expects to enter into a cooperation agreement with Germany in 2016 concerning the
mutual opening of tenders for support for solar cells to plants located in the other country. Solar
photovoltaic plants in Germany will therefore be able to receive support from Denmark, and solar
photovoltaic plants in Denmark will be able to receive support from Germany. It is expected that,
pursuant to Article 6 of the RE Directive, the energy from the plants concerned will be transferred
statistically from the country in which the energy is produced to the country which is providing the
support.
31
Danmarks Energi- og Klimafremskrivning 2014 (Denmarks energy and climate projections 2014), Danish
Energy Agency, October 2014.
25
12. Please provide information on how the share for biodegradable waste in waste used for
producing energy has been estimated, and what steps have been taken to improve and verify such
estimates. (Article 22(1)(n) of Directive 2009/28/EC)
In the energy and CO2 emission statistics, waste is divided into two categories: biodegradable and
non-biodegradable. In accordance with international conventions, including the RE Directives
definition in Article 2, the biodegradable component is counted as renewable energy. In Danish
energy statistics it is expected that 55.0 % of consumption of waste is biodegradable. This proportion
is determined on the basis of a study carried out in 2012.
From 1 January 2013 Denmark has decided to include 21 of the largest waste incineration plants in
the CO2 quota adjustment. Incineration plants with CO2 emissions above 50 000 tonnes of CO2 per
year will measure their CO2 emissions, while other plants will apply standard national factors.
There are nine waste incineration plants that emit more than 50 000 tonnes of fossil CO2 per year.
These plants will determine their annual emission of fossil CO2 by measuring the CO2 content of the
flue gas. Two different methods are used for these measurements. These are a 14C method and a
mass balance method (Bioma), which is based on a number of balances set up for the plant. The
results of the measurements for the first two years show that the measurement uncertainties of the
methods of measurement are relatively high. Work on standardising the methods of measurement is
currently in progress which may contribute to more uniform measurement.
Because the measurement uncertainty is high, no decision has yet been taken on how the
measurements from the waste incineration plants can be used to quality assure the national CO2
emission factors for waste.
26
Table 2: Overview of all policies and measures

Where relevant, reference is made to sections in the RE Action Plan (abbreviated to REAP) and the Energy Policy Agreement of 2012 (abbreviated to EPA).
Name and reference of the
measure
Tendering of offshore wind farms
Type of
measure*
Economic
Adjustment of premium for wind

turbines (RE Act)
Increase in premium for domestic
wind turbines
Economic
Increased premium for small

offshore pilot projects
Economic
Support for wave power

Funding pool for strategic energy
planning in the municipalities
Economic
Economic
New and increased premiums for

use of biogas for electricity
generation and upgrading
New premiums for transport,
processing and other use of biogas
Funding pool for RE technology in
district heating (geothermal energy
and large heat pumps)
Economic,
regulation,
information
Economic,
regulation
Economic
Economic
Expected result**
Establishment of 1 350 MW of
offshore wind turbines. 400 MW at
Horns Rev, 600 MW at Kriegers Flak
and 350 MW of inshore wind farms.
Erection of more efficient types of
wind turbine.
Large expansion of small domestic
wind turbines
Support of future technology for
offshore wind farms and
establishment of up to 50 MW of
pilot projects
Testing of wave power
Promoting strategic energy planning
between municipalities, undertakings
and energy companies
Promoting biogas production
Promoting biogas production and

consumption
Promoting new RE for heating
purposes
Targeted group and/or

activity***
RE electricity generation,
investors.
Existing or
planned
Planned
Investors, RE electricity
generation
Autoproducers, investors, RE
electricity generation
Existing
Development, RE electricity
generation
Planned
Industry and research

Municipal authorities,
undertakings and energy
companies, as well as the
Government and regional
authorities
CHP plants and other
upgrading that uses biogas
Planned
Existing
2014 2015
2012 2015
Existing
2013
Undertakings and others that

use biogas
District heating companies
Planned
Existing
2012 2015
27
Existing
Start and end dates of

the measure
Contract for Horns
Rev was entered into
in 2015. Others are
expected in 2016.
Entered into force
1 January 2014
Decided January
2013. Entered into
force February 2015.
Approval to be given
by the end of 2019.
Reference
REAP: 4.2.1 and 4.3
EPA: 2.1 and 2.2
EPA: 2.7
EPA: 2.10
REAP: 4.2.8. 4.3 and

4.6
EPA: 5.1-5.5
EPA: 5.1.-5.5.
EPA: 2.13

measure
Funding pool for RE for processing
Type of
measure*
Economic

activity***
Undertakings
Existing or
planned
Existing

the measure
2013 2020
Roll-out of hourly and remotely

readable meters
Regulation
Electricity consumers, grid

companies and electricity
trading companies
Energinet DK (TCO)
Existing/
planned
2013-2020
International electricity exchange

capacity
Supervision of regulation of the
Danish electricity supply sector
Regulation,
analyses
Regulation,
analyses
Building regulations
Regulation
Promoting the interconnection of

electricity markets
Providing incentives for green
conversion, cost-effectiveness,
competition and consumer
protection
Promoting energy savings
Existing/
planned
Existing/
planned
The building industry and

consumers
Existing
End customers
Existing
Information
The building industry
Existing
Last amended in
August 2013
1 January 2016
March 2010
Last amended
2012 2015
2008 2015
Information campaign for energy

efficiency improvements
Information
Knowledge Centre for Energy

Savings in Buildings
Tax relief for electric vehicles
Economic
Promoting the use of electric vehicles
Existing
2015
Economic,
information
Acquiring experience and knowledge

of the use of electric vehicles and
their interaction with the electricity
system
Establishment of infrastructure that
can promote the use of alternative
fuels for transport
Promoting electric buses
Restricting the number of oil and gas
boilers installed in new buildings and
supplied by fossil fuels
Manufacturers and
consumers
Undertakings, authorities,
institutions and organisations
Research scheme for electric

vehicles (Order on state support
for a research scheme for electric
vehicles)
Funding pool for infrastructure for
electricity, hydrogen and gas for
heavy goods vehicles
Subsidies for electric buses
Phasing out of oil and natural gas
boilers for building heating
Existing
2008-2015
REAP: 4.5
EPA: 6.4
Undertakings, authorities,
institutions and organisations
Existing
2012-2015
REAP: 4.5
EPA: 6.1
Transport companies
Consumers
Existing
Existing
2015
Jan. 2013
Economic
Economic
Regulation
Expected result**
Promoting the energy-efficient use of
renewable energy
Promoting smart electricity
consumption
The Government, electricity

sector and others
28
2012 2014
Reference
EPA: 3.5
EPA: 4.1 and 4.5

EPA: 4.7
REAP: 4.2.3
EPA: 1.3
REAP: 4.2.4
EPA: 1.7
REAP: 4.2.4
EPA: 1.5
REAP: 4.5
EPA: 3.1

measure
Establishment of advice service
concerning alternatives to oil and
natural gas boilers
Type of
measure*
Information
Establishment of demonstration
projects concerning alternatives to
oil and natural gas boilers
Reorganisation of support for solar,
wave power and hydro etc. after
abolition of annual net settlement
Tendering of solar photovoltaic
Economic,
information
Economic
Demonstration programme for

large electric heat pumps for
district heating generation
Financial
measure
Economic
Expected result**

activity***
Consumers
Existing or
planned
Existing

the measure
Aug. 2013
Undertakings
Existing
Jul. 2013
Autoproducers, investors, RE
electricity generation
Existing
Establishment of 20 MW of solar
photovoltaic
RE electricity generation,
investors.
Planned
Around 18 MW of thermal output

expected to be installed
Local district heating plants
Existing
Applies to plants
erected since
November 2012
Contracts expected to
be entered into in
2016
From 1 July 2015 to
15 September 2016
Information for building owners

concerning the possibility of
converting from oil and natural gas to
RE-based alternatives
Testing of new technologies and
reducing the cost of existing
technologies and business forms
Controlled expansion of solar
photovoltaic etc.
Reference
EPA: 3.3
EPA: 3.3
* Indicate if the measure is (predominantly) regulatory, financial or soft (i.e. information campaign).
** Is the expected result behavioural change, installed capacity (MW; t/year), energy generated (ktoe)?
*** Who are the targeted persons: investors, end-users, public administration, planners, architects, installers, etc.? or what is the targeted activity/sector: biofuel production, energetic use of
animal manure, etc.)?
29
22 March 2012
Agreement
between the Government (the Danish Social Democrats, Danish Social-Liberal Party and
the Socialist Peoples Party) and the Liberal Party, Danish Peoples Party, Danish RedGreen Alliance and Conservative Peoples Party
concerning Danish Energy Policy 2012 2020
The parties are in agreement that the conversion of Denmark to an energy supply met by renewable
energy is dependent on a reliable, stable and long-term framework concerning the Danish Energy
Policy. This agreement establishes specific energy policy initiatives for the period 2012-2020. The
agreement will support joint EU targets.
Duration of the agreement:
- The agreement covers the period 2012-2020.
- The parties will prepare an annual status of agreed new initiatives and analyses and any
continuation of initiatives that expire.
- The Government will prepare an annual status of savings that are realised (see agreed cost
reduction measures). If the anticipated savings resulting from the regulatory supervision are
not realised, the parties undertake to provide alternative financing. The energy efficiency
initiative will be adjusted correspondingly in the event that this is not possible.
- The parties will meet in 2015 to discuss the continuation of initiatives and financing for the
agreement, including the distribution of DKK 60 million annually from the energy efficiency
package in the period after 2015.
- The parties undertake to enter into discussions by the end of 2018 regarding specific
supplementary initiatives for the period after 2020.
The parties have agreed to implement the following initiatives with a view to fulfilling the purpose of
the agreement:
An energy-efficient society with less energy wastage

The realisation of the goal of an energy supply met by renewable energy requires an increase in
energy efficiency that minimises energy wastage and energy consumption in all sectors. The parties
note that it was decided in the Danish Finance Act to introduce a subsidy pool for energy
refurbishments in residential properties in 2013 and 2014. The parties are furthermore in agreement
regarding the following:
The savings obligations incumbent on energy companies are to be increased in relation to the
initiative for the period 2010-2012 by 75 %, corresponding to 10.7 PJ per year for the period
2013-2014, and by 100 %, corresponding to 12.2 PJ per year for the period 2015-2020.
In connection with the increased savings obligations, the energy companies initiatives are to be
targeted at existing buildings and industries. It will be an aim to enter into a cost-effective
agreement with the energy companies to strengthen the exposure to competition of the
initiative. A total of DKK 12 million will be allocated to support energy saving initiatives in the
period 2012-2015.
An overarching strategy for the energy renovation of the existing building stock, including an
investigation of the scope to tighten up requirements concerning building components, will be
drawn up, and a comprehensive analysis of the area, including initiatives to ensure better
30
compliance with the requirements of the building regulations and the use of ESCO models, will
be carried out. The minimum requirements for building components in the building regulations
will be future-proofed to reflect future challenges and anticipated energy prices. The strategy
will be discussed by the parties to the agreement by the end of 2013. The strategy will be based
on an overall analysis of the existing building stock, including the possible potential with the aim
of ensuring that the strategy is targeted at the most cost-effective initiatives.
A total of DKK 30 million will be allocated in the period 2012-2015 to support the energy
renovation of the existing building stock.
A total of DKK 20 million will be allocated in the period 2012-2015 for the continuation of the
initiative in the Knowledge Centre for Energy Savings.
The municipal CO2 calculator for the municipalities annual CO2 statements will be further
developed and updated. A total of DKK 2 million will be allocated for this in the period 20122015.
Given the significant reinforcement of the energy companies energy savings obligations, the
current campaign and information activities in Go Energi will be wound up. The remaining
activities will be transferred to the Danish Energy Agency, which will then assess which of these
activities are to be continued. This will release funds amounting to DKK 60 million annually. From
2012 to 2015, these funds will be allocated to other energy efficiency measures, as described in
Annex 3. The parties will meet in 2015 to discuss the distribution of the remaining funds
available for the energy efficiency package.
As a follow-up to the Energy Policy Agreement of 2008 and the strategy to reduce energy
consumption in buildings, the parties have agreed to implement an energy-saving package,
which will promote energy savings in private rental accommodation. The energy saving package
will, among other things, include the following initiatives under the remit of the Ministry of
Housing, Urban and Rural Affairs:
Opportunity to demand a larger increase in rent following energy renovation than is the
case under the applicable rules, provided the requirement concerning total financial
profitability has been fulfilled.
New model for agreed green urban renewal.
Increase in the amount that can be claimed by tenants for improvements, provision for
the prior approval of rent increases in connection with improvements to premises,
energy requirements as a condition for landlords being able to apply Section 5(2) of the
Danish Housing Regulation Act, and the right to require the installation of water meters.
The package will involve indirect tax revenue losses, which in 2020 will amount to
DKK 11 million. These revenue losses will be financed by the security of supply tax.
A green and sustainable energy supply based on renewable energy

The parties are in agreement regarding the following:
Development of wind power and other renewable energy technologies
By 2020, offshore wind power will be expanded by 1 000 MW of offshore wind turbines and
500 MW of inshore wind turbines.
600 MW at Kriegers Flak and 400 MW at Horns Rev will be put out to tender between
2013 and 2015, with commissioning anticipated in the period 2017-2020. The
development at Horns Rev will be initiated first.
The screening of areas will take place during the first half of 2012 with a view to
establishing 500 MW of inshore wind turbines by 2020. The detailed settlement model
will be determined by the parties following the screening.
It is critical that thorough preparations are carried out for putting offshore wind farms out to
tender and that the wind farms are marketed to potential tenderers and implemented with
flexibility in order to ensure the greatest possible level of competition and lowest prices. A total
31
of DKK 12 million will be allocated in the period 2012-2015 to strengthen the initiative with
regard to the putting of offshore wind turbines out to tender.
The construction of new onshore wind turbines with a total capacity of 1 800 MW is anticipated
by 2020. The dismantling of 1 300 MW of capacity is also anticipated during the same period.
Support for this will be sought via new planning tools, strategic environmental assessments, the
adaptation of the framework conditions as a result of technological developments and other
measures. A proposal for this will be drawn up and submitted during the first half of 2013, and
the parties to this agreement will reach agreement on any new initiatives. The proposal will
partly be based on the evaluation of the four schemes in the RE Act (the green scheme, the
purchasing right scheme, the devaluation scheme and the guarantee fund) and will include an
assessment of the scope to further cut premiums for investments where the full premium is not
necessary.
A change will be made to the settlement for new wind turbines connected to the grid from
1 January 2014, such that the fixed premium, which is nominally DKK 0.25/kWh for the first
22 000 full-load hours will in future be reduced by one re for each re that the market price of
electricity exceeds DKK 0.33/kWh nominally, and thus be removed completely if the electricity
price reaches or exceeds DKK 0.58/kWh at current prices. At the same time, the calculation basis
will be changed for the supported production, so that it is weighted by 30 % of the turbine
power and 70 % of the rotor area.
To safeguard future investment opportunities, etc. concerning wind turbines, the existing Danish
Wind Turbine Secretariat will continue to perform this task within the Danish Ministry of the
Environment. A pool of DKK 13.2 million will be allocated for the period 2012-2015 in order to
finance the secretariat.
There will be an extension of the existing PSO-financed pool for new renewable energy
technologies for electricity generation (solar, wave, etc.) amounting to a total of DKK 100 million
over four years.
A total of DKK 25 million will be allocated in 2014-2015 to support the construction and
demonstration of wave power projects.
Promotion of CHP, district heating and biomass, etc.

Changes will be made to the Danish Heat Supply Act with a view to promoting the conversion of
central CHP plants to biomass. Electricity and heating generators and heating customers will be
given the opportunity to enter into voluntary agreements, according to which the tax benefits of
switching from fossil fuels to biomass for heat generation may be split between the two parties.
To assist the smaller and troubled open-field plants struggling with high heat prices changes will
be made to the rules so that, the 35 CHP plants with the highest heat prices may, in connection
with the dispensation application, be given permission to install a biomass-powered boiler up to
a maximum of 1 MW to be used solely for heat production.
A funding pool will be set up with a total of DKK 19 million in the period 2013-2015 to promote
partnerships for strategic energy planning between municipalities, local businesses and energy
companies, and to improve the interaction between government, regional and municipal
initiatives and to support municipal planning and citizen-focused initiatives. Government
involvement will be supported with a total of DKK 4.8 million.
An analysis of the role of district heating in the energy supply of the future will be prepared and
submitted by the end of 2013. DKK 3 million will be allocated for the analysis.
An analysis of the use of bioenergy in Denmark will be carried out. This analysis will focus on
whether the right conditions exist for the efficient and environmentally sustainable use of
biomass resources in Danish energy supply. The analysis will also look at CO2 displacement. A
total of DKK 7.5 million will be allocated for the period 2012-2015. The analysis will be submitted
by the end of 2013.
32
A funding pool will be set up for the promotion of renewable energy in district heating
(geothermal, large heat pumps, etc.) amounting to a total of DKK 35 million for the period 20122015.
Conversion to renewable energy in buildings and industry

The parties have agreed to support the phasing out of oil-fired boilers in existing buildings in cases
where there are financially profitable alternatives. On the basis of this, the following initiatives will
be implemented:
From 2013, a ban will be introduced on the installation of oil and natural gas-fired boilers in new
buildings. There will be provision for exemptions from this ban in cases where no suitable
alternatives exist.
The parties are in agreement that from 2016 it will no longer be possible to install oil-fired
boilers in existing buildings in areas where district heating or natural gas is an alternative, and
that it will still be possible to install oil-fired boilers in existing buildings in areas without these
alternatives.
In order to support the conversion from oil and natural gas-fired boilers in existing buildings to
forms of heating based on renewable energy, a funding pool totalling DKK 42 million will be
allocated for the period 2012-2015 to promote initiatives for and the preparation of analyses of
energy-efficient alternatives, including heat pumps, solar and solar thermal. The scheme will
subsequently be evaluated.
An analysis of the future use of the gas infrastructure will be carried out by the end of 2013
both during a transition phase with the continued use of natural gas and in a future where
biogas and other renewable energy gases take over. A total of DKK 2 million is being allocated
for this analysis.
A funding pool will be set up with DKK 250 million available in 2013, and DKK 500 million per
year as of 2014, which will be maintained until 2020. The pool will promote the energy-efficient
use of renewable energy in company production processes. The support will be given as a
construction subsidy for projects that replace fossil fuels with renewable energy or district
heating, and energy efficiency measures directly associated with these conversion projects.
Companies that currently use district heating for processing may instead choose to receive a
subsidy on an ongoing basis for their additional costs, up to a maximum of DKK 42 per GJ
provided that the CHP production is converted to biomass and provided that the scheme is
approved by the EU under the State aid rules. An evaluation of the scheme will be carried out
during the first half of 2015.
An annual grant of DKK 30 million is being introduced from 2013 until 2020 to maintain and
promote industrial CHP in industry and horticulture, which will be financed by the security of
supply tax.
A general basic allowance will be introduced for coal, coke and petroleum coke used for heavy
processing. This relief will amount to around DKK 3 million in both 2013 and 2014, and will
thereafter amount to around DKK 10 million per year in the period 2015-2020. The new
allowance will be formulated on the basis of sulphur content per GJ of coal fuel.
An analysis will be carried out concerning the potential for better exploitation of surplus heat
from industry. The issue will be discussed by the parties to this agreement before the middle of
2013. These discussions will include a discussion of the issue of the unequal scope for passing on
tax changes.
33
Smart grids, etc.

Realising the goal of phasing out fossil fuels will require the further expansion of the electricity
system in an intelligent manner. Therefore, the parties are in agreement regarding the following:
New international electricity exchange capacity will be established in connection with the
construction of Kriegers Flak. The EU is providing around DKK 1.1 billion in support for the
interconnection of the Danish and German electricity markets.
An overarching strategy for the establishment of smart electricity grids in Denmark will be drawn
up in 2012. The parties will discuss possible new initiatives on the basis of the strategy.
Efforts will be made to establish an agreement with the grid companies concerning the roll-out
of remotely readable hourly electricity meters.
An analysis will be carried out concerning the scope to maintain the high functionality of the
electricity network in a situation with steadily rising wind strengths, with particular emphasis on
the period after 2020. DKK 2 million will be provided to support the analysis and subsequent
work. The analysis will be completed in 2013.
An analysis will be carried out concerning the opportunities and effects of exchange
connections, including connections to developments in neighbouring countries. The analysis will
be presented by the end of 2014.
A wholesale model will be established to promote competition in the electricity market, partly
by ensuring that electricity consumers receive a single invoice from electricity trading
companies. The wholesale model will not require any changes to consumer prices or payment
terms which are parameters for competition. A compulsory insurance scheme will be set up to
safeguard the maintenance of government tax revenue.
A detailed review will be carried out of the regulation of the Danish electricity supply sector with
a view to providing incentives for green conversion, cost-effectiveness, competition, and
consumer protection. The regulatory review will be concluded in 2014. A total of DKK 13 million
will be allocated for this in the period 2012-2014.
Better framework conditions for biogas developments

An ambitious expansion of biogas will be implemented. The financial conditions for biogas
production will be improved with a view to facilitating progress in this field, and it will be possible to
use biogas outside the CHP sector to a greater extent than at present. The parties have therefore
agreed, among other things, that overall support for biogas used for CHP or distributed via the
natural gas network should be able to amount to DKK 115/GJ in 2012. This will be achieved through
the following:
A new combined support model for biogas, where:

The existing support of DKK 79/GJ for biogas used in CHP plants will continue as a basic
subsidy.
Subsidy equalisation will be implemented for biogas supplied to the natural gas network
relative to biogas used for CHP generation, so that biogas supplied to the natural gas
network will also receive the basic subsidy of DKK 79/GJ.
A new basic subsidy will be introduced of DKK 39/GJ net for biogas for processes in
undertakings and transport.
The start-up support from the construction pool will be increased from 20 % to 30 % in
2012.
A subsidy of DKK 26/GJ will be introduced for all biogas users. The subsidy will be
reduced in line with increases in natural gas prices. The subsidy will be reduced by
DKK 0.01/GJ when the natural gas price rises by DKK 0.01/GJ.
A further supplement of DKK 10/GJ will be introduced for all biogas users. From 2016 the
subsidy will be reduced in DKK 2/GJ steps to DKK 0/GJ in 2020.
34
The regulations will be amended with a view to facilitating a voluntarily transition from fixed
electricity prices to electricity price premiums for purely biogas-based plants.
Municipal natural gas companies will be given the opportunity to become involved in biogas
production as an associated activity to their commercial activities.
A task force will be set up to investigate and support specific biogas projects with a view to
ensuring the expected biogas expansion up until 2020. If the necessary development of new
projects does not occur in 2012-2013, the parties are in agreement that discussions will take
place in 2014 concerning other options to promote biogas development, including specific
proposals involving purchase obligations. DKK 9.6 million will be allocated to the task force in the
period 2012-2015 to support the expansion of biogas.
The biogas task force will be continued. A total of DKK 13.2 million will be allocated for this in
the period 2012-2015.
Electricity and biomass in the transport sector

In the longer term, the transport sector must undergo radical conversion from fossil fuels to new
fuels such as electricity and biomass. The parties are in agreement regarding the following initial
steps in this conversion:
A strategy will be drawn up to promote energy-efficient vehicles such as hybrid plug-ins, electric
vehicles, etc., for which a funding pool of DKK 70 million will be distributed in the period 20132015 to support the roll-out of charging points for electric vehicles, the infrastructure for
hydrogen and the infrastructure for gas in heavy goods transport. The strategy will be discussed
by the parties to the agreement in 2013.
Amendments will be made to the Danish Biofuels Act with a view to ensuring the admixture of
10 % biofuels by 2020. However, the implementation of this awaits an analysis of alternative
initiatives to comply with the EUs obligations in relation renewable energy in transport. The
analysis will be completed in 2015.
A funding pool amounting to DKK 9 million will be set up for the period 2013-2015 for a model to
develop an analysis of the climate and energy-related conditions related to the use of alternative
fuels. The work will support the reduction of CO2 emissions from the transport sector. One
element of this work will be the interplay between the fuels and the energy system.
A total of DKK 15 million will be allocated in the period 2013-2015 for the continuation of the
electric vehicle research scheme.
Increased research, development and demonstration activities

Investments in research, development and demonstration activities are also prerequisites for Danish
undertakings to develop and sell green solutions and create green jobs in Denmark in the longer
term. The parties are in agreement regarding the following:
The parties will strive to continue the high level of research and development in energy
technology to support continued efficiency improvements in the use of energy and promote
cost-effective renewable energy technologies that also have commercial and export potential.
A total of DKK 9.5 million will be allocated in the period 2012-2015 to support the ongoing work
on Sams to demonstrate solutions for the creation of a fossil fuel free island.
The parties note that the framework for receiving support from the PSO-financed ForskEL
programme is broad, but subject to the restriction that individual research projects must have a
significant link to the electricity system.
35
Financing of the agreements energy policy initiatives

The agreements new energy policy initiatives up until 2020 require financing. At the same time,
there is a need to ensure the long-term sustainability of government finances, which includes
ensuring that the system of taxes and subsidies can also help to support the green conversion going
forward. The framework conditions must support green investments and make it attractive for
consumers to make green choices. The parties are in agreement regarding the following:
The agreement will be implemented in a cost-effective manner and give consideration to

customers and the competitiveness of companies.
The additional costs for energy companies as a result of the increased energy savings obligations
will be financed through the companies tariffs.
Support costs in connection with the expansion of renewable energy supplied to the electricity
grid will be financed through PSO schemes.
Support for renewable energy supplied to the gas network will be financed via a PSO scheme for
gas consumption corresponding to the existing PSO scheme for electricity.
Other support will be financed via the Finance Act (cf. the initiatives in Annex 3).
Government subsidies for renewable energy for processing, biogas (for transport and
processing), industrial CHP, energy savings packages for private rental properties and the
government tax revenue losses that will result from the displacement of fossil fuel will be
financed via a security of supply tax.
The security of supply tax will be imposed on all space heating, i.e. space heating generated by
both fossil fuels and biomass, and will enter into force in 2013. However, this will require a new
tax basis with regard to biomass; hence this must be formulated with due consideration for the
EUs anti-discrimination and State aid rules and will enter into force no later than 2014.
To ease the burden of the security of supply tax on consumers of fossil fuels, who already pay
high taxes, the tax rise in respect of fossil fuels already subject to taxation will be reduced by
DKK 7.5/GJ by no later than in 2020 (2010 level).
In order to shield private companies from the tax financing of the agreements energy policy
initiatives, tax relief will be provided in respect of energy taxes on electricity and fuel for
processing. This tax relief will be financed via the security of supply tax and will ensure that the
burden borne by private companies collectively from the security of supply tax and processing
energy tax relief will be reduced to DKK 75 million in 2020. The tax relief relating to energy taxes
on electricity and fuel for processing will be phased in gradually by 2020 alongside the other
financing measures for the agreement.
The security of supply tax will generate DKK 0.6 billion in 2013 for financing the agreements
energy policy initiatives, rising to DKK 2.8 billion in 2020 in immediate revenue following the
deduction for compensation of industry (see Table 1).
Table 1. The security of supply taxs financing contribution

2011 prices, DKK billions
2013 2014 2015 2016
Direct revenue less
0.6
1.4
1.7
1.9
compensation for industry
2017
2018
2019
2020
2.2
2.4
2.5
2.8
The remaining proposed expenditure relating to the Finance Act will be financed within the
allocated reserves for energy negotiations for the Finance Act for 2012 and through the windingup of the campaign and information activities in Go Energi.
With a view to assessing the need for adjustments, there will be a review of the existing subsidy
and taxation system will be reviewed, including the scope for providing the right incentives for
conversion to a green, cost-effective and flexible energy system. The terms of reference for the
36
analysis will be approved by the parties to the agreement. The analysis will be completed by
2014.
With a view to reducing the cost for citizens and undertakings of the initiatives in the
agreement, a number of cost-reducing initiatives will be implemented, such as increased
competition, efficiency measures, etc. relating to the monopoly-regulated companies in the
electricity sector, including the grid companies and Energinet.dks activities, which in summary
form can be broken down as specified in Annex 2. The Government is obliged to report on the
status of any savings realised on an annual basis, so there will be continuous monitoring to
ensure that the agreement is not built on erroneous economic foundations.
37
Overview of analyses and studies for the conversion of the overall energy supply to clean renewable energy
The conversion of the energy supply to clean renewable energy is a very extensive task. It is critical that the various subsystems of the energy sector
operate optimally together during the conversion, but at the same time the requisite infrastructure must be continuously developed. To ensure an
adequate knowledge base that supports the most economic and effective solutions, the agreements initiatives, and decisions regarding new initiatives for
the next phase in the conversion process, there will be a need to initiate a number of analyses and studies in the period 2012-2015 for which funds will be
allocated.
The parties will meet and discuss the analyses and studies when they have been completed. The parties are in agreement regarding the implementation of
the following initiatives:
Topics in the Energy Policy
Agreement
Analyses, etc.
An energy-efficient society with less

energy wastage
Analysis of the role of district heating in the future energy supply by the end of 2013.
The municipal CO2 calculator for the municipalities annual CO2 statements will be further developed and
updated. A total of DKK 2 million will be allocated for this in the period 2012-2015.
Strategy for the energy renovation of the existing building stock, including the scope to tighten up requirements
concerning building components, and a comprehensive analysis of the area, including initiatives to ensure better
compliance with the requirements of the building regulations and the use of ESCO models. The minimum
requirements for building components in the building regulations will be future-proofed to reflect future
challenges and anticipated energy prices. The strategy will be discussed by the parties to the agreement by the
end of 2013. A total of DKK 30 million will be allocated for this in the period 2012-2015.
A green and sustainable energy
supply based on renewable energy
Analysis of the future use of the gas infrastructure both during a transition phase with the continued use of
natural gas and in a future where biogas and other renewable energy gases take over by the end of 2013.
Analysis of the use of bioenergy in Denmark. The analysis will focus on whether the right framework conditions
exist for the efficient and environmentally sustainable use of biomass resources in Danish energy supply,
including CO2 displacement. The analysis will be submitted by the end of 2013.
Analysis of the potential to maintain the high level of functionality of the electricity network in a situation with
steadily rising wind strengths.
Analysis of the potential and effects of exchange connections.
Analysis of models of support for solar energy.

38
Smart grids
Strategy for the establishment of smart electricity grids in Denmark.
Transport
Recurring technology assessments for the transport sector.

Strategy for the promotion of energy-efficient vehicles such as hybrid plug-ins, electric vehicles, etc., which will
be discussed in 2013.
Other
Detailed review of the regulation of the Danish electricity supply sector with a view to providing incentives for
green conversion, cost-effectiveness, competition and consumer protection. The regulatory review will be
concluded in 2014. A total of DKK 13 million will be allocated for this in the period 2012-2014.
Review of the subsidy and taxation system with the aim of assessing the need for adjustments to the existing
system, so that, in economic terms, it provides appropriate incentives for conversion to a green and flexible
energy system. The terms of reference for the analysis will be approved by the parties to the agreement.
Development of a general equilibrium model for modelling energy systems and the economy to identify effective
policy measures and future regulatory measures. A total of DKK 15.2 million will be allocated for this in the period
2012-2015.
An analysis of the overall energy initiative and possible new initiatives to identify the pivotal preconditions and
strategic choices to ensure the conversion of the overall energy supply to clean renewable energy in 2050, and to
identify how the sub-elements of the energy system (electricity, heating and transport) can interact together. The
analysis will be prepared in advance of the parties meeting in 2018 to discuss initiatives after 2020.
Analysis and underlying data concerning the energy-related conditions of industry, in particular the effect of
competitiveness in relation to other countries in both the short and the long term for different industries. The
analyses will incorporate new knowledge concerning the scope for energy efficiency, the scope for passing on
costs and the identification of rural/urban problems, in addition to the development of energy efficiency under
different assumptions regarding developments in energy prices, CO2 prices, technological development, etc. A
total of DKK 10 million will be allocated for this in the period 2013-2015.
39
Annex 1 concerning the financing and phase-in profile for the security of
supply tax, PSO and tariffs
Table: Annual financing broken down by PSO, tariffs and security of supply tax, rounded to the
nearest DKK 100 million
DKK millions
2012
2013
2014
2015
2016
2017
2018
2019
2020
Energy Policy
Agreement1)
-300
700
1 400
1 800
1 800
2 500
2 900
3 400
3 500
100
100
200
200
300
800
1 100
1 500
1 400
-300
100
-200
-100
-300
-400
-500
-600
-600
600
1 400
1 700
1 900
2 200
2 400
2 500
2 800
PSO
Tariffs
Security of
supply tax2)
1) Due to rounding, the total of the sub-contributions does not necessarily add up to the overall
rounded total for the financing.
2) The security of supply tax is not expected to generate revenue until 2013, and it is expected that
the loss in revenue of around DKK 100 million in 2012 will be financed in 2013.
40
Annex 2
The initiatives in the agreement will result in a number of investments and costs of significance for
citizens and industry. Therefore, a number of measures will be implemented in parallel during the
agreement period, which will reduce energy costs for consumers compared with the developments
that would take place without these measures. Measures will be implemented which, it is estimated,
will result in savings totalling around DKK 1.8 billion in 2020.
Table: Measures to reduce the burden on consumers
DKK millions in 2020
PSO
Network tariffs
(electricity +
(electricity, gas, oil,
gas)
district heating), etc.
Cost-reduction measures
Inshore wind turbine model
-200
Efficiency improvement of
-755
Energinet.dk
Energinet.dks acquisition of
-200
regional transmission
networks
Energy efficiency
-110
Regulatory review altered
-300
economic regulation of
network companies
Deferment of aspects of the
-130
cable action plan
Wholesale model
-75
Total
Treasury (space
heating)
Total
-200
-755
-200
-110
-300
-130
-75
-1 770
Reduced costs for the erection of inshore wind turbines: Reassessment of the need for support
based on a reduced requirement for test turbines and the scope to distribute support over a longer
period. The establishment of 400 MW at DKK 0.70/kWh will generate savings in relation to the
amount assumed in the strategy document Vores energi (Our Future Energy) of around
DKK 200 million by 2020 (2011 prices).1
Cost reductions in the energy companies savings initiatives: A ceiling will be established for the
total cost of the energy companies savings initiatives which will generate savings of DKK 110 million
by 2020 (2011 prices) compared to the amount anticipated in Our Future Energy. If it transpires that
the anticipated energy savings cannot be achieved within this ceiling, the parties will discuss how to
deal with this.
Energinet.dks acquisition of regional transmission networks: It is anticipated that Energinet.dk will
acquire the regional transmission networks in 2012. The takeover of these regional networks is
anticipated to generate benefits in the form of lower operating costs amounting to DKK 200 million
by 2020.
Efficiency improvements to Energinet.dk, etc.: Energinet.dk will initiate savings and efficiency
measures, amend the depreciation of electricity activities and pay any excess bottleneck income
faster than previously assumed, such that in 2020 costs will be reduced by DKK 775 million in total,
benefiting energy consumers through lower tariffs for the use of Energinet.dks network.
The parties to the agreement subsequently reached agreement to establish a further 100 MW via inshore
wind turbines, making a total of 500 MW.
41
Cable action plan: In 2009, the parties to the Energy Policy Agreement reached an agreement
concerning the cable action plan, which included total investments of DKK 15.2 billion at 2011 prices
for the laying of cables and aesthetic projects. Parts of the projects have been postponed, which will
save costs amounting to a total of DKK 130 million in 2020.
Benefits associated with the amended regulation of the electricity sector: Our Future Energy
includes a review of the regulation of the electricity sector. Benefits associated with changes to the
economic regulation of the network companies are expected to produce savings of DKK 300 million.
Wholesale model: The introduction of the wholesale model to the electricity sector is itself expected
to contribute a reduction in consumer-related costs for network companies and electricity trading
companies combined of DKK 100 million. The gain relates to the direct saving from not having to
issue two invoices. In addition, the wholesale model will open up a number of tasks to competition,
which on one hand is expected to lead to efficiency gains, but on the other hand will entail a loss for
consumers as a result of a greater risk of loss of tax revenues, PSO and network tariffs.
42
Annex 3: Funding pools under the Energy Policy Agreement

Table 1: Initiatives related to the Finance Act
DKK millions
2012
2013
2014
2015
Initiatives that have been or are being

implemented:
Detailed review of electricity supply
legislation
Equilibrium model (CGE model)
9.0
9.2
6.5
3.5
Total, 20122015
28.2
5.0
5.0
3.0
13.0
4.0
4.2
3.5
3.5
15.2
Prioritised initiatives not yet

implemented:
Support for biogas development
Analysis of bioenergy usage
Support for wind development
Energy planning and smart grids
Promotion of new RE technology
Commercial analyses of energy usage
Support for fossil-fuel-free island (Sams)
25.5
31.5
54.0
54.8
165.8
5.7
1.5
6.3
3.0
5.0
2.0
2.0
5.7
2.0
6.3
3.0
10.0
2.0
2.5
5.7
2.0
6.3
12.0
22.5
3.0
2.5
5.7
2.0
6.3
12.8
22.5
3.0
2.5
22.8
7.5
25.2
30.8
60.0
10.0
9.5
DKK millions
2012
2013
2014
2015
Prioritised energy efficiency initiatives

Promotion of alternatives to oil-fired
boilers
Support for energy-saving initiatives
Energy renovation of the existing building
stock
Continuation of Knowledge Centre for
Energy Savings in Buildings
Transport infrastructure
Continuation of the electric vehicle
research scheme
Climate- and energy-related conditions
associated with alternative fuels
CO2 calculator
20.0
3.0
60.0
13.0
60.0
13.0
60.0
13.0
Total, 20122015
200.0
42.0
3.0
7.5
3.0
7.5
3.0
7.5
3.0
7.5
12.0
30.0
5.0
5.0
5.0
5.0
20.0
1.0
0.0
23.0
5.0
23.0
5.0
23.0
5.0
70.0
15.0
0.0
3.0
3.0
3.0
9.0
0.5
0.5
0.5
0.5
2.0
Table 2: Energy efficiency packages
43
DANSK ENERGI
(Danish Energy Association)
DANSK FJERNVARME
(Danish District Heating Association)
Industry agreement to ensure sustainable biomass (wood pellets and wood chips)1
One of the major challenges for the Danish energy supply right now is to reduce levels of permanent
CO2 emissions into the atmosphere, thus contributing to keeping the temperature rise under
2 degrees Celsius, as well as addressing current dependence on fossil fuels.
The use of sustainable biomass to displace fossil fuels is an important tool in this context, as the
burning of fossil fuels creates permanent emissions of CO2 into the atmosphere, whereas
sustainable biomass creates only temporary emissions, which minimises the impact on the climate.
In order to ensure that a significant CO2 reduction is achieved, it is essential that only biomass
fractions that have a positive effect on the climate (in relation to the objective of 2 degrees) are
used.
As part of the Energy Policy Agreement of 2012, an analysis was prepared of the use of bioenergy in
Denmark. The analysis has identified whether the right conditions are present for efficient and
environmentally sustainable use of biomass resources in the Danish energy supply. The analysis
concluded that the conversion of combined heat and power (CHP) plants to wood pellets and wood
chips is good for the climate, when using sustainable biomass.
In this context, there exists no national legislation specifying requirements for sustainable biomass.
Nonetheless, by this agreement the Danish District Heating Association and the Danish Energy
Association wish to establish an industry-initiated voluntary framework for sustainable biomass, and
thereby support the significant and sustainable reductions in CO2 when compared to fossil fuels.
This framework agreement will help ensure that the use of solid biomass (chips and wood pellets)
for energy production in Denmark is compliant with the framework for sustainability in terms of the
environment, health and safety and climate, while it is CHP producers themselves that are
responsible and both document and satisfy the sustainability requirements through a third party.
The following points define the framework for the criteria that the industry agrees need to be met if
biomass is to be considered sustainable in accordance with this agreement.
Power plants covered
The requirements for sustainable biomass, as defined in this agreement shall cover all plants that
generate heat and electricity using biomass. To ensure that this does not entail disproportionately
high costs for smaller plants, only plants whose rated thermal input exceeds 20 MW,2 will be subject
to the documentation requirements.
1
The agreement to ensure sustainable biomass applies only to wood chips (comminuted wood) and wood
pellets (compressed wood shavings and sawdust)
2
Production units generating electricity and/or heat with rated thermal input of 20 MW or more. The above
thresholds refer in general to production capacity or production scale. If multiple activities that fall under the
same category are carried out at the same production unit, the capacities of such activities are added
together. When calculating a production units total nominal rated thermal input with a view to determining
whether it is subject to the documentation requirements outlined in the agreement, the nominal rated
thermal input of all the production units technical facilities that burn wood pellets and/or wood chips will be
44
The timeframe for the agreement

These documentation requirements will enter into force from 1 August 2016 (thus with effect for
purchases for the 2016-2017 heating season).3 The CHP plants affected shall commit to
demonstrating on an annual basis that the following proportions (by weight) of wood pellets and
wood chips comply with the requirements:
2016: 40 %
2017: 60 %
2018: 75 %
2019: Fully phased-in4
The Danish Energy Association and Danish District Heating Association also undertake to keep the
agreement up-to-date on an ongoing basis, with the possible adoption of common sustainability
requirements in the EU or globally, as well as to evaluate the industry agreement in 2018. This
evaluation shall include (inter alia) a discussion of whether the 20 MW requirement should be
phased out or reduced so that additional plants are covered by the documentation requirements of
the agreement.
Requirements for sustainable biomass
The following points outline the requirements and criteria that the industry aims to ensure and
document as being fulfilled before the use of biomass can be considered sustainable. The
requirements take their point of departure in the currently most ambitious legislation, which is UK
legislation on biomass sustainability
Timber Standard for Heat & Electricity: Woodfuel used under the Renewable Heat Incentive
and Renewables Obligation
The agreement also reflects the content of the Danish Ministry of the Environments Guidelines on
securing sustainable timber in public procurements of goods and services, and Forest Europes
criteria for sustainable forest management. The agreement is supplemented by criteria for CO2
savings compared to fossil alternatives which ensure that the biomass used contributes to a positive
effect on climate in terms of keeping the increase in temperature below 2 degrees.
1) Legality
Legality of forest management and utilisation is safeguarded through:
Logging from legally designated areas
Payment of all relevant taxes and duties related to the forest sector
Logging complies with applicable legislation governing the environment and forest areas
added together. Geographically dispersed production units that share common corporate affiliations (same
owner) count as a single production unit, and the calculation of rated thermal input is the sum of the rated
thermal input of the individual production units.
3
This means that annual reporting in 2016 will cover 40 % of wood pellets and wood chips purchased between
1 August 2016 and 31 December 2016. From 2017 this will be purchases between 1 January 2017 and
31 December 2017, etc.
4
The agreement shall be fully phased-in in 2019. This means that 90 % of wood pellets and wood chips used
will be documented as being sustainable in compliance with the requirements of the agreement. The
remaining 10 % must comply with the requirements of the agreement, but only document that the legality
requirement (point 1) is met.
The reason why it is not possible to fully document that 100 % of the fuel as sustainable is, for example, new or
small suppliers who have difficulties with (the resources for) integrating the documentation processes required
to verify all the requirements of the agreement. In addition, there may be biomass from storm damage, or the
like. When the agreement is evaluated in 2018, an assessment will be made as to whether the requirement of
90 % documentation can be further tightened.
45
Logging respects the rights acquired by prescription and the civil rights of indigenous people
Compliance with the trade and customs legislation governing the forest sector.
2) Protection of the forests ecosystems

Forest management must ensure the preservation of the fundamental conditions of the ecosystem
through:
Assessment of the environmental (e.g. water, soil) impact related to clearance of wood
Impact assessment of the influence of management on ecosystem and biodiversity
Scheme to minimise negative impact on ecosystems and biodiversity, including impact from
fertilisers, pesticides and waste disposal.
3) The forests productivity and ability to contribute to the global carbon cycle must be
maintained.
Management of forests must ensure the least negative impact on the forests productivity and
carbon sequestration through:
Maintaining the forest's ability to produce wood for future generations
Balancing logging and growth rates
Establishing a system for measuring the forest's productivity
Education and training of producers and subcontractors
Refraining from using wood from forests which are not replanted/rejuvenated
Refraining from converting land with forest status
Refraining from converting forests with high carbon content5
4) The forests must be healthy and well-functioning
Forest management must ensure healthy and well-functioning forests through:
Maintaining or increasing forest health and vitality
Management of natural processes, including forest fires, pests and diseases
Protection against illegal logging and mining operations
5) Protection of biodiversity, sensitive areas and areas worthy of preservation
Forest management must ensure protection of biodiversity, sensitive areas and areas worthy of
preservation through:
Identification of particularly vulnerable areas or areas which are particularly worthy of
preservation
Protection of designated areas through forest management with due consideration to
sensitive areas and areas worthy of preservation
Areas may have special value if they e.g. protect against soil erosion, protect water resources, have
high biodiversity, have special scenic values and/or comprise particularly valuable animal or plant
species.
6) Social and work-related rights must be respected
Forest management must safeguard respect for social and work-related rights by:
identifying, documenting and respecting original inhabitants with a traditional or legal forest
easement
establishing complaint mechanisms, if not already available, to resolve disagreements in
connection with identified forest easements and the working environment
In this context, forests with high carbon content are forests growing in wetland areas and in undrained peat
soil.
46
employees shall be entitled to organise themselves and child labour, forced labour or
discrimination are not permitted
the work must be organised and executed in such a way that the employees health and
safety are taken into due consideration.
7) CO2 emissions limits from biomass value chain

Biomass may only be used where CO2 emissions from the biomass value chain in question do not
exceed the applicable limits resulting from this agreement at any given time.
The limits are in place to ensure a significant CO2 reduction compared to the reference.
There is no Danish model for calculating actual CO2 emissions from the value chain and absolute
values from biomass cannot be determined at the current time. Work will therefore commence with
the aim of establishing absolute limits and methods of calculation. The calculation model will be
prepared on the industrys initiative by independent stakeholders on the basis of existing recognised
methods which will be adapted to Danish conditions, including CHP and heat generation. The work is
expected to be completed by the end of the first quarter of 2015, and will take as its starting point
the following criteria:
Reduction Percentage with reference to the EUs current applicable guidelines, combined
with the most ambitious of suitable European standards. The most ambitious standard in
Europe right now is from the UK, see the table below.
Reduction compared to the reference specified by the EU (fossil fuel comparator).
Involvement of the entire value chain for both biomass and fossil reference. It is assumed
that the value chain includes: operations that can be attributed specifically to the production
of the fuel (incl. planting, maintenance and felling), processing of the fuel, transport to endcustomers (energy producers) and utilisation rate at the power station.
2015
2020
2025
EU reduction
70 %
72 %
75 %
recommendation
(2015)
UK reduction
recommendation
(2020/2025)
Absolute limit
201 kg/MWh
187 kg/MWh
167 kg/MWh
1
(electricity)
Absolute limit (heat)
86 kg/MWh
81 kg/MWh
72 kg/MWh
Absolute limit (CHP)*
100 kg/MWh
94 kg/MWh
84 kg/MWh
1
EU fossil fuel comparator: 670 kg/MWh (electricity), 335 kg/MWh (CHP)*, 288 kg/MWh (heat). All based on
energy output.
Source: Commission staff working document: State of play on the sustainability of solid and gaseous biomass
used for electricity, heating and cooling in the EU (*own estimate based on total CHP efficiency of 85 %).
8) Additional requirements targeted at carbon cycle, maintenance of forest carbon stock, indirect
land use change (ILUC) and indirect wood use change (IWUC)
In addition to the biomass value chain, the use of biomass as a form of energy can have indirect
implications for global carbon balance. In May 2014 the Danish Energy Agency published an analysis
of the use of biomass for energy in Denmark: Analyse af bioenergi i Danmark (Analysis of bioenergy
in Denmark). The analysis highlights a number of biomass types, where the use of energy will have
varying effects on carbon balance, and therefore on the climate benefits that will be obtained by
using biomass to displace fossil fuels.
47
In order to ensure a climate-appropriate carbon balance, and on the basis of the conclusions of the
analysis, in addition to the actions mentioned in the seven points above, the industry aims to not use
biomass:
for which there is alternative demand in the region for high-value production (including the
production of timber)
which comes from trees that are grown on fertile soil that has been inappropriately
converted from agriculture to forestry
which causes deforestation in the region concerned
which negatively affects the quantity and quality of forest resources in the medium and long
term
If standardised methods are developed for documenting retention of forest carbon stock, IWUC
effects and ILUC effects, the industry must accept these methods before they can be incorporated
into the industry agreement as documentation requirements.
Compliance with requirements
Biomass sustainability must be documented through annual reporting on compliance with
requirements. The report must be either prepared or verified by a third party.6 For further details,
see Appendix 1.
Publication of compliance with requirements
The annual report shall be made available on the industry members websites. In addition, the
Danish Energy Association and the Danish District Heating Association will provide links to the
annual reports on their respective websites.
The costs associated with the annual reporting of the industry agreement shall be borne by the respective
company/CHP station relative to the fuel distribution for electricity and heat or other agreed formula in
heating agreements.
48
Appendix 1 Compliance with requirements

The purpose of a voluntary industry agreement is to encourage the industrys members and
branches to adopt a particular behaviour (the purchase of sustainable biomass), but also to give
members the freedom to decide what means are necessary to comply with the agreements
sustainability requirements. In this context, it is essential that the means that the industrys
members decide to employ are also sufficient guarantees to substantiate that wood pellets and
wood chips are sustainable.
Requirements 1-6 Sustainable forestry
By way of documentation of requirements 1-6, the certification system developed by Sustainable
Biomass Partnership can be used. The Sustainable Biomass Partnership certification system is a
certification of the production and purchase of wood pellets and wood chips. The certification
scheme is the result of a collaboration between a number of energy companies including DONG
Energy, Vattenfall and E.ON. Certification schemes, which are widely used world-wide and are
recognised as documentation of sustainability by the Danish Nature Agency may also be used.
Currently, only the FSC and the PEFC are recognised. The FSC and the PEFC set standards for forest
management, tracking and labelling, which means that timber sold to end users that is certified as
traceable under one of these schemes will be deemed to satisfy requirements 1-6.
Requirements 1-6 of the agreement may also be met by an appropriate form of documentation
other than certification. Appropriate and sufficient evidence that a forest is managed in accordance
with the industry agreements sustainability criteria would in such cases have to be audited annually
by an independent third party. Rules concerning third parties are outlined in the section Third-party
verification. Other forms of documentation (other than certification) are also required for previously
certified timber that has passed through one or more non-certified stages before reaching the enduser (the CHP station). In such instances, the documentation may then be limited to tracking from
the last valid certification stage to delivery of the contracted wood pellets or wood chips.
Requirement 7 Emission of CO2 in the value chain
The requirements for CO2 emissions in the value chain are calculated both as an absolute limit and
as a percentage in comparison with a fossil reference. The requirements ensure a significant CO2
reduction compared to the reference.7 When determining the limits of the industry agreement, EU
recommendations and the tightest regulation in the area (currently the UK) will be taken into
consideration. The values are thus in line with the recommendations of the European Commission
on solid biomass of 28 July 2014: State of play on the sustainability [of] solid and gaseous biomass
used for electricity, heating and cooling in the EU.
The emission is calculated as an annual average of delivered biomass using the calculation model
and the phasing-in route. The annual report must indicate how the used biomass (wood chips, wood
pellets) deliver absolute CO2 reductions and how the biomass performs compared to a fossil
reference fixed by the EU (fossil fuel comparator). The requirements for emissions will be tightened
up to 2020 in line with expected increased imports of wood pellets and wood chips.
It is assumed that the value chain will include: operations that can be attributed specifically to the
production of the fuel (incl. planting, maintenance and felling), processing of the fuel, transport to
end-customers (energy producers) and the utilisation rate at the power station.
EU fossil fuel comparator: 670 kg/MWh (electricity), 335 kg/MWh (CHP)*, 288 kg/MWh (heat). All based on
energy output. (*own estimate based on total CHP efficiency of 85 %).
49
Requirement 8 Satisfying requirements targeted at the carbon cycle, maintenance of forest carbon
stock, ILUC and IWUC
There are currently not the same methods for calculating the additional requirements as there are
for requirements 1-7. The industry will therefore (in collaboration with authorities and other key
stakeholders) work to develop methods to document and formulate more detailed criteria for the
three points under the heading: further requirements targeted at the carbon cycle, maintenance of
forest carbon stock, ILUC and IWUC.
Third-party verification
Fulfilment of requirements 1-7 must be documented through annual reporting. The report must be
either prepared or verified by an independent third party that is accredited to conduct either FSC or
PEFC forest certification, SBP certification or by an organisation that is EU-approved as an EUTR
monitoring organisation8. The report must be available on the websites of the plants/companies
concerned and is thus freely available to the public. The report is not subject to control by the
authorities.
http://ec.europa.eu/environment/forests/timber_regulation.htm
50
Energistyrelsen (Danish Energy Agency)

8 June 2010
File No. 2104/1164-0004
Ref. joj
Energy supply
MEMORANDUM
Summary of comments on the basis for the Danish action plan for renewable energy
In connection with the preparation of the Danish action plan for renewable energy, which is to be
sent to the Commission by 30 June 2010, the Danish Energy Agency held a meeting on 26 April 2010
with relevant stakeholders from, among others, industry and interest organisations about the basis
for the Danish action plan.
At the meeting, the Danish Energy Agency explained the new baseline projection on which the
figures reported in the action plan will be based. According to the projection, the share of renewable
energy in gross final energy consumption is expected to rise from 17.0 % in 2005 to 28.3 % in 2020.
With the energy policy initiatives already implemented, Denmark is therefore around 1.7 percentage
points short of the overall target of 30 % renewable energy in 2020 to which Denmark has
committed itself.
In the projection, the share of renewable energy in the transport sector is estimated to rise from
1.0 % in 2010 to 6.0 % in 2020. There is therefore around a 4 percentage point shortfall in the
fulfilment of the transport sectors target of 10 % renewable energy.
At the meeting, the Danish Energy Agency also presented ideas about how the action plan could set
out how Denmark intends to meet its renewable energy obligations up to an including 2020,
including which technologies and measures could be highlighted.
Subsequently, the Danish Energy Agency has received 21 written commentaries on the basis for the
Danish action plan for renewable energy. These are attached as annexes. The main points of the oral
and written comments are outlined below. The contributions are included in the Danish Energy
Agencys continued work on the Danish action plan.
1. Process and involvement

A number of parties have complained about the process of drawing up the action plan. They want to
have a proper consultation about the action plan and thus a broader public information phase
concerning the work. Several parties also point out that it is difficult to comment on the basis for the
action plan when a draft action plan has not been released and owing to the short time allowed for
submitting written comments.
The criticism comes from WWF, Greenpeace, OVE (the Danish Organisation for Renewable Energy),
Det kologiske Rd (the Danish Ecological Council), FRI (the Danish Association of Consulting
Engineers), Landbrug & Fdevarer (the Danish Agriculture & Food Council), Mellemfolkeligt Samvirke
(ActionAid Denmark), 92-gruppen (the Danish 92 Group), Danmarks Naturfredningsforening (the
Danish Society for Nature Conservation) and Dansk Energi (the Danish Energy Association). INFORSEEurope is also calling for experts and NGOs to be involved in the preparation and subsequent follow51
ups to the action plan. OVE does not believe that the process satisfies the intentions of the RE
Directive as regards publicity about the action plan.
LGDK (Local Government Denmark) points out that the RE Directive states that local and regional
authorities should be involved in the development of the national RE action plans. According to
LGDK, this has not happened to the extent required by the Directive. A meeting was subsequently
held with LGDK concerning the sections of the action plan that relate to local/municipal matters.
Vindmlleindustrien (the Danish Wind Industry Association) and Danmarks Vindmlleforening (the
Danish Wind Turbine Owners Association) have requested a meeting with the Danish Energy Agency
to further discuss the basis for the action plan. A meeting has also been scheduled with the Danish
92 Group.
2. Fulfilment of other objectives and exceeding the RE target
A number of stakeholders, WWF, the Danish Energy Association, the Danish Ecological Council, the
Danish Wind Industry Association, NOAH (Friends of the Earth), OVE and Greenpeace, believe that
the action plan should reflect the fact that the expansion of renewable energy is necessary to fulfil a
number of Denmarks other objectives and obligations. This applies in particular to the
Governments vision of Denmark being independent of fossil fuels and Denmarks obligations
regarding the reduction of greenhouse gases.
Greenpeace, OVE and the Danish Ecological Council point out that the EUs target of a 20 %
reduction in greenhouse gases could be raised to 30 %. It should be even higher to achieve the
2 degree objective and the target of reducing emissions by around 90 % in 2050. Greenpeace does
not believe that the Government has presented a plan on how to achieve the reduction targets and
is calling for a plan to be drawn up that ensures at least a 40 % reduction in domestic greenhouse
gases in 2020.
The expansion of renewable energy could also strengthen Danish innovation, competitiveness and
exports (WWF and the Danish Ecological Council) and help to support Denmarks leading position in
green energy and climate technologies (the Danish Wind Industry Association).
There is therefore reason for an ambitious approach in relation to renewable energy. Several
stakeholders, including the Danish Ecological Council, WWF, OVE, INFORSE-Europe, Greenpeace and
the Danish Wind Industry Association, point out that Denmark could and should exceed the RE
target. It is proposed that the Danish action plan should aim at an overall RE share of at least 35 % in
2020 and 50 % wind power in electricity generation in 2020. OVE is proposing an ambitious target of
at least 37 % renewable energy in 2020.
3. Long-term plan for conversion of the energy system
Several parties mention that there is a need for a large-scale conversion of the energy system, which
requires carefully thought-out, specific, long-term energy policy plans as well as immediate action
(Greenpeace, the Danish Ecological Council, WWF). According to the Danish Ecological Council,
decisions, planning and investment cannot wait until 2015, as the Minister has proposed. On the
contrary, an active and progressive Danish energy policy will be of benefit for Denmarks security of
supply, innovation, competitiveness and job creation.
Studies and energy plans prepared by, among others, Greenpeace, Teknologirdet (the Danish Board
of Technology), IDA (the Danish Society of Engineers), Ea Energianalyse (Ea Energy Analyses), OVE
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and FRI, show that there is need for a rapid conversion of the energy system, energy savings and
phasing-in of more renewable energy (Greenpeace, WWF, OVE, the Danish Ecological Council, FRI).
According to the Danish Energy Association, there will not only be need of a different technology
mix, but also changes in production, and there is therefore an increased need for expanding
networks and ensuring that energy is available for society at times when there is a need for it.
It is mentioned by, among others, FRI that there is a need for joined-up solutions across sectors and
coordination between administrative units, and there is also a need for energy planning in the form
of national plans with associated regional and municipal plans.
LGDK is similarly calling on the Government to incorporate the municipalities in the action plan as a
resource in relation to achieving the national RE goals and points to the paper on strategic energy
plans, which was the result of a collaboration between LGDK and the Danish Energy Agency.
Strategic energy plans can be used to think long-term and holistically, which is expected to give a
large economic benefit.
4. The baseline projection as the basis for the action plan
Several of the commentaries point out that the Danish Energy Agencys baseline projection is not an
appropriate basis for the RE action plan (WWF, the Danish Ecological Council, TEKNIQ, Greenpeace).
This is due to, among other things, the fact that the projections only focus on the period up to 2020,
and only very narrowly on the fulfilment of targets applicable to that period. This short-term focus
means that it is not possible to see whether the current measures are sufficiently ambitious to meet
the long-term goals of fossil independence etc.
The action plan is criticised for not being an action plan in the true meaning of the term, if it is
largely based on the baseline projection. Greenpeace notes that the baseline projection is not
appropriate as a basis for the action plan, because it simply shows how far the market, on the basis
of the decisions taken, will take Denmark relative to the objectives. According to Greenpeace, that
has nothing to do with an action plan. WWF considers that the projection is inappropriately shortterm and unrealistic in relation to the economic challenge and that the Danish action plan is
therefore a technical progress report and projection, rather than an actual action plan. Both
organisations believe that the term action plan refers to a description of objectives and necessary
means. An action plan must therefore necessarily include policy statements (Greenpeace, WWF).
The Danish Energy Association also argues that an RE action plan should help create a road map to
the objective which is centred around access to sustainable, secure energy under the best conditions
for costs, economic development and prosperity.
According to the Danish Wind Industry Association, the selection of an approach in which the action
plan is based on the baseline projection means that, in a large number of areas, no political decision
has been made on what technologies the Danish energy sector and the Danish authorities should be
planning for over the next 10 years. Several parties also express a need for clear policy signals and
initiatives as well as a stable framework for the expansion of renewable energy (the Danish Energy
Association, the Danish Wind Turbine Owners Association).
The Danish 92 Group, NOAH and Greenpeace criticise the fact that the action plan places too much
emphasis on biomass relative to other technologies (e.g. wind, solar and ambient heat), because the
baseline projection shows that, under the given conditions, this is the area in which the largest RE
expansion can be expected.
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TEKNIQ also points out that the technologies emphasised in the RE Directive, including solar thermal,
wood pellet boilers, solar cells and heat pumps, are largely left out of the baseline projection.
According to TEKNIQ, the price of solar cells and domestic wind turbines is falling considerably at
present and investment in them must therefore be expected to be profitable within a very short
time.
The Danish Ecological Council believes that it is wrong for the Danish Energy Agency, on the basis of
the baseline projection, to think that RE expansion is going well and that not much needs to be done
to achieve targets. INFORSE -Europe recommends that countries that do not expect to achieve the
RE targets with current means should decide on new measures. NOAH believes that it is wrong to
allow the action plan to be based on something that does not set the stage for more initiatives, and
finds it hard to see the paper as a serious proposal on how Denmarks RE obligations should be
fulfilled. Instead, NOAH hopes that, later, Denmark will make use of the opportunity to adjust the
fuel mix and the means that are set out in the action plan.
OVE points out that basing the action plan on the baseline projection means that the current
measures are expected to work. There is not, for example, an adequate risk assessment in relation
to whether the energy savings set as targets will be achieved.
More scenarios are needed, including with regard to the economy under the various solutions (DI,
the Confederation of Danish Industry).
A number of parties express the opinion that it is important to be aware of the considerable
uncertainty there is in the baseline projection. There is great uncertainty in particular about the
anticipated fuel prices, biomass price and CO2 quota price as well as the assumptions regarding
economic development (the Danish Wind Industry Association, the Danish Energy Association,
Greenpeace, WWF, the Danish Ecological Council). WWF is surprised that the biomass price is
assumed to be stable, since it can be expected that the price of wood pellets will rise as a result of
the pressure on resources that RE expansion in the EU will bring about. On the other hand, it is
doubtful that the quota price will rise to 35 in 2020, as assumed in the baseline projection. WWF
points out in this regard that, in its analysis of the scope for the EU to go further than the 20 % CO2
reduction in 2020, the Climate Directorate expects a quota price of 16 in 2020 if the EU does not
raise the climate target to 30 %.
According to Skov & Landskab (Forest & Landscape Denmark), the combustion calculation included
in the baseline projection is uncertain, and there is need for an improved statistic.
The Danish Ecological Council and WWF find it problematic that the baseline projection uses
external data too uncritically and without adequate uncertainty assessments.
The Danish Wind Industry Association points out that, owing to the large uncertainties, it is unlikely
that investors will act in the way described in the projection. Greenpeace points out that you cannot
simply rely on the market to provide the necessary RE expansion, especially not if this is based on
unrealistic fuel prices. According to NOAH, the focus at present is concentrated too much on
economic conditions.
5. The RE Directives cooperation mechanisms
OVE and INFORSE-Europe consider that Denmark should fulfil the RE targets using domestic means
and thus without the use of the RE Directives cooperation mechanisms.
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The Danish Energy Association and DI believe the cooperation mechanisms could be used to achieve
a more cost-effective utilisation of the RE resources of individual Member States, but are also calling
for them to be used to ensure greater harmonisation of RE support. This may mean that it is easier
for market players to operate in foreign markets, but may also ensure that Member States do not
work against each other and that competition between countries for RE projects is avoided. DI is
calling on Denmark to work for a testing of the RE Directives cooperation mechanisms and
coordination of support systems by entering into bilateral research cooperation with the Nordic
countries.
INFORSE-Europe supports the call for Member States to exchange experience with support schemes,
but is calling for national support to be kept within national borders.
6. Energy savings and efficiencies
A number of stakeholders point out that energy savings are a decisive and effective focus area in the
fulfilment of the RE target, and that this should be emphasised in the action plan. This is mentioned
by, among others, the Danish Energy Association, DI, Greenpeace, WWF, OVE, TEKNIQ, NOAH and
Dansk Fjernvarme (the Danish District Heating Association).
To illustrate this, Greenpeace has calculated that the 1.7 percentage point shortfall in the fulfilment
of the overall target in 2020 can be made up either by expanding RE by an additional 12 PJ or by
lowering energy consumption by 40 PJ.
NOAH is critical of the fact that the basis for the action plan does not assume any form of change in
behaviour which could reduce total energy consumption and thus reduce the need to provide
renewable energy. NOAH also finds it problematic that no new policy measures are being introduced
to seriously reduce energy consumption, and that growth in energy consumption is still being
encouraged in the transport sector.
OVE notes that there is a need for greater focus on energy savings, because it is uncertain that the
savings targets will be reached, and that this is crucial in order to reduce CO2 emissions. It points out
that the energy labelling scheme for buildings has not worked, inspection schemes have not started,
there is a lack of supervision of compliance with building regulations, etc. OVE recommends that
measures be introduced to realise energy savings and ensure CO2 reductions.
According to the Danish District Heating Association, there is, in particular, a need for an effective
savings effort in the areas, and for the forms of heating, where the greatest savings in fossil fuels can
be achieved (individual oil or gas heating).
According to DI, it is not appropriate to have absolute targets for reductions, but, instead, tools to
promote efficiency, such as, for example, the energy companies efforts.
FRI mentions a number of proposals for savings measures in buildings, including information,
government grants for socially beneficial energy renovation, scrapping premiums for the demolition
of old high-energy buildings, requirements for holistic planning of energy renovations, and the
possibility for landlords to transfer costs to tenants, provided that, overall, this is financially neutral
or beneficial for the tenant.
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7. Fulfilment of the transport target

Several organisations, including Greenpeace, WWF and OVE, point out that, to the greatest possible
extent, the transport target should be achieved through increased use of electric vehicles, because,
among other reasons, electric vehicles use the input energy more efficiently and can benefit the
electricity system through intelligent solutions.
According to LGDK, WWF and FRI, there should be a focus on how public transport can be converted
to renewable energy. WWF recommends the establishment of a payment ring around Copenhagen
to help switch commuters from their cars to the S-train and thus increase the RE share. LGDK is also
calling for coordination with the municipalities in connection with the promotion of electric vehicles
and points to the Danish Energy Agencys working group on charging points. INFORSE-Europe
proposes that renewable energy used in electric trains should be counted with a weighting of 2.5 in
the transport target in the same way as electric vehicles, which is not otherwise included in the RE
Directive.
FRI mentions a number of proposed initiatives relating to transport: the creation of an incentive
structure that promotes the use of public transport, that the infrastructure be coordinated to
achieve the optimal conditions for short transport times, public transport and CO2 reduction, and
the introduction of high-speed trains, etc.
A number of organisations are concerned about the indirect consequences and sustainability
problems that the fulfilment of the targets in the RE Directive could entail. OVE points out that the
EUs sustainability requirements must be implemented in Danish rules in an effective way and, if
necessary, Denmark must go further than the EU rules. INFORSE-Europe believes that the
implementation of the RE Directive risks undermining sustainable development if sustainability is
not incorporated in the framework for the fulfilment of the RE targets.
Greenpeace proposes that Denmark should either drop the fulfilment of the transport target or fulfil
it insofar as possible through a massive initiative for electric vehicles. This is due to the sustainability
problems associated with the production and use of biofuels, and also to the fact that biomass used
for the production of biofuels could and should be used more efficiently for other purposes (e.g.
substitution of coal in CHP plants or ploughing-in of straw). Greenpeace believes that biofuels should
also not be used as a temporary solution in the area of transport.
NOAH agrees that the use of biofuels in the transport sector is absolutely undesirable and that other
options should be used instead. The recommendation not to use biofuels is based on, among other
things, the fact that the production of biofuels has displacement effects and produces greenhouse
gas effects that are not included in the CO2 account. Increased use of biomass does not reduce
emissions, but risks increasing them.
ActionAid Denmark believes that, as an absolute minimum, Denmark should freeze and not further
increase the current target for biofuels while further studies are conducted on the sustainability and
indirect consequences of the various forms of biofuel. This applies to both first and second
generation biofuels. ActionAid Denmark is concerned about the indirect social consequences of the
increased use of biofuels, which today are primarily produced from foodstuffs. They point out that
the World Bank, the OECD and the UN consider that the production of biofuels is vastly inflating
food prices, which is contributing to the food crisis in the worlds poorest countries. Studies have
shown that production of biomass for biofuels displaces local food production. This uses up land and
water resources and local farmers are losing their land. According to ActionAid Denmark, Denmarks
targets in this area will exacerbate the problem and counter efforts to support local food security.
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ActionAid Denmark is calling for a decision on Denmarks biofuel target to wait for the Commissions
studies on ILUC (indirect land-use change) and on the consequences for food security. If it is found
that it cannot be done in a sustainable way, ActionAid Denmark will argue for a massive reduction in
the existing biofuel target. According to ActionAid Denmark, Denmark should also not embrace new
forms of biofuel (second generation biofuels) uncritically. There is a need for life-cycle analyses of
each type.
The Danish Society for Nature Conservation and NOAH support ActionAid Denmarks comments.
Others point out that electric vehicles are good, but that they can only be expected to make a
modest RE contribution, so it is necessary to involve other forms of renewable energy to achieve the
transport target (the Danish Agriculture & Food Council, the Danish Energy Association). INFORSEEurope has calculated that, based on the EUs RE average, 41 % of vehicles would have to be electric
to achieve the 10 % target.
DI believes that increased use of first and second generation biofuels will play a key role in the
fulfilment of the transport target. WWF and INFORSE-Europe point out that biofuels can be used,
but only with strict requirements concerning the sustainability of production.
According to the Danish Agriculture & Food Council, efforts to meet the transport target should be
made using second generation biofuels. According to the organisation, this requires a bringing
forward of the current blending requirement, the political will for which was expressed in Grn
Vkst 2.0 (Green Growth 2.0). There has been major development in this area, the available straw
resources can be used for the purpose, and it is therefore recommended and considered technically
feasible to meet the transport target using Danish-produced second generation biofuels in 2020
The Danish Energy Association proposes that extensive use should be made of second generation
biofuels, but also suggests that there is the opportunity to use biogas and biodiesel in the heavier
side of transport.
OVE and INFORSE-Europe propose that hydrogen should also be included in the fulfilment of the
transport target.
Taxes are mentioned as a possible way to influence energy consumption in the transport sector. The
Danish Energy Association mentions green vehicle taxes, possibly at European level, as an
appropriate tool, as it would put pressure on producers to come up with new technologies.
DI is working for the conversion of the current value-based registration tax into an annual CO2 tax
and points out that it is inappropriate that second generation biofuels are currently taxed more
heavily than conventional fuels.
8. RE expansion
General
Seen overall, several parties emphasise that Denmarks future RE expansion should focus on using
domestic RE resources and promoting small technologies to make Denmark self-sufficient (the
Danish Agriculture & Food Council, TEKNIQ, Greenpeace, INFORSE-Europe). TEKNIQ emphasises the
use of wind, solar cells, waste-based district heating and biogas in the natural gas network.
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Greenpeace also states that the electricity market should be set up in such a way that environmental
and health externalities are also taken into account in the use of fossil fuels.
According to the Danish District Heating Association, it is important that the fuels and technologies
that are focused on should contribute to an overall flexible energy system, so that the electricity and
heating systems complement each other.
LGDK recommends that the action plan should take into account the results of the cooperation
between LGDK and By- og Landskabsstyrelsen (the City and Landscape Agency) concerning the
location of wind farms and biogas plants.
The expansion must also be cost-effective, and there must be benefits for the economy and for
corporate and consumer finances in the chosen solutions (the Danish District Heating Association.
the Danish Wind Industry Association and DI). If the national approach is combined with common
European harmonisation, it will be possible, according to the Danish Energy Association, to ensure a
cost-effective approach and remove market barriers.
According to DI, the focus should be on improving the conditions for energy-intensive businesses to
produce their own renewable energy. Draft law L154 reduces this because you can no longer
simultaneously obtain a price premium and net settlement (reduced PSO).
The Danish Society for Nature Conservation broadly supports WWFs and ActionAid Denmarks
comments on the basis for the action plan.
Wind
According to the Danish Wind Turbine Owners Association and the Danish Wind Industry
Association, wind power can make up the 1.7 percentage point shortfall which, according to the
baseline projection, exists relative to fulfilling Denmarks overall RE target. The Danish Wind Turbine
Owners Association and the Danish Wind Industry Association believe that work should be done
towards Denmark basing at least 50 % of its electricity consumption on wind power in 2020, and
point out that the Danish Wind Turbine Owners Association and the Danish Wind Industry
Association have presented a development plan Den rigtige vindkraftudbygning (Correct wind
power development) showing that wind power could account for at least 50 % of total electricity
generation in 2020.
WWF, OVE and Greenpeace believe that wind power capacity offshore and onshore should at least
double between 2010 and 2020. The Danish Wind Industry Association notes that the action plan
should be based on robust, known technologies like wind power.
The Danish Wind Turbine Owners Association and the Danish Wind Industry Association point out
that the expansion of onshore wind is likely to be greater than indicated in the baseline projection.
According to the baseline projection, total wind capacity will decline over the period owing to
planning considerations, but previous calculations have shown that the potential for wind is far
greater. The Danish Wind Turbine Owners Association does not believe there is evidence for the
alleged planning constraint for wind development referred to in the baseline projection, and,
according to the Association, it would be unfortunate if the Danish Energy Agencys projection came
to be seen as an announcement of very low targets based on an unfounded planning constraint.
The Danish Wind Turbine Owners Association considers that, with the current support measures, at
least twice the expansion of onshore wind assumed in the baseline projection can be achieved. The
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Association points out, among other things, that Energinet.dk has disclosed that new onshore wind
turbine projects corresponding to a capacity of 250 MW have been approved under the new
devaluation scheme so far i.e. in the around 16 months that the RE Act has been in force. The
baseline projection assumes annual expansion of 25 MW per year in the period 2010-15.
The Danish Energy Association also expects wind to make up a larger share than outlined in the
projection because onshore capacity should at least be maintained and continued expansion of
offshore wind is likely after the establishment of the Anholt offshore wind farm.
The Danish Wind Turbine Owners Association believes that there is now a positive attitude towards
the expansion of onshore wind. There was previously a bad atmosphere and lack of ownership
among municipalities, as well as insufficient involvement of local citizens, owing to hasty decisions
taken before the county councils were closed down. Today wind is included to a large extent in the
planning of the municipalities. The Association is warning against sending policy signals through the
action plan that create uncertainty about the planning that is already underway in the municipalities.
The Danish Wind Industry Association points out that a number of reports and analyses from
universities, Energinet.dk, independent consultants, think tanks and stakeholder organisations are
agreed that the future energy system in Denmark should prioritise and plan for the long term,
including ensuring that large amounts of wind power can be integrated into the energy system.
The Danish Energy Association and the Danish Wind Industry Association are calling for policy
decisions to be taken that can reduce the uncertainty about long-term investments in wind farms.
The largest barrier to the erection of wind turbines, according to the Danish Energy Association is
the uncertainty surrounding this type of project owing to the financial crisis and uncertainty about
costs etc.
The Danish Wind Industry Association is also calling for the Danish Energy Agency to be aware of the
planning barriers in relation to wind expansion. There are examples of it taking 2 to 3 years to obtain
the necessary building permits and grid connections for onshore wind turbines, and offshore the
overall time horizon, including the construction phase, is longer.
LGDK points out that the municipalities have planning competence in relation to the location of wind
turbines and that there are some clear constraints.
FRI comments that the wind technology should be developed in order to be able to utilise the
variability of wind with the aid of CHP plants with electric boilers, heat pumps and large heat stores.
Biomass
Several parties point out in their comments that biomass is a scarce resource which must be utilised
in the best possible way.
Greenpeace emphasises that it is necessary to have clear criteria for sustainable biomass and that
with the general expansion of renewable energy in the EU there could well be a risk that the rise in
demand will lead to unsustainable pressure on a scarce resource. However, Greenpeace is of the
opinion that, in the EU, it is possible to achieve the necessary climate targets without using
unsustainable biomass.
According to the Danish Energy Association, the baseline projection shows such large growth in the
use of biomass that there is need for a long-term credible strategy for the use of biomass that
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provides certainty for the investments to be made by agriculture and the energy sector. Forest &
Landscape Denmark agrees that there is a need for planning.
The Danish District Heating Association is also calling for the limited biomass resources to be used
with care in order to ensure that local solutions do not lead to a national increase in, for example,
coal condensation operations.
According to Forest & Landscape Denmark, there is a need for national initiatives to strengthen
production of biomass. Forest & Landscape Denmark believes there is a need for research into and
development of additional production of energy wood in forestry and wood outside of forests etc.
DI and the Danish Agriculture & Food Council note that Denmark has potential for increased
production of biomass for bioenergy without impacting on production of food and animal feed.
According to DI, the production of biomass for bioenergy in agriculture could be increased by 4-5
times through greater use of straw in CHP plants, slurry for biogas and animal fat for biodiesel as
well as through the use of multi-annual energy crops and grass from low-lying areas. According to DI,
it is essential that bioenergy, as the only renewable energy source, can be regulated.
The Danish Agriculture & Food Council expects that wood pellets and wood chips, which today are
primarily imported from the Baltic States and Canada, will rise in price. The organisation believes
that, insofar as possible, the RE target should be met using Danish-produced resources, because it
was found in 2010 that supplies from eastern European partners can be unstable. The Danish
Agriculture & Food Council sees a large potential for using biomass and biogas in place of coal and
gas in the district heating sector. They propose that local CHP plants that currently use natural gas
could be connected to biogas plants if a framework can be created for the production of biogas.
The Danish Technological Institute and the Danish Agriculture & Food Council point out that large
amounts of straw still lie unused in the fields.
FRI suggests that technology should be developed for the optimal utilisation of biogas from
agriculture in the form of gas, foodstuffs and fertiliser, and that biomass boilers should be developed
for the utilisation of straw.
NOAH considers that there is too much emphasis on biomass in the baseline projection and the
action plan. NOAH does not believe that biomass should be characterised as a renewable energy
source and therefore that biomass should also not be used to meet RE targets. The organisation
believes that new evidence keeps emerging that the use of biomass does more harm than good from
a climate perspective. It does not reduce greenhouse gas emissions, but instead risks increasing
them because it releases more carbon than it binds. According to NOAH, the emissions caused by
agricultural production itself are underestimated. This applies to emissions from cultivated areas,
from direct changes in land use (where the production of biomass is extended to previously
uncultivated areas) and from indirect changes in land use (where the production displaces other
production to previously uncultivated areas). In addition, there are the emissions from the
production of artificial fertiliser and chemicals, agricultural machinery, etc.
NOAH points out that, according to the Danish Energy Agencys calculations, biomass already
accounts for 2/3 of the renewable energy used in Denmark (2008), and that, under the approach
proposed in the action plan, the use of biomass will be increased by a total of around 66 PJ (80 %).
NOAH considers it problematic that biomass would be imported and points to calculations by the
Danish Energy Agency showing that 87 % of the wood pellets used are already imported today.
According to NOAH, there is no evidence that it will be possible globally to produce the biomass that
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is demanded, and, moreover, the countries from which it is imported need it themselves to phase
out the use of coal.
NOAH does not consider that the certification of biofuels or biomass can solve the problems with the
use of biomass on such a large scale for energy purposes, and also finds it problematic that, under
the RE Directive, biofuels are subject to sustainability criteria, while that is not the case for solid and
gaseous biomass.
NOAH is also opposed to the use of biogas, because it is not sustainable in the long term to have
agricultural production that is based on imported feed.
OVE, INFORSE-Europe, the Danish Energy Association and Forest & Landscape Denmark also state
that only sustainable biomass should be used. INFORSE-Europe states that sustainability
requirements could also be set up for imported biomass.
According to the Danish Energy Association, it is important that the markets for biomass function
optimally so that the biomass resources are available on equal terms. It is important to have a
global, or, failing that, an EU sustainability regime, which is necessary to ensure legitimacy for the
use of biomass.
OVE and INFORSE-Europe recommend that the biodegradable part of waste should be investigated
further so that it is not overestimated.
FRI recommends that waste-fired power stations should be optimised to handle waste from future
production based on the cradle-to-cradle principle.
DI believes that Denmark is interpreting the Waste Incineration Directive too restrictively, which
means that biomass is being incinerated rather than being used as fuel in power plants.
With regard to questions concerning consequences for other sectors that should be answered in the
action plan (section 4.6.2(a)), the Danish Agriculture & Food Council suggests that it be added that
an increased use of straw in energy supplies will affect agricultural production owing to the
increased demand. This could mean higher prices and thus increased costs for any livestock
producers that use straw. On the forest side, there is the possibility that rising chip prices could
mean that an increasing proportion of timber is used for energy instead of being used in
construction, furniture production, etc. The increased consumption may be of benefit to forestry.
In section 4.6.2(b) concerning expected developments in other sectors which may affect the energy
sector, the Danish Agriculture & Food Council suggests that the importance of new home insulation
requirements that will reduce the need for district heating should be mentioned. This may cause a
decline in the need for biomass for pure heat production because the district heating networks of
large towns receive surplus heat from other businesses which for much of the year will be able to
supply enough heat without using biomass specifically for heat production.
Geothermal energy
The Danish District Heating Association and Greenpeace consider that geothermal energy should be
promoted in heating systems, and, according to WWF and OVE, the expansion of geothermal heating
should be strengthened with a target of at least 5 PJ of geothermal energy in 2020.
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The Danish Agriculture & Food Council mentions that biomass heating could be combined with
geothermal energy so that the biomass ensures the correct temperature in the district heating pipes.
Solar energy
When the baseline projection shows that with the frozen policy (i.e. based on the energy policy
measures that have been implemented today) there is not expected to be any strong growth in solar
energy up to 2020, there is, according to Dansk Solvarme Forening (DSF, the Danish solar heating
association), a need for policy initiatives in this area if solar heating is to play a larger role in Danish
energy policy. According to DSF, solar thermal, through both district heating and individual heating,
will be able to make a significant contribution to making up the shortfall which, according to the
baseline projection, exists in meeting the overall RE target in 2020. DSF points to a number of other
stakeholders who believe that solar thermal is a good investment for Denmark and should be much
more widespread.
According to DSF, solar thermal is one of the cleanest and most dependable renewable energy
sources and, at the same time, it is cost-effective and a guarantee of security of supply without the
use of imported fossil fuels. Solar thermal creates local jobs in Denmark and promotes the industry
that already exists in this area in Denmark.
The Danish District Heating Association and FRI believe that solar thermal should be promoted in
heating systems. WWF and Greenpeace also believe that the development of solar thermal should
be strengthened through, for example, the introduction of a solar heating obligation for home
owners outside of district heating areas. According to OVE, the development of solar thermal should
be strengthened, both in individual buildings and in district heating, with a target of 4 million square
metres of solar panels in 2020.
DSF has calculated a market development scenario for solar thermal systems on individual homes
and large solar thermal plants. According to this, given the right measures, 200 000 home systems
and 225 large systems could be sold between 2011 and 2020. According to the calculation, this
would amount to 1 % of Denmarks gross final energy consumption in 2020, displace 0.8 million
tonnes of CO2 and create 2 500 local jobs. The outlined development requires new initiatives to
promote solar heating.
DSF suggests that the typical barriers to the spread of solar heating (large initial investments and
lack of knowledge among the population about solar heating) should be overcome with the aid of a
grant scheme covering 50 % of the systems value and campaign funds (DKK 30-40 million) for
information, training and labelling. For the large systems, requirements could be imposed
concerning increased use of solar thermal in the supply of district heating. Access to capital could be
ensured through state-guaranteed loans at favourable interest rates, supplemented by tougher
energy saving requirements and 10-20 % investment grants. For the large plants there is also,
according to DSF, a need to deal with tax issues and discrimination in economic calculations.
OVE suggests that the expansion of solar photovoltaic should be strengthened through state
subsidies to kick-start development.
Wave energy
According to Blgekraftforeningen (the Danish Wave Energy Association), wave energy is unlikely to
make a significant contribution to the expansion of renewable energy before 2020, but it should be
stated in the action plan that there is a considerable and realistic potential for wave energy after
62
2020, corresponding to up to 30 % of Denmarks electricity consumption. The technologies exist, but

there is a need for political initiatives, e.g. in the form of support for the industrialisation of wave
energy.
FRI suggests that wave energy should be combined with large wind farms so that the technologies
can share physical foundations.
Heat pumps
According to Varmepumpefabrikantforeningen (the Danish Heat Pump Association), heat pumps,
combined with an increased use of wind energy, could easily contribute to covering the entire
shortfall shown in the baseline projection for the fulfilment of both the RE target and the CO2
reduction target for 2020. Please see the Danish Energy Agencys technical background report of
2005, which shows that in many situations heat pumps are the best option both for the economy
and for the finances of private individuals. As the share of RE increases, the electricity consumption
for heat pumps will not burden the economy or the environment. Heat pumps can help stretch
energy resources, reduce fossil fuel consumption, increase security of supply and help reduce the
problem of excess electricity from wind turbines. Like the Danish Wind Industry Association, the
Danish Heat Pump Association reports that it does not expect delivery problems and that increased
use of heat pumps combined with the large expansion in wind power will not give rise to a need to
import fuel.
WWF also points out that the expansion of heat pumps should be strengthened and targeted with a
view to equipping heat pumps with heat stores so they can contribute to smart electricity
consumption.
The Danish District Heating Association believes that large heat pumps should be promoted both in
heating systems and in CHP systems.
OVE suggests that heat pump expansion should be targeted so that all heat pumps are equipped
with heat stores and can therefore function as flexible energy consumption, used primarily when
electricity generation from wind power is at its highest. It also suggests that the expansion of heat
pumps should be in line with the increasing share of RE in electricity generation, with the aim that
electricity consumption for heat pumps and transport should rise more slowly than electricity
generation from RE sources.
TEKNIQ and the Danish Heat Pump Association are calling for an announcement to be made as soon
as possible on how Denmark is going to meet the RE Directives criteria concerning training
requirements to be met for fitters and installers of RE technologies. According to TEKNIQ, only a very
small number of installers are providing training in the area of small RE technologies because the
training requirements for future certification are not yet known and it typically takes two years
from when the training requirements are known until a sufficient number of installers have been
trained to be able to service the market. TEKNIQ would be happy to participate in the preparation of
the certification schemes.
The Danish Heat Pump Association suggests that comparable calculations be prepared on an
objective basis of what the energy and environmental consequences of the expansion of various
forms of heating would be. The Association also suggests that the continuation of the initiatives that
were implemented with the action plan for heat pumps, and that are due to expire soon, should be
ensured. It is proposed that there be a continuation of the labelling scheme, the quality assurance
scheme and active participation in the standardisation work as well as advice and information for
63
consumer groups. Technical support for producers and suppliers and increased market supervision
will further promote efficient heat pumps. The Association is also proposing the introduction of
dynamic taxes and tariffs, electricity price discounts on consumption in excess of 4 000 kWh for
users of efficient heat pumps, and the abolition of the process heat tax.
9. Infrastructure and smart electricity consumption
With regard to infrastructure, several parties point out that the electricity grid needs to be
strengthened and that it is important to be able to manage generation and consumption of
electricity to a greater extent through smart systems (DI, TEKNIQ, Greenpeace, INFORSE-Europe and
FRI).
There is a need for smart meters and price signals that promote smart electricity consumption
(INFORSE-Europe, Greenpeace, FRI, DI) such as incentivising tariffs, taxes and subsidies that support
socially responsible energy-efficient behaviour. FRI also proposes the establishment of smart grids
and that the building stock should be made smarter. According to DI, there is also a need for a looser
investment framework for the energy companies, and there should be the right grid connection
conditions for the plants, approval procedures, etc.
With regard to the action plans section on access to the energy grid (Article 16 of the RE Directive),
OVE and INFORSE-Europe recommend, among other things, that, in addition to the required access
for renewable energy to the electricity and gas networks, RE producers should also be given access
to the heating network and that the rules on the use of waste heat should be improved with, among
other things, clearer tax rules.
The Danish District Heating Association and FRI note that it is important to have storage
opportunities on the heat side so that, among other things, wind energy is used efficiently.
FRI also considers that the infrastructure for biogas should be developed and that the technology for
district cooling should be developed further as it is a natural extension to Denmarks highly
developed district heating system.
10. Research and development
The Danish Energy Association, DI and TEKNIQ mention the need for further effort in the area of
research, development and demonstration activities to ensure RE expansion.
According to DI, this can be done through deductions from the quota system or additional public
funds, and the current funds for research into climate-friendly energy technology should be
increased each year by DKK 300 million up to a new annual level of DKK 4 billion in 2020. More
specifically, DI proposes that research and development programmes be linked together better in a
smart innovation system that exploits the strengths of development partnerships between public
authorities, research institutions and the private sector.
INFORSE-Europe suggests that the EU should provide more assistance for development and
demonstration activities.
11. The RE Directives other provisions
With regard to the action plans section on administrative procedures and rules (Article 13 of the RE
Directive), OVE and INFORSE-Europe recommend, among other things, that the building regulations
64
should contain a solar heating requirement for new buildings and building renovations where this is
economical, i.e. in practice outside of district heating areas, and that it should also contain a
requirement of at least 25 % renewable energy in 2015. There should also be higher efficiency
standards for heat pumps preferably higher than the EU requirement. Finally, it is emphasised that
the public sector should lead the way.
With regard to the action plans section on information and training (Article 14 of the RE Directive),
OVE and INFORSE-Europe recommend, among other things, that, impartial information on
renewable energy should be available to consumers, home owners and administrators at the same
level as there is today for energy savings, that there should be free advice aimed in particular at
planners, architects and structural engineers, primarily via the internet, and that public authorities
and NGOs could play a role in the information work. With regard to training, it is recommended,
among other things, that the systems for the training of installers, architects, building technicians,
etc. should be reviewed and expanded so that all relevant professional groups have a good
knowledge of RE solutions and how the solutions can be used in context. OVE also recommends that
at least one person among the planning officials in each municipality should be trained in the use of
local renewable energy.
65
Annex. Meeting participants and contributors of written comments on the basis for the action
plan
The following parties submitted written comments on the basis for the Danish action plan for
renewable energy:
-
Blgekraftforeningen (the Danish Wave Energy Association)

Danmarks Naturfredningsforening (the Danish Society for Nature Conservation)
Danmarks Vindmlleforening (the Danish Wind Turbine Owners Association)
Dansk Energi (the Danish Energy Association)
Dansk Fjernvarme (the Danish District Heating Association)
Dansk Solvarme Forening (DSF, the Danish solar heating association)
Det kologiske Rd (the Danish Ecological Council)
DI (the Confederation of Danish Industry) (DI Energy Section and DI Bioenergy)
Foreningen af Rdgivende Ingenirer (FRI, the Danish Association of Consulting Engineers)
Greenpeace
INFORSE-Europe
LGDK (Local Government Denmark)
Landbrug & Fdevarer (the Danish Agriculture & Food Council)
Mellemfolkeligt Samvirke (ActionAid Denmark)
NOAH (Friends of the Earth)
Organisationen for Vedvarende Energi (OVE, Danish Organisation for Renewable Energy)
Skov & Landskab (Forest & Landscape Denmark), University of Copenhagen
TEKNIQ
Varmepumpefabrikantforeningen (the Danish Heat Pump Association)
Vindmlleindustrien (the Danish Wind Industry Association)
WWF (World Wildlife Fund)
Other participating organisations at the meeting on 26 April (68 participants in total):

-
92-gruppens sekretariat (the Secretariat to the Danish 92 Group)

affald danmark (Waste Denmark)
Brancheforeningen for Decentral Kraftvarme (trade association for decentralised CHP)
Brancheorganisationen for Biogas (trade association for biogas)
COWI A/S
Dansk Skovforening (the Danish Forest Association)
Dansk Transport og Logistik (the Danish Transport and Logistics Association)
Faculty of Agricultural Sciences, Aarhus University
DS Hndvrk & Industri (the Danish Employers' Association for Industrial and Construction
Enterprises)
Energi- og Olieforum (the Danish Oil Industry Association)
Energinet.dk
Force Technology
Grontmij Carl Bro
The Danish Ministry of the Environment
PlanEnergi
Pyry
Skov- og Naturstyrelsen (Danish Nature Agency)
Teknologisk Institut (the Danish Technological Institute)
Trafikstyrelsen (the Danish Transport Authority)
66

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December 2015

Overall RES share (%)

Of which from cooperation mechanism (%)

Surplus for cooperation mechanism (%)

Notes to figures in Tables 1, 1a, 1d and 4:

Facilitates comparison with Table 3 and Table 4a of the NREAPs.

E) Transfer of RES to other Member States

E) Transfer of RES to other Member States

Facilitates comparison with Table 4a of the NREAPs.

Tide, wave, ocean

Facilitates comparison with Table 10a of the NREAPs.

Of which biomass in households

Of which biomass in households

Of which biofuels Article 21(2)

Of which biofuels Article 21(2)

Of which road transport

Of which biofuels Article 21(2)

Of which biofuels Article 21(2)

Hydrogen from renewables

Note: Domestic production of biodiesel is confidential and is therefore calculated as imports.

Smart and flexibly priced electricity consumption

Per unit support

[(sub) category of specific technology or fuel]

A. Feed-in premiums for wind turbines

B. Premium for biogas etc.

Support for biogas for transport

The devaluation scheme

Heat pump task force

Table: The trend in issuing, transfer and cancellation

Table 4: Biomass supply for energy use

Biomass supply for heating and electricity:

Table 4: Biomass supply for energy use

For biofuels: In accordance with Article 22(2) of Directive 2009/28/EC.

Estimated excess as stated

Table 2: Overview of all policies and measures

Adjustment of premium for wind

Increased premium for small

Support for wave power

New and increased premiums for

Promoting biogas production

Promoting biogas production and

Targeted group and/or

Industry and research

Undertakings and others that

Start and end dates of

REAP: 4.2.8. 4.3 and

Name and reference of the

Targeted group and/or

Start and end dates of

Roll-out of hourly and remotely

Electricity consumers, grid

International electricity exchange

Promoting the interconnection of

The building industry and

Promoting energy savings

Promoting energy savings

The building industry

Information campaign for energy

Knowledge Centre for Energy

Promoting the use of electric vehicles

Acquiring experience and knowledge

Research scheme for electric

The Government, electricity

EPA: 4.1 and 4.5