BWO statement: On the consultation “Offshore Wind Energy Act”
"The BWO welcomes the proposed amendment to the Offshore Wind Energy Act (WindSeeG). The central point for us is...:
Offshore optimization measures must be implemented. The BWO's objective of reducing system costs through more efficient use of infrastructure and available space is fundamentally understandable. It is particularly positive that reducing power density to limit shadowing effects is part of the set of objectives.
The overplanting/overbuilding addressed primarily in the consultation by the Federal Ministry for Economic Affairs and Energy (BMWi) is only one of many optimization measures. These measures should be discussed, evaluated, and implemented on an equal footing. They include, among others: reducing the power density on areas to be tendered in the future to below 10 MW/km²; adjusting the expansion sequence to minimize shading effects and maximize full-load hours; and the possibility of developing and radially connecting areas in neighboring countries such as Denmark, as also provided for in the current coalition agreement.
From the BWO's perspective, it is also crucial that optimization potential is not exploited unilaterally at the expense of developers. One-sided grid cost optimization must not be the sole focus of cost-efficient expansion planning. Developers already operate within the bounds of what is economically sensible and feasible. The extent of optimal, area-specific development should be left to them. This flexibility must be maintained. Rigid development plans would represent a further obstacle to investment in offshore wind energy and further increase project risks. In conjunction with an adjustment to the auction design, it can be assumed that these additional costs would be reflected in higher PPA or CfD prices. These effects, and the resulting higher electricity prices, must also be included in a macroeconomic analysis. Should a study commissioned by the BWO and BDEW reveal that higher development values from a macroeconomic perspective exceed optimal business levels, the excess development must be compensated accordingly.
The BWO sees various advantages and disadvantages to different models for implementing a CfD. However, among its members, there is a strong preference for a CfD-only model. Accordingly, the interpretations of the Consultation The majority of the membership tends not to agree with the advantages of the either-or model.
The BWO clearly advocates for the indexing of two-sided CfDs.”