Overall assessment

Updated December 2022

While France has taken some significant legislative steps to transposing RECs and CECs, in particular to operationalise the activity of energy sharing, this process has not yet extended concretely to most elements of the enabling framework that must be in place. Prior to the Clean Energy Package, France was already developing a framework to allow collective self-consumption beyond the building level (neighborhood or district level). The French government has put in place some lofty policy objectives for the development of energy communities, but in reality it has a ways to go to make these proposals more concrete. The Ministry convened a stakeholder group, bringing various people across the energy sector together, to propose enabling measures. From this initial work, The Ministry communicated in November 2021 that the pluriannual energy programme will account for the development of energy communities via the inclusion of a Roadmap for the development of energy communities. The Roadmap itself sets an objective of 1,000 citizen initiatives by 2028 and communicates 10 different measures to make this a reality. These measures still need to be delivered, however. Renewable Energy Communities currently do not have dedicated support under the national renewables support scheme, while the process of revising this framework has been ongoing for some time now.

Overall, France has communicated a number of objectives and supportive measures. However, it needs to put turn these commitments into concrete action, as well as finalise a proper support scheme that helps RECs overcome existing barriers to accessing renewables support.

Detailed assessment

Assessment of obstacles and potential for development of ECs

As part of the Roadmap, the Ministry will create an observatory for renewable energy projects with local governance and launch an impact assessment on local support an appropriation for renewable energy. Furthermore, a Working Group has been established by the Ministry with relevant stakeholders (public entities, associations, banks…) for this specific purpose. As per the Roadmap, the Working Group will continue meeting to process other needs for legislative and regulatory adaptation. While a good step in itself towards establishing dialogue with energy communities to better understand their needs, this has not yet resulted in the adoption of concrete measures.

Removal of unjustified regulatory & administrative barriers

As part of the Roadmap, the Ministry stated it would continue the working group set up to explore how to support energy communities. Specifically, it should discuss new possible legal and regulatory changes to support local engagement in renewable energy (heating, gas, biomethane, local authorities' participation, communities). Again, this has not yet resulted in the adoption of concrete measures.

DSO duties around cooperation with ECs and facilitation of energy sharing

DSO for electricity, gas and district heating cooperate with energy communities for energy sharing (labelled collective self-consumption). The Decree will specify under which situations the energy community has to pay a fee and under which condition the fee is established. In addition, energy communities have to declare their installations to the electricity, gas, heating and cooling DSO prior to their activation.

Fair, proportionate, and transparent registration & licensing procedures

As part of the Roadmap, the Ministry will lower the grid access connection fee for all installations under a certain capacity (500kW) in a way the grid tariff covers up to 60% of the connection fee. If and when done, this would remove a significant barrier for RECs. Although, grid access procedures should also be addressed, and they are not currently mentioned.

Incentives connected to network tariffs based on a CBA

The NRA establishes specific network tariffs for consumers participating in self-consumption operations, so that those consumers do not pay for access fees that do not reflect the costs of the DSO.

Non-discriminatory treatment as market participant

National legislation states that energy communities benefit from a proportionate and non-discriminatory treatment for their rights, activities and obligations as final consumer, producer, supplier and market operator.

Accessibility to low-income & vulnerable households

Not addressed in the transposition.

Tools to access finance

As part of the Roadmap, the Ministry will create a working group to identify and remove financial barriers for projects with local governance. This should focus on simplifying investment in locally governed projects, as well as accessing bank financing.

Tools to access information

In its Roadmap, the government stated that it would launch a national communication campaign to raise awareness of citizen energy and its benefits for the territories, and would support local elected officials by providing communication tools so that they can disseminate this information to local citizens.

Regulatory capacity building for public authorities

As part of the Roadmap, the Ministry will clarify how regional and national support schemes can co-exist. Furthermore, it plans to increase by 50% the number of local governance advisors in the regions.

NECP reporting on enabling frameworks

Not addressed in the transposition. Member States are required via the Governance Regulation (2018/1999) to report on their enabling frameworks for RECs by 15 March 2023.

Support Scheme adapted for RECs

RECs taken into account when designing eligibility/participation requirements

REC are not exempted from tendering. However, the selection criteria of the tendering process can include, among others, the share of capital owned by inhabitants and local authorities in the geographical proximity of the project in the legal entity developing the project. This provision is not specific to RECs, however.

Energy communities have a priority right to buy back guarantees of origin for biogas and electricity before or after they have been put on auctions. According to the Road Map, support schemes will be adapted for citizen energy.

Support for excess production not used in energy sharing

Feed in-tariffs for the surplus of an energy sharing initiative is identical to those for full injection.