The Bundesverband Windenergie Offshore (BWO), representing Germany’s offshore wind sector, demands a realistic and efficient application of the Net-Zero Industry Act (NZIA). The organization warns that excessive bureaucracy could deter investments and slow the growth of the offshore wind industry. Stefan Thimm, Managing Director of BWO, emphasizes the need for agile and clear implementation to capitalize on the NZIA’s potential to bolster Europe’s offshore wind supply chain.
In a position paper released on August 21, BWO outlines critical adjustments needed for the effective execution of the NZIA in Germany. The association highlights the importance of transparent, investment-friendly regulations to prevent low participation in auctions and to ensure timely project execution.
One key recommendation from BWO is to limit the application of non-price criteria to a maximum of 6 GW of the annual auction volume, instead of the proposed 30% share, provided that the total auction volume exceeds 20 GW. This strategic limitation aims to distribute risk more evenly across the offshore wind sector, thereby protecting the supply chain from disruptions.
BWO advocates for the inclusion of a resilience criterion as a mandatory prequalification for manufacturers. This requirement would enhance supply chain reliability without complicating the process for project developers. Additionally, the organization calls for flexibility to accommodate potential supply shortages or unexpected price increases.
To facilitate smoother project execution, BWO suggests that verification of component origins occur at the implementation stage rather than during the auction process. The association argues that early commitments to specific suppliers may restrict competition and burden component manufacturers. Instead, a self-commitment at the bidding stage, followed by rigorous verification during the project’s execution, would better balance compliance and investment certainty.
Thimm warns that if the NZIA’s additional criteria merely increase bureaucratic hurdles and costs without improving resilience, the act will not fulfill its intended goals. He urges the use of existing national frameworks, like those in the WindSeeG, to simplify the NZIA’s implementation process.
Furthermore, BWO recommends employing quantitative metrics to evaluate compliance with the criteria, enhancing transparency and speeding up the assessment process. The organization cautions against relative assessments based on auction bids, as these could introduce legal uncertainties and hinder progress.
On enforcing compliance, BWO requests that penalties be proportional and only applied when developers are clearly responsible for delays or breaches. The association stresses the need for clear delineation of responsibilities among developers, grid operators, and suppliers, along with the establishment of defined ‘force majeure’ scenarios to prevent unfair penalties for disruptions beyond developers’ control.
BWO’s position paper outlines strategies to attract investment while strengthening supply security. With offshore wind projected to be instrumental in Europe’s decarbonization efforts, the organization warns that poorly designed implementation of the NZIA could impede progress instead of promoting it.
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