Brussels, 14 November 2022

Dear Members of the European Parliament,

The EREF Small Hydropower Chapter and its members, national hydropower
associations from EU Member States, urge you to refuse the tabled amendment to
exclude small hydropower (SHP) from access to on “go-to” areas which are object
under Article 2 (9a) of the amended Renewable Energy Directive (EU) 2018/2001.

As instrument to ensure the REPowerEU objectives to increase Europe’s energy
independence and to speed up its decarbonisation, all forms of renewable energy,
including small hydropower, must be used both under considerations for an increased
renewable energy production and for a better energy system integration.

It is for this reason that EREF thinks it is important that “go-to” areas should better be
renamed as “acceleration” areas, conveying a more positive term, and not excluding
other areas from the development of renewables.

The exclusion of hydropower plants below 10 MW adopted by the Environment
Committee in the European Parliament contradicts the principle of technology
neutrality and lacks any scientific justification.

Due to latest innovative technical solutions, small hydropower and good ecological
status of a river can go hand in hand harmoniously. Hydropower is not a threat to the
ecological status of rivers if basic ecological requirements are met, e.g., sufficient
environmental flows (minimum water flows) and fish migration aids. Ecological
monitoring of watercourses very often reveals stretches of water used for power
generation where there is not only a minimal difference to the unused stretches but a
specific biodiversity resilient to draught.

The European small hydropower industry is regarded as world leader, offering the
complete range of technical solutions which comply with even the strictest
environmental laws and regulations.

Over the last decades, owners of European hydropower plants have invested billions of
Euros in upgrading existing plants with environmental mitigation measures, showing
their commitment and support to the ecological requirements of the Water Framework
Directive, and demonstrating that small hydropower and environment go hand in hand.

In the 27 EU Member states, around 25,000 small hydropower plants provide annually
13 million households with electricity and contribute already to the EU’s
decarbonization by saving CO2 emissions from energy production.

A recent assessment on the residual and hidden potential of small and micro
hydropower in the EU
estimates an additional yearly production of 79 TWh of green
electricity under the strictest environmental constraints. This would be an additional
substantial contribution from the small hydropower sector to the REPowerEU
objectives to increase Europe’s energy independence and to speed up its
decarbonisation. It would also help against soaring energy prices and potential energy
shortages during upcoming winters.

Prof. Dr. Dörte Fouquet
EREF Director

Ghislain Weisrock
Spokesperson of the EREF Small Hydropower Chapter

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