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By 30 June 2021, EU Member States were expected to transpose the recast Renewable Energy Directive (RED II) which includes provisions for renewable energy communities (RECs) and to develop an enabling framework to promote the development of RECs. Although there is a growing number of studies analysing the emergence of various forms of community energy, comparative studies investigating the transposition and creation of enabling frameworks for RECs in a multi-level governance (MLG) perspective are scarce. This article examines the transposition in Germany and Italy and compares elements of the respective enabling frameworks. Key methods include context and MLG analysis combined with methods of descriptive (legal) studies. Insights and participatory observations of the stakeholder desks established in the Horizon2020 project COME RES complement the spectrum of methods deployed. Although community energy development is more advanced in Germany, the transposition of the RED II provisions has been slow and piecemeal so far. Conversely, in Italy, RED II played a catalyst role; the transposition has been rather dynamic and encouraged a continuous growth of REC initiatives. Nevertheless, a widespread uptake of RECs requires structural adjustments of the governance system in both countries and attention to MLG as well as vertical policy coordination.
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Citation: Krug, M.; Di Nucci, M.R.;
Caldera, M.; De Luca, E.
Mainstreaming Community Energy:
Is the Renewable Energy Directive a
Driver for Renewable Energy
Communities in Germany and
Italy? Sustainability 2022,14, 7181.
Academic Editor: Miguel Amado
Received: 3 May 2022
Accepted: 9 June 2022
Published: 11 June 2022
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Mainstreaming Community Energy: Is the Renewable Energy
Directive a Driver for Renewable Energy Communities in
Germany and Italy?
Michael Krug 1, * , Maria Rosaria Di Nucci 1, Matteo Caldera 2and Elena De Luca 2
1Research Center for Sustainability, Freie Universität Berlin, Ihnestrasse 22, D-14195 Berlin, Germany;
2Italian National Agency for New Technologies, Energy and Sustainable Economic Development (ENEA),
Lungotevere Thaon di Revel 76, 00196 Rome, Italy; (M.C.); (E.D.L.)
By 30 June 2021, EU Member States were expected to transpose the recast Renewable
Energy Directive (RED II) which includes provisions for renewable energy communities (RECs) and
to develop an enabling framework to promote the development of RECs. Although there is a growing
number of studies analysing the emergence of various forms of community energy, comparative
studies investigating the transposition and creation of enabling frameworks for RECs in a multi-level
governance (MLG) perspective are scarce. This article examines the transposition in Germany and
Italy and compares elements of the respective enabling frameworks. Key methods include context
and MLG analysis combined with methods of descriptive (legal) studies. Insights and participatory
observations of the stakeholder desks established in the Horizon2020 project COME RES complement
the spectrum of methods deployed. Although community energy development is more advanced in
Germany, the transposition of the RED II provisions has been slow and piecemeal so far. Conversely,
in Italy, RED II played a catalyst role; the transposition has been rather dynamic and encouraged a
continuous growth of REC initiatives. Nevertheless, a widespread uptake of RECs requires structural
adjustments of the governance system in both countries and attention to MLG as well as vertical
policy coordination.
European Union; renewable energy communities; community energy; energy policy;
multi-level governance
1. Introduction
1.1. Context
The evolution from an energy system based on centralised large power plants to a dis-
tributed energy production model based on renewable energy sources (RES) still represents
a socio-political challenge in most European countries. On the customers’ side, direct citizen
participation, lower energy prices and access to private capital for RES plants and energy
efficiency investments show already evident benefits [
]. Renewable energy communities
(REC) can play an important role in achieving such goals, but their establishment requires
a suitable regulatory framework that fosters the economic sustainability of community
energy (CE) projects.
The European Union (EU) with its legislative package “Clean Energy for All Euro-
peans” established a ground-breaking framework to trigger community-based bottom-up
initiatives. The Renewable Energy Directive (2018/2001/EU) (RED II) provides definitions,
rights, and duties of RECs and requires EU Member States to create enabling frameworks
for their development. By 30 June 2021, Member States had to transpose those provisions.
Although many countries have transposed the definitions of RECs literally, there is still a
Sustainability 2022,14, 7181.
Sustainability 2022,14, 7181 2 of 24
lack of effective enabling frameworks. The progress made by pioneer countries is still far
from the positive narratives that foretell a swift mainstreaming of CE [
], yet the creation
of enabling frameworks is not a trivial matter and is confronted with several barriers. To
overcome these, it is necessary to fine-tune the existing energy governance and infrastruc-
ture to accommodate RECs, especially in relation to incentives, subsidies, and access to
energy markets.
Due to the actuality of this topic, challenges and chances offered by the transposition of
the EU directives have been only partially investigated in the literature [
]. Only recently,
however, studies have started examining the process of transposing the RED II provisions
for RECs, both in single country settings [
] and in comparative analyses [
]. A
number of comparative assessments have been performed in the frame of projects funded by
the European Union, many of which focus on specific elements of the transposition process,
e.g., legal definitions [
], rights or legal forms [
], economic viability [
], loopholes and
positive developments [5] or selected elements of an enabling framework [11,18].
Although there is ample evidence that effective government coordination of sectoral
policies along different levels of government is conducive for CE [
], comparative stud-
ies investigating the RED II transposition process and the creation of enabling frameworks
for RECs in a multi-level governance (MLG) perspective are scarce. There are only very few
studies addressing the transposition process, although not in a systematic manner [
]. The
present article aims to address this gap by analysing in a comparative fashion the status
of implementation of enabling frameworks in Germany and Italy, two EU Member States
that share a tradition of CE, albeit with different energy policy backgrounds and historical
development paths of their energy systems. Hence, the novelty of the article is threefold: it
approaches the RED II transposition process from a Multi-Level Governance perspective, it
scrutinizes recent policy developments in Germany and Italy and assesses the progress of
the implementation of the enabling frameworks against the set of requirements specified
by the RED II.
1.2. Purpose and Stucture
The purpose of this paper is threefold: to illustrate how community renewable energy
evolved in Germany and Italy so far, to analyse the progress of the transposition and
implementation of RED II, and to assess to what extent governments in both countries
managed to create an enabling framework to foster the development of RECs. In doing so,
we focus on the electricity sector and place a particular emphasis on both the key drivers
and barriers, and on the characteristics of the enabling frameworks that are required to
boost the development of RECs. We undertake a critical analysis of specific national
and regional measures in both countries and assess whether policies and measures are
suitable to overcome barriers and whether their interaction and coordination are effective
in establishing a robust enabling framework.
The article is structured as follows. In Section 2, we illustrate the theoretical approach
which includes a brief literature review with a focus on multi-level governance in the energy
field and an examination of recent works that link energy decentralisation and citizen-led
energy initiatives. In Section 3, we elaborate on the research concept and explain materials
and methods. In Section 4, we describe the regulatory framework for RECs provided by the
RED II. Results of our comparative analysis are presented in Section 5. First, we refer to the
historical development as well as barriers and drivers in both countries and then examine
the transposition of RED II itself. In the discussion part (Section 6), we compare and
scrutinize context, enabling frameworks, support scheme designs, policy instrumentation
as well as policy coordination. Finally, in the concluding section, we present lessons for
future policy, provide insights for the design and implementation of public policies in a
complex multi-level perspective and highlight issues for future research.
Sustainability 2022,14, 7181 3 of 24
2. Decentralisation and Bottom-Up Pathways as Key Elements of the Energy
Transition: A Theoretical Approach
The transition to a low carbon economy requires new structures and organisational
forms. Energy communities are important vehicles for reducing GHG emissions by dis-
tributed integration of RES and for providing positive environmental and economic impacts
fostering regional and rural development.
The development of enabling frameworks calls for a multi-level governance (MLG)
perspective and mutually reinforcing policies at different levels of government. The energy
transition is a multi-level task and develops in multi-level institutional settings [
Following Rogge and Reichardt (2016), we assume that policy mixes are embedded in multi-
level governance systems encompassing supranational, national, and subnational levels of
governance [
]. From the multi-level perspective, government and firms, as well as other
stakeholders, have a central role to play in system change and in the diffusion of low carbon
technologies [
]. The development of more performing technologies in terms of reducing
GHG emissions could accelerate this change but needs support for technology transfer
initiatives, e.g., through the creation of public and private partnership [
]. An analysis
based on MLG represents a good heuristic to describe the process of decision making in
the energy field and to understand the dynamic nature of energy governance, because the
so-called enabling frameworks are framed within a multi-level setting encompassing the
supranational, the national and the regional/local level. MLG thus provides us with a
coherent framework to understand inter-related processes of centralisation, decentralisation,
fragmentation, as well as recentralisation and coordination of the energy system.
In recent years, national and subnational policymakers have increasingly adopted
measures to stimulate decentralised renewable energy generation. Therefrom, a growing
body of research analysed national pathways to a decentralisation of the energy system. In
this context, renewable energy communities increasingly attracted interest. The prolifera-
tion of the literature on CE and citizen-led energy initiatives and the increasing number of
projects financed by the European Commission within the Horizon 2020/Europe Research
Programme are good indicators of the disruptive force that these bottom-up initiatives can
represent for the energy transition in the EU.
The theoretical approaches found in the literature vary from typical transitional theory
settings analysing energy innovation systems [
], to multi-level perspective and hindering
effects of multilevel settings on the energy transition [
], to governance approaches that
address institutional arrangements, the interplay of national and local government, and
cooperation challenges [
]. Furthermore, sociological and acceptance studies dealt with
renewable energy and bottom-up energy initiatives with respect to their social effects [
Over the years, the scholarly literature has encompassed various aspects of CE and citizens-
led energy initiatives analysing different concepts and configurations, as well as barriers
and drivers jointly with financial and legal aspects [
]. These bottom-up approaches
involving local actors are regarded as a strong means to implement a more democratic
and inclusive just energy transition [
]. Most analysts point out the strong link with
democratisation and grass-root activities [
], where bottom-up initiatives driven not only
by citizens as investors but also as consumers play a key role [46].
CE represents a social innovation [
] and is characterised by the combination of the
collective and public interest [
]. Over the years, however, we have witnessed an evolu-
tion of the terminology. In an analysis of the scholarly literature based on the review of
405 articles, Bauwens et al. (2022) lamented ambiguity in the use of the notion of “com-
munity” and detected a variation changing over time in the meanings and the objectives
pursued by communities. They observed a shift from the concept of community under-
stood as “a process that emphasizes participatory aspects toward a notion of community
primarily referring to a place” [47] (p. 1).
The factor that makes CE solutions congenial elements of the energy transition is
that they combine energy generation, distribution, storage, and trading structures and are
mostly owned locally. These schemes are instrumental to reach energy transition objectives
Sustainability 2022,14, 7181 4 of 24
at local level for cost savings, emission reductions, energy efficiency and self-sufficiency.
Due to the multi-energy character of these initiatives, there are complex physical and
economic interactions. The push towards the circularity of the energy resource, which is
therefore produced and consumed onsite, increases the awareness of citizens and local
administration and encourages new initiatives in other sectors such as waste or water
resource management.
There is ample evidence from a number of EU countries, not only pioneer countries
like Denmark, Germany, Belgium and the UK where CE initiatives have been perceived as
important actors in the transition toward low-carbon energy systems [
], but also from,
e.g., Greece, France and Ireland, where advancement of CE has gone hand in hand with
the enhancement of local environment and economy. Greece, for example, was rather
fast in introducing EU legislation already in 2018 and CE has played an important role
in decarbonizing society, and it has been reported that Law 4513/2018 represented a
novel and integrated institutional intervention which enhanced social economy in the
energy sector [
]. In Ireland, energy citizenship enjoys social and local acceptance,
but in spite of infrastructural support, energy communities face difficulties to upscale
their activities [
]. France introduced already in 2015 incentives in form of “participatory
bonuses” to foster financial participation of local actors in renewable projects [
]. Sebi and
Vernay who focused their analysis at the national and regional levels and examined CE
initiatives by a typology governance type and project size highlight the role that CE can
play locally and advocate the establishment of support schemes that reflect the multifarious
roles of renewable community energy [52].
In this context, local energy communities play a fundamental role for the decentral-
isation of the energy systems and demonstrate the need for new modes of governance
and market design. Indeed, the enhancement of CE calls for organisational and struc-
tural change, or at least fine-tuning of governance systems that today still revolve around
centralised energy systems.
The development of energy communities has faced numerous limiting
factors [
]. Challenges are met already in the planning stage due to increasingly
complex planning and licensing procedures. Furthermore, the transition to auction systems
in the electricity sector has negatively affected CE initiatives.
There are many suppositions about the motivation and which factors have triggered
the development of CE. Hewitt et al. (2019) consider the interplay of the EU market
liberalisation, generous incentives and the fall in the price of PV systems to have played
a pivotal role in enhancing CE [
]. Other studies show that a complex interaction of
material-economic, actor-institutional, and discursive factors help explain the emergence
of CE initiatives [
]. Supportive governance is among the key success factors identified
by research [
]. A number of studies refer to the important role of subnational
policy actors, i.e., state, regional, provincial, and local governments in contributing to
the development and the creation of success conditions [
]. In a recent literature
review of challenges of CE examined through a policy lens, Busch et al. (2021) highlight
directionality, experimentation, demand articulation, policy learning and coordination as
key enabling factors [
]. Literature has been pointing out for a while that a consistent,
coherent, and beneficial mix of policies from different bodies of legislation is required
for a successful transition to more CE, whereby a policy mix encompasses more than just
a combination of policy instruments, but also the processes by which such instruments
emerge and interact at various levels of governance [
]. Several researchers emphasize
the need for policymakers at all levels to help CE unfold [
]. However, only little is
known about the interacting effects of different governance levels in promoting CE [20].
In Germany and Italy, RECs also represent a response to the decentralisation paths
facilitated or even triggered by a federal governing structure (Germany) or a quasi-federal
structure (Italy) [
]. In both countries, the multi-level dimension plays a role in the choice
of policies.
Sustainability 2022,14, 7181 5 of 24
3. Materials and Methods
The present article compares the transposition of the recast Renewable Energy Direc-
tive (RED II) in Germany and Italy with an exclusive focus on the provisions for RECs
and the respective enabling frameworks that Member States shall provide to promote and
facilitate their development. Our analytical framework follows the provisions of RED II
and covers the following conditions that should be fulfilled for a complete implementation:
context, elements of enabling frameworks, support scheme designs, policy instrumentation
as well as policy coordination. We further investigate the characteristics of the transposition,
including the coherence of the processes and as well as the estimated effectiveness of the
policy mix. In the comparative part of this article, we juxtapose the German and Italian
policy strategies with their objectives and the plans for achieving them, along with the
instrument mix and interacting policy instruments.
The key methods applied in our analysis combine context analysis and MLG analysis
with methods of descriptive (legal) studies and document analysis. Data collection relied
on secondary sources, in particular academic journals, technical journals in both countries,
reports of European collaborative projects, drafts of laws and regulations, official govern-
mental reports as well as reports and advisory opinions of renewable energy organisations
and NGOs, press releases and websites.
Further evidence to support our analysis is derived from stakeholder
consultations [
], participatory observations and outcomes of the German and Italian
stakeholder desks established in the framework of the Horizon 2020 project COME RES.
This project focusses on advancing RECs in nine European countries, learning from regions
with advanced CE development and supporting target regions which have less experience
with the development of energy communities. Country stakeholder desks have been estab-
lished in all partner countries and serve as informal dialogue fora. They consist of a core
group of approximately 30–50 stakeholders including policy makers, public authorities, en-
ergy agencies, policy advisory organisations, CE initiatives and cooperatives, associations
and other groups of interest, etc. Between December 2020 and April 2022, each of the two
countries under investigation organised two desk meetings and two thematic workshops
in combination with policy round tables involving European, national and regional policy
makers. These events primarily address the status and challenges of transposing the RED
II provisions for RECs. Participatory observations and conclusions derived from those
events represent an important complement to develop our understanding of how enabling
frameworks are presently shaped in practice.
4. The RED II and Its Provisions for Renewable Energy Communities
With its legislative package “Clean Energy for All Europeans”, the EU supports active
energy citizens and communities as stakeholders in the European energy market and
empowers citizens, granting them ownership of the energy transition. Within the package,
particularly relevant are the Internal Electricity Market Directive (2019/944-IEMD) and
the revised Renewable Energy Directive (2018/2001-RED II). These directives introduced
two types of energy communities: Citizen Energy Communities (CECs) defined under the
IEMD and Renewable Energy Communities (RECs) defined under the RED II. Although
both types share many commonalities, there are several distinct differences.
The directives provide an extensive list of energy-related activities that CECs and RECs
are allowed to conduct. These include generation, consumption, supply, energy sharing,
energy storage, aggregation, and management of distribution networks for both RECs and
CECs, as well as the provision of energy efficiency, charging, and other energy services
for CECs. While regulatory frameworks exist for most of these activities, energy sharing
within energy communities and the operation of distribution networks requires particular
attention from national and regional authorities when transposing and implementing the
directives [
]. The primary objective of CECs and RECs is not financial gain, but to bring
environmental, economic, or social community benefits to the members or the local areas
in which these entities are active. Key differences between both concepts refer to corporate
Sustainability 2022,14, 7181 6 of 24
governance, membership, effective control, and autonomy. Corresponding provisions
are generally more demanding for RECs than for CECs. Member States must provide
enabling frameworks to promote and facilitate the development of CECs and RECs. The
RED II includes a comprehensive list of key elements that an enabling framework for
RECs shall comprise. These include, inter-alia, removal of regulatory and administrative
barriers, nondiscriminatory treatment of RECs as market participants, fair and transparent
procedures, adequate, fair, and balanced contribution of RECs to the overall cost sharing,
access to finance and information, regulatory and capacity-building support for public
authorities in enabling, setting up or participating in RECs.
Member States are required to assess the existing barriers and the development poten-
tial of RECs. Furthermore, they need to consider the specificities of RECs when designing
support schemes for RES so that these can apply for support under the same conditions as
other market participants. Recital 26 of the RED II contains several exemplary measures:
provision of information, of technical and financial support, reduction of administrative
requirements, inclusion of bidding criteria targeted at RECs, tailored bidding windows
for RECs, remuneration via direct support if RECs meet the “de minimis” criteria for
small installations.
In general, both directives contain several indefinite legal terms, and Member States
have considerable room to maneuver in implementing a legal and regulatory framework
that is conducive to the development of RECs [
]. This applies in particular to corpo-
rate governance criteria such as autonomy and effective control or to criteria referring
to proximity.
5. Results
5.1. The Development of Community Energy in Germany and the Transposition of RED II
5.1.1. Historical Development, Barriers and Drivers of Community Energy
Germany has a long tradition of energy cooperatives and municipal (multi-) utility
companies. In 2016, in Germany existed approximately 1700 CE initiatives with coop-
eratives representing slightly more than 50% [
]. Electricity distribution cooperatives
played a key role in the electrification of rural areas at the beginning of the 20th century, but
only a few of them persisted [
]. Modern energy cooperatives experienced a particularly
dynamic development between 2006 and 2013. By the end of 2020, the cumulative number
of energy co-operatives founded since 2006 reached 896, involving 200,000 members and
mobilizing investments in renewable energies of 3.2 billion EURs [66].
The supportive legal and regulatory framework played a fundamental role for the
development of CE in Germany. A crucial factor facilitating the emergence of CE were
attractive, long-term oriented feed-in tariffs/premiums, which helped create a low-risk
investment environment [
]. The price-based support scheme was complemented by a
purchase guarantee and priority feed-in of renewable electricity providing a high degree
of planning security for investors. Further, this worked as a shelter for small-scale and
locally rooted renewable energy producers in particular to grow in a niche market [
Amendments to the Cooperative Law in 2006 simplified the rules and requirements to
establish energy cooperatives whilst the availability of low interest loans offered by public
banks helped to ease the diffusion of energy communities [
]. Subnational policies
in several federal states have also supported the development of community wind farms
through advice, guidance, capacity building, networking and financial support [
]. The
German case illustrates that the coordination of national and sectoral policies along different
levels of government did effectively support the development of CE [21].
Lately, bottom-up CE initiatives have been increasingly challenged by the changing
political framework conditions, particularly by the phase-out of the feed-in-tariff/premium
system and the transition to competitive bidding in 2017. Since then, onshore and offshore
wind, larger PV, and biomass projects must compete in auctions, where only the cheapest
offers are awarded remuneration contracts. The auction design encompasses a “price only”
Sustainability 2022,14, 7181 7 of 24
selection process, i.e., the only award criterion being the necessary support level for the
electricity. Only smaller installations benefit from legally fixed remuneration rates.
CE projects cope with multiple structural challenges: higher transaction costs for
collective decision making, management and coordination of a large number of members or
shareholders, increasingly complex administrative procedures (e.g., planning, permitting,
grid connection), lack of expertise and market oversight, lower economies of scale and
limited possibilities for project financing. Small project portfolios and a weak capital base
prevent the recovery of sunk development costs caused by unsuccessful bids [70].
To preserve a certain diversity of actors and to ensure participation of community
wind energy projects in the auctions, the amendments of the Renewable Energy Sources
Act (RESA) of 2017 provided special privileges for “citizens’ energy companies” (Bürgeren-
ergiegesellschaften). The low prequalification requirements for citizen energy companies
and loopholes in the legal framework led to cases of abuse [
]. Several commercial project
developers set up pseudo citizen energy companies formally complying with the eligibility
criteria to benefit from the privileges. While some of the privileges have been withdrawn
in 2018, others are still in force including a preferential pricing rule [
]. However, the
remaining privileges turned out to be ineffective, as demonstrated by the continuously
shrinking share of successful bids from citizen energy companies in the frame of wind
energy auctions [
]. Overall, the transition from the fixed-price system to competitive
tenders has favoured large players and at the same time led to a decline in the number of
newly founded energy communities and energy cooperatives [66,73].
5.1.2. Transposition of RED II to Date
Despite its pioneering role, Germany is lagging behind other countries in terms of
transposition of the relevant provisions for RECs. The most recent amendments of the
RESA of December 2020 and June 2021 failed to fully and timely transpose the provisions
for RECs defined in RED II. Although the federal government transposed several require-
ments referring to individual prosumers, there are still considerable transposition gaps
regarding most of the provisions relevant for RECs, but also with regards to collective
self-consumption at the building scale.
Many existing energy communities may already implicitly fulfill the criteria of RECs
as defined in the RED II. Nonetheless, so far there is no legal definition of RECs in German
law that would fully comply with the RED II. The legal term “citizen energy company”,
which was already introduced in 2017, shows certain parallels to the definition of RECs in
the RED II. However, the purpose of RECs as defined in Art. 2.16 has no explicit equivalent
in German law. Furthermore, the definition of “citizens’ energy companies” has a very
limited scope of application (wind energy), and there is no equivalent for the other RES.
The existing circle of actors that can form a citizen energy company is larger than envisaged
for RECs in the RED II. The German law does not define explicitly the rights and activities
of RECs mentioned in Art. 22.2 of RED II. Although they are not formally entitled by
law, entities that fulfill the criteria of a REC are free to produce, consume, store, and sell
renewable energy. However, there is no regulatory framework for energy sharing, enabling
REC members to share RES produced by the community.
Neither the federal government nor the Länder governments have carried out any
assessment of the existing barriers and potential of development of RECs as required
by the RED II that could serve as a well-grounded basis for the creation of an effective
enabling framework [
]. So far, the federal government provided only a few elements of an
“enabling framework” as defined by the RED II, Art. 22(4). The federal government neither
offers any regulatory and capacity-building support to public authorities, nor developed a
cost–benefit analysis to ensure an adequate, fair, and balanced contribution of RECs to the
overall cost-sharing. Moreover, there are no mechanisms in place to ensure cooperation
of relevant Distribution System Operators (DSO) with RECs to facilitate energy transfers
within RECs. Access of RECs to start-up financing and information might be improved.
There are some innovative measures taken by the Länder, such as the community energy
Sustainability 2022,14, 7181 8 of 24
fund (Bürgerenergiefonds) which has been set up by the state government of Schleswig-
Holstein in 2018 and which provides risk capital for CE projects [
]. However, these are
standalone measures, and a coherent enabling framework supporting RECs is still lacking.
Although Germany was one of the first countries to consider the specificities of CE in
its support scheme for RES based electricity, these turned out ineffective and had partly
detrimental effects. Hence, it is essential to provide accompanying support and develop
tailor-made solutions. This is precisely where an enabling framework should come in.
Another problem aggravating the situation is the increasingly complex and bureaucratic
procedures which have deterring effects for CE projects.
After years of stagnation, following the general elections of September 2021 promising
signals emerged that gave hope for a U-turn in the piecemeal policy approach of the past
years. In its coalition agreement, Germany’s new “traffic light” government of Social
Democrats, Free Democrats, and the Green Party committed to increase the RES share to
80% of the country’s electricity mix by 2030 (from 42% in 2021). The agreement envisaged
to strengthen CE as an important element to enhance local acceptance and to improve the
frame conditions within the scope of European law. In particular, the coalition committed
itself to facilitate energy sharing and to examine the possibility of establishing a fund to
cover the risks of CE initiatives. Further, the development of landlord-to-tenant electricity
models and neighbourhood concepts is going to be simplified and strengthened. The gov-
ernment also plans to make full use of the “de minimis” rules under the revised Guidelines
on State Aid for Climate, Environmental Protection and Energy (2022/C 80/01) and exempt
RECs below certain thresholds from the auctions as a contribution to reducing bureaucracy.
Parts of those measures have been recently incorporated in the so-called ‘Easter Package’,
a set of legislative proposals released by the Ministry of Economic Affairs and Climate
Action in March 2022. These include adjustments to the existing definition of ‘citizen energy
companies’ and the exemption for RECs to participate in auctions. However, a regulatory
framework for collective self-consumption and energy sharing is still missing. There are
indications that the government first aims to fundamentally overhaul the electricity market
design including the complex system of surcharges, fees, taxes and then as a further step
deal with the regulatory framework [60].
The creation of an enabling framework pursuant to the RED II needs to consider
and integrate subnational levels of government including the federal states, districts, and
municipalities. Policies relating to RECs are a multi-governance issue [
]. Therefore,
appropriate transposition of RED II requires effective vertical and horizontal coordina-
tion. In the past, federal states have been pioneers in promoting the use of RES and CE
initiatives [
]. Moreover, the German Länder function as important “laboratories for
experimentation” [
] (p. 304). Several promising policies and support measures such as
the community energy fund established in Schleswig-Holstein or a networking platform
for CE initiatives and energy cooperatives set up by the regional energy agency in North
Rhine-Westphalia promoting exchange, networking and cooperation and providing initial
advice for CE start-up initiatives could serve as crystallization points of a future enabling
framework for RECs required by RED II [53].
5.2. The Development of Community Energy in Italy and the Transposition of RED II
5.2.1. Historical Development, Barriers and Drivers of Community Energy
In Italy, historical energy communities survived the nationalisation of the electrical
system in 1962. They are classified as historical cooperatives and consortia with their
own distribution grid. According to the Regulatory Authority for Energy, Networks,
and the Environment (ARERA) (Delibera 233/2020/R/eel of 23 June 2020), there are
28 historical cooperatives and one consortium, mainly located in the Alpine area (above
all in North-Eastern Italy) (This is not a complete list because some of the entities have yet
to be classified.). Due to their location, small and large hydropower and biomass plants
represent the most common RES plants to produce electricity. Many of the cooperatives are
local distribution system operators (DSOs) and manage district heating networks. Even
Sustainability 2022,14, 7181 9 of 24
though locally limited, some of them supply thousands of customers and own large power
plants, exceeding the megawatt threshold.
Until recently, the regulatory framework in Italy imposed significant barriers to the
creation of energy communities. RECs differ substantially from the Italian historical
cooperatives. For instance, pursuant to Art. 42 bis of Law no. 8/2020 that has partially
transposed RED II as regards collective self-consumption and RECs, they could not act
as a DSO because their members must be connected to the low voltage grid referring to
the same medium-to-low voltage substation, and the single RES installation owned by a
REC could not exceed 200 kW nominal capacity. These constraints significantly limited the
dimension and relevance of RECs and consequently the interest of stakeholders to invest
in such projects. However, the legislation adopted in November 2021 (Legislative Decree
no. 199/2021) relaxed those limits. In particular, RECs are limited to the same electricity
market zone and the incentives are granted to RECs where the members (producers and
consumers) are connected to the same primary electrical substation (i.e., they can be
connected to the medium voltage grid) and RES power plants are up to 1 MW. By the
beginning of 2021, approximately 20 initiatives complying with RED II provisions have been
established pursuant to national law and are operating while more projects are currently
under development [
]. Moreover, ten other projects planned before the adoption of
the national regulation pursuant to Law Nr. 8/2020 have characteristics which are not
compliant with that law, especially regarding the plant size and the connection of the
members to the public grid. In those cases, a possible strategy could be to split the original
project into small projects and to create an “aggregator” to coordinate the smaller RECs.
New RECs are located in many Italian regions from North to South and also on the islands
(Sardinia and Sicily). Piedmont is currently the region that counts most RECs (operating
and planned). One of the reasons is that it was the first Italian region that adopted a regional
law promoting the foundation of RECs in 2018.
So far, the key characteristics of RECs already established or in preparation are affected
by the regulation set by Art. 42 bis of Law no. 8/2020:
1. Location: quite widespread, in many Italian regions from North to South;
2. Status: only a few of them are operative, most are in a planning stage;
Initiators: mainly municipalities, in some cases SMEs and private companies that are
technical partners of the project;
Number of members: this is indirectly limited by current legal constraints, in the
order of few tens, generally not exceeding one hundred members;
Type of RES technology: PV is the far most common choice, due to the limits imposed
by the current legislation, the economics of the investment and the favourable incen-
tives for this technology. Only for larger projects other RES technologies are relevant:
hydro, biomass, or, less frequently, wind and biogas;
Storage: some of the projects foresee the integration of battery storage facilities (so far,
in the order of few kilowatt-hours).
5.2.2. Transposition of RED II to Date
As a rule, policy targets for RES are established at the national level. The regional
administrations provide specific rules and guidelines for RES projects in their territories
such as suitable areas for new plants. Within the National Energy and Climate Plan (NECP),
national targets have been set for 2030 referring to RES (i.e., to reach a share of 30% in
gross final energy consumption, and of 21.6% in transport), energy efficiency, (reduction of
final energy consumption by 43% vs PRIMES scenario 2007) [
] and reduction in GHG
emissions (33% reduction compared to 2005) [
]. Even if no quantitative targets have
been formulated, the NECP fosters initiatives oriented to make citizens and SMEs the
leaders and beneficiaries of the energy transition through the creation of self-consumption
initiatives and energy communities.
Prior to 2020, there was no organic regulatory framework for collective self-consumption
and CE actions. In order to close this gap, the Italian government anticipated the adoption of
Sustainability 2022,14, 7181 10 of 24
RED II, by pro-actively inserting a specific article, i.e., Article 42bis, in the Omnibus Decree
Law 162/19 (so called “Milleproroghe” Decree) subsequently modified in Law no. 8/2020
regulating the establishment of energy communities.
Thanks to the progress made in the transposition of RED II, electricity consumers can
join collective self-consumption initiatives and energy communities. According to Art.42bis,
eligible RES plants of RECs and collective self-consumers are required to start operation
after 1st March 2020, but their size is limited to 200 kW. The “Rilancio” (Re-launch) Decree,
9 May 2020 n. 34, offers up to 110% tax deductions of personal income (Superbonus) for
energy efficiency measures and new PV installations up to 20 kWp. These also apply
for RECs and collective self-consumers. The Energy Authority (ARERA) Resolution of
4 August 2020, 318/2020/R/eel established criteria for regulating specific economic items
(i.e., energy costs, energy prices, taxes and duties) related to self-consumption or energy
sharing within RECs. On 16 September 2020, the Ministry for Economic Development
(MiSE) issued a decree that provides financial incentives for collective self-consumption
and energy communities.
However, considering the provisions of RED II, a number of issues still need to be
improved. These concern instruments to facilitate the access to finance; regulatory and
capacity-building support to public authorities in enabling and setting up RECs and rules
to secure the equal and nondiscriminatory treatment of consumers.
Until the full transposition of RED II there were only limited opportunities for REC
projects to contribute to achieving the NECP goals. This was partially due to the national
regulations which limited the capacity of RES installations to 200 kW, and which required
that consumers and prosumers are connected to the low voltage grid (see above). This
limitation has been recently overcome by Legislative Decree no. 199 of 8 November 2021
which largely transposes RED II, increases the capacity limit of REC plants to 1 MW
and allows members and plants of a REC to be connected to the medium voltage grid.
Under the Italian Recovery and Resilience Plan (PNRR), which aims to overcome the
economic consequences of the COVID-19 pandemic, a fund of 2.2 billion Euro has been
set up to provide financial resources for the establishment of RECs in small towns with
fewer than 5000 inhabitants. This represents a congenial support to finance public–private
REC initiatives.
In anticipation of national regulations, the region of Piedmont adopted the Regional
Law no. 12 of 3 August 2018 on regional energy communities. This led to the develop-
ment of several CE initiatives in the region which can be considered pioneers in terms of
promoting RECs.
After the establishment of Art. 42bis, other regions created own regulatory frameworks
for energy communities by considering the specific local conditions. The Regional Council
of Apulia enacted the Resolution no. 1346 of 7 August 2020 which provides specific
guidelines and an enabling framework to the already existent Regional Law no. 45 of
9 August 2019 “Promotion of the institution of the energy communities”. According to
those regional laws, qualifying as an energy community requires the achievement of a
minimum annual share of self-consumed energy (70% for Piedmont and 60% for Apulia).
Following the examples of Piedmont and Apulia, also the region Liguria has approved
a law for the promotion of energy communities. The Regional Law n. 13 of 6 July 2020
aims at promoting self-consumption and distributed generation through the creation of
groups of public and private entities to produce, consume and store energy. Moreover,
the region Calabria has a law (Regional law no. 25 of 10 November 2020) that promotes
the establishment of RECs for the production, exchange, storage and sale of renewable
energy as well as self-consumption. Furthermore, it supports energy efficiency initiatives
contributing to reduce energy poverty and illegal power withdrawals. With Regional Law
no. 2 of 23 February 2022, Lombardia has set a favourable framework for the development
of RECs, with an initial allocation of 21.5 million Euros between 2022 and 2024. Other
regions, e.g., Veneto, Sardinia, Emilia Romagna are currently implementing regional legal
frameworks to promote energy communities.
Sustainability 2022,14, 7181 11 of 24
6. Discussion
6.1. Comparing the Context: Technology Assets, Type of Initiators and Legal Forms
In this section, we compare the status quo in the two countries according to a set
of criteria including the number of initiatives, technology assets, type of initiators and
legal forms.
In Germany, energy cooperatives represent the most common form of energy commu-
nities in the field of PV. In general, energy cooperatives tend to be small and local, with only
a few cases with several thousand members, typically engaged in electricity supply. These
local energy initiatives provide fruitful ground for the development of community storage
and integrated community-based concepts such as cross-sector coupling, e.g., power-to-
heat, virtual power plants, or microgrids [
]. Such approaches are in a nascent stage of
development. In contrast to other European countries such as the Netherlands, the cooper-
ative model is less common for wind farm operations. Community wind farms mostly use
the legal form of a limited partnership with a limited liability company as general partner.
CE projects are widespread, and the German CE landscape is fairly heterogeneous in terms
of initiators, supporting structures, geographical scale, size, technologies, involvement of
local authorities, legal forms and financing [23].
In Italy, energy communities are emerging in almost all regions, but so far just a few of
them are operating in accordance with the national framework pursuant to Art. 42bis. The
regions with a higher number of projects are Piedmont, Sardinia, and Apulia, also thanks
to regional laws that have supported their realization. Historical energy communities are
located in Northern Italy (Lombardy, Trentino Alto Adige). In the following, the main
indicators are summarised, based on the literature [76] and market surveys.
With regard to technology, PV dominates in new energy communities, while historical
cooperatives use a mix of technologies including PV, hydro, and biomass power plants.
Energy communities operating wind turbines have not been found so far, probably because
the plant sizes are generally above the initial capacity limits of the national legislation
(200 kW) and the Operation and Management (O&M) costs are generally higher than
PV plants. Storage facilities have been installed only in few communities so far but are
becoming more popular thanks to the current fiscal deductions and incentive. Typical
capacities are in the order of a few tens of kWh, generally less than 30 kWh. One factor
facilitating the emergence of RECs is the fact that Italy is one of the frontrunners regarding
the introduction of smart meters [15].
New energy communities pursuant to Art. 42bis are generally composed of a lim-
ited number of members, typically around twenty, with few exceptions approaching
100 members. By contrast, historical energy cooperatives count several thousand members.
As depicted in Figure 1, new REC projects are initiated mostly by municipalities
and private companies (above all SMEs), less frequently by public companies (e.g., social
housing companies) and associations. There are a few examples of RECs directly promoted
by research centres, while less common is the case where citizens are the first initiators.
Regarding the legal form, most of the RECs pursuant to Art. 42bis have been estab-
lished as nonprofit organizations or associations, reflecting the small size of the community.
Finally, the revenues gained by the electricity sold to the grid and the incentives for energy
sharing among members are primarily used to pay back the initial investment and then
distributed among members. Profits are used mainly to reduce electricity bills of the mem-
bers, to install new RES installations, social solidarity measures aimed specially to mitigate
energy poverty, and for local initiatives. Tables 1and 2provide an overview of the most
common legal forms in both countries.
6.2. Comparing RED II Transposition and Development of Enabling Frameworks
In this section we compare the transposition of key provisions of RED II concerning
RECs and the key elements of an enabling framework. The comparative assessment helps
to answer whether the provisions are suitably transposed into national law. We summarize
Sustainability 2022,14, 7181 12 of 24
the characteristics of the enabling frameworks that the governments of both countries are
providing to promote and facilitate the development of RECs under RED II.
Sustainability 2022, 14, x FOR PEER REVIEW 12 of 26
New energy communities pursuant to Art. 42bis are generally composed of a limited
number of members, typically around twenty, with few exceptions approaching 100
members. By contrast, historical energy cooperatives count several thousand members.
As depicted in Figure 1, new REC projects are initiated mostly by municipalities and
private companies (above all SMEs), less frequently by public companies (e.g., social
housing companies) and associations. There are a few examples of RECs directly
promoted by research centres, while less common is the case where citizens are the first
Figure 1. Initiators of renewable energy communities in Italy. Source: Authors’ elaboration based
on data from [76].
Regarding the legal form, most of the RECs pursuant to Art. 42bis have been
established as nonprofit organizations or associations, reflecting the small size of the
community. Finally, the revenues gained by the electricity sold to the grid and the
incentives for energy sharing among members are primarily used to pay back the initial
investment and then distributed among members. Profits are used mainly to reduce
electricity bills of the members, to install new RES installations, social solidarity measures
aimed specially to mitigate energy poverty, and for local initiatives. Tables 1 and 2 provide
an overview of the most common legal forms in both countries.
Table 1. Legal forms of renewable energy communities in Germany.
PV (Ground
PV (Rooftop)
Cooperatives + +++ + + +
Limited partnerships or
limited companies or
hybrid forms
+++ + +++ + ++
Civil law partnership + + +
Other legal forms + + + + +
+++ large experience; ++ medium experience; + selective experience, no experience.
Table 2. Legal forms of renewable energy communities in Italy.
PV (Ground
PV (Rooftop)
Figure 1.
Initiators of renewable energy communities in Italy. Source: Authors’ elaboration based on
data from [76].
Table 1. Legal forms of renewable energy communities in Germany.
PV (Ground
PV (Rooftop)
Cooperatives + +++ + + +
Limited partnerships
or limited companies
or hybrid forms
+++ + +++ + ++
Civil law partnership
Other legal forms + + + + +
+++ large experience; ++ medium experience; + selective experience, no experience.
Table 2. Legal forms of renewable energy communities in Italy.
PV (Ground
PV (Rooftop)
Cooperatives + +
Limited partnerships
or limited companies
or hybrid forms
+ + ++
Civil law partnership
+ ++ + ++
Other legal forms + +
++ medium experience; + selective experience, no experience.
A preliminary comparative assessment of the transposition process in the countries
represented in the COME RES project which was published in April 2021, suggested that
Italy, Belgium (Flanders) and Portugal are among the frontrunners in terms of transposing
the legal provisions for RECs, whereas Latvia, Poland and Germany made comparatively
little progress [
]. This finding has been supported by other comparative cross-country
assessments [
]. Referring to Germany and Italy, our analysis shows that at the point of
writing the paper (March 2022), the situation has not much changed (Table 3). So far, the
federal government in Germany has been reluctant to facilitate collective self-consumption
and energy sharing as required by the RED II. The findings of the stakeholder dialogues
and policy round tables performed in the frame of the German COME RES country desk
Sustainability 2022,14, 7181 13 of 24
suggest that a key concern is if too many people would switch to self-consumption, the
system costs (e.g., grid charges) would disproportionally increase the financial burden for
the remaining consumers [60].
Table 3. Key elements of the enabling frameworks for RECs (as of 31 March 2022).
Elements Germany Italy
Legal definition of RECs fully in
compliance with RED II No Yes
Final customers, in particular household
customers, entitled to participate
in a REC
In principle, yes, but so far RECs
have been insufficiently
legally codified
Yes, further provisions are
expected in future decrees.
RECs legally entitled to produce,
consume, store and sell renewable
energy and share, within the REC,
renewable energy that is produced
by the REC
Theoretically, but there is no
regulatory framework for
energy sharing
Assessment of barriers and drivers of
RECs carried out by national or any
regional government
No Partly
Removal of unjustified regulatory and
administrative barriers to RECs Partly
Partly, further provisions
are expected in
future decrees.
Cooperation of relevant DSO with RECs
to facilitate energy transfers
within RECs
No specific provisions Provisions are expected in
future decrees.
Fair, proportionate and transparent
procedures; cost-reflective network
charges; relevant charges, levies and
taxes to contribute in an adequate, fair
and balanced way, to the overall cost
sharing of the system (in line with a
transparent cost–benefit analysis
developed by the national
competent authorities)
Partly, no cost benefit
analysis existing Partly
Nondiscriminatory treatment of RECs
with regard to activities, rights and
obligations as final customers,
producers, suppliers, DSOs, or as other
market participants
Yes, in principle, detailed
provisions are expected in
future decrees.
Accessibility of RECs to all consumers,
including those in low-income or
vulnerable households
In principle yes, but no specific
provisions or incentives; conflicts
with social welfare legislation
Availability of tools to facilitate access to
finance and information
Access to finance available (e.g.,
low interest loans provided by the
publicly owned development
bank KfW); access to information
available but should be improved;
need of risk capital/
start up finance.
Partly (at regional level)
Regulatory and capacity-building
support provided to public authorities
in enabling and setting up RECs, and in
helping authorities to
participate directly
Only few federal states
(e.g., North Rhine Westphalia). Partly
Rules to secure equal and
non-discriminatory treatment of
consumers that participate in the REC
in place
No specific provisions No specific provisions
Consideration of RECs in support
scheme designs Partly (see below) Yes
Sustainability 2022,14, 7181 14 of 24
6.3. Comparing Support Schemes for Renewable Energy and Their Consideration of RECs
In this section, we compare to what extent the specificities of RECs are taken into
consideration when governments design support schemes for RES. We take a broader view
and also look at dedicated support measures specifically targeting RECs. Overall, various
financing sources for CE initiatives are available.
Although the German federal government introduced special privileges for com-
munity wind projects under the auction regime, current legislation failed to achieve its
intended effect. The example of Germany suggests that auctions need to be carefully
designed, implemented and evaluated in order to yield the intended results and avoid
unintended effects. In particular, the provision of risk capital, start-up financing and other
risk mitigation strategies for RECs would be crucial. As mentioned above, individual
federal states took measures to overcome this barrier, but the impact remained regionally
limited. However, the new federal government recently decided to exempt RECs below
certain capacity thresholds from the auctions.
In Italy, the type of the initiating actor(s) reflects the financing mechanisms to purchase
and install the RES power plants. Municipalities generally rely on public funds and
nonrefundable grants, while companies rely on equity, foundation funds or funds gained
from national or European research projects. The latter type of financing is mostly used by
research centres, which often benefit from EU research funding in cooperation with SMEs.
Social housing and private citizens rely on tax deductions, and there are a few cases where
crowdfunding has been used to finance RECs.
The already cited Decreto Rilancio (see Section 5.2.2) introduced the “Superbonus”,
new tax credits for improvements to Italian properties, recently extended to 31 December
2023. It qualifies seismic renovations, energy efficiency improvements and rooftop PV
installations attracting a tax credit amounting to 110% of the qualifying expenses ensuring
tax compliance in the local building industry. Tables 4and 5summarize the key findings of
our comparative research.
Table 4. General support schemes for RES and their consideration of RECs in comparison.
Elements Germany Italy
Quantitative policy targets
for RES in general
Yes, both on federal and state
level. The coalition agreement of
the new federal government sets a
target of 80% RES-based
electricity and 50% RES based
heating for 2030.
Yes, National Integrated
Energy-Climate Plan
(PNIEC): 30% RES coverage
of final gross energy
consumption for 2030
Key support schemes for
RES based electricity
Market premium based on
auctions for PV and wind energy
plants >750 kW, biomass/biogas
plants >150 kW; feed in
premiums for small scale PV;
low-interest loans and investment
grants provided by public
banks (e.g., KfW,
Landwirtschaftliche Rentenbank)
Auctions for big RES plants
(exceeding 1 MW), direct
incentives (subscription to
registers) for RES plants
below 1 MW, investment
grants, fiscal incentives,
favourable VAT regime, tax
credits for PV installation
costs, net metering scheme.
Consideration of RECs in
key support schemes for
RES based electricity
Reduced security deposits and
uniform pricing rule for citizens’
energy companies under the
auctions in the field
of wind energy
Investment grants, incentive
of 110 /MWh feed-in
premium for shared energy
in RECs, reimbursement of
part of network charges in
the bill, tax deductions (for
residential members)
Sustainability 2022,14, 7181 15 of 24
Table 5. Comparing dedicated support schemes for RECs.
Elements Germany Italy
Policy targets
Quantitative policy targets
for RECs No
Yes, the Recovery Plan (PNRR)
envisages 2 GW of RES
capacity to be installed by
RECs by 2026 in
municipalities below
5000 inhabitants.
Qualitative policy
targets for RECs
No explicit target, but
pursuant to §2 of the RESA
the “diversity of actors in
electricity generation from
RES should be preserved”.
Few federal states formulated
qualitative targets in their
energy strategies.
RECs are included in the
National Integrated Energy
and Climate Plan among the
initiatives that contribute to
the 30% RES coverage target
on the final gross energy
consumption for 2030.
Regulatory measures
Privileges for RECs in the
context of spatial planning No No
Privileges for RECs in project
approval/permitting No No
(Virtual) net metering No Yes
Economic and fiscal incentives
Specific investment grants Partly (federal states) Yes, in some regions
(e.g., Lombardia)
Funds providing
start up finance
In 2018, the state government
of Schleswig-Holstein has
established a revolving fund
providing risk capital for CE
initiatives in the start-up
phase. The government of
Thuringia plans to follow this
example. The new federal
government plans to set up a
similar fund at national level.
Regional funds
Low-interest loans specifically
for community energy
initiatives/RECs (e.g., lower
interest rates, longer
repayment periods or
extended grace periods)
Low interest loans and grants
provided by
Yes, PNRR provides 2.2 billion
Euro to support development
of RES installations by RECs
established in municipalities
below 5000 inhabitants (via
zero interest loans).
Fiscal incentives No specific provisions
Yes, 50% or 110% personal
income tax deductions for the
installations of PV plants for
residential customers.
Financial support for
energy sharing No
Yes, 110 /MWh feed-in
premium for shared energy
in RECs
Sustainability 2022,14, 7181 16 of 24
Table 5. Cont.
Elements Germany Italy
Technical assistance, capacity development
Information, advice Few federal states Advice, guidance, capacity
building through key national
(e.g., GSE, ENEA, RSE *)
Technical assistance Few federal states
Promotion of networks Few federal states Few regions
Institutional support,
centers, one stop shops, etc.
Few federal states (e.g.,
through energy agencies and
other intermediaries)
Yes, coordination centres in
some regions
Dedicated training for local
authorities and/or RECs Few federal states Yes
Dissemination of
good practices Few federal states Yes
R&D, experimentation,
regulatory sandboxes,
living labs etc.
Federal government and few
federal states Yes
* Gestore dei Servizi Energetici (GSE), Italian National Agency for New Technologies, Energy and Sustainable
Economic Development (ENEA), Ricerca sul Sistema Energetico (RSE).
6.4. Comparing Policy Instruments and Vertical Policy Coordination
This section analyses parallels and differences regarding policy instrumentation
and the extent to which policies and measures taken at the national level and at the
regional/local level reinforce (or inhibit) each other. The set-up of enabling frameworks for
RECs represents a multi-level governance task involving different levels of government
including the municipalities. Hence, the promotion of RECs encounters various policy
interlinkages with partly overlapping competences which need a considerable level of co-
ordination, in particular vertical coordination efforts involving different governance levels.
Market rules, definition of overall rights and duties of RECs, their roles and integration in
the overall energy market and RES support scheme design are usually tasks carried out by
the national government. Spatial planning and permitting are typical tasks performed by
subnational entities, partly based on national/federal, partly on regional/state legislation.
The same applies to ‘soft’ accompanying policy measures including the provision of infor-
mation, advice, capacity development, networking, etc. Often, regional/state governments
design complementary financial support measures to facilitate the development of RECs.
R&D activities, including experimental regulations and regulatory sandboxes, are typically
supported by national and subnational policy actors. Municipalities enjoy some degree
of autonomy, including certain financial autonomy and partly legal authority in planning
and approving RES facilities. There are various options for municipalities to support the
development of RECs [
]. They may act as initiators of or shareholders in a REC and
may purchase the energy produced by RECs. In their role as owners of land and property,
municipalities may provide suitable sites for RES facilities operated by RECs. They may
financially support RECs in the form of equity or by granting loans, or they can assist
by providing information, start-up financing, by building trust and provide legitimacy
to RECs. Table 6provides a comparative assessment of the different responsibilities for
designing and implementing an enabling framework for RECs.
Although one of the aims of the RESA under the auction scheme has been to preserve
the diversity of actors in electricity generation from RES, the previous governments in
Germany failed to operationalize and underpin this objective with a coherent and effective
set of promotional measures. As described above, the new auction system tilted the
playing field to the disadvantage of CE, particularly in the field of wind energy. With the
amendments to the Climate Change Act, the Merkel government enshrined the goal of
Sustainability 2022,14, 7181 17 of 24
achieving GHG neutrality by 2045. This and the full transposition of the RED II provisions
for RECs require considerable efforts and intensified collaboration between the federal
government and subnational levels of government. Although the new federal government
recently decided to exempt RECs below a certain capacity threshold from the auctions,
there is definitively a need to remove the manifold administrative barriers in the field of
planning and authorization. In any case, it is of utmost importance to amend the existing
legal definition of citizens’ energy companies in order to re-align it with the requirements
of the RED II and at the same to ensure avoidance of misuse. Furthermore, energy sharing
and collective self-consumption within buildings need to be facilitated. This should be
combined with accompanying measures enhancing experimentation, capacity building and
institutional support through intermediaries such as regional and local energy agencies [
Here the federal states, regions and municipalities have a fundamental role to play. Austria
provides a useful model case where the federal government has established an official
coordinating body offering administrative support and guiding the establishment of energy
communities on a national as well as on a federal province level [5].
Table 6. Elements of the enabling frameworks for RECs and respective responsibilities.
Elements Germany Italy
Assessment of barriers and
drivers for RECs
Federal government,
state governments National government
Foundation/setup of RECs
Nondiscriminatory participation
of households Federal government National government
Nondiscriminatory participation of
low-income/vulnerable households
Federal government National government
Defining rights and duties of RECs Federal government National government
Market activities of RECs
Access to financing, provision of
start-up financing, risk capital, low
interest loans etc.
Federal government, state
governments, public funds
(e.g., community
energy funds)
National government,
regional governments,
private foundations
Other economic incentives (fiscal
incentives etc.)
Federal government,
state governments National government
Spatial planning/siting of
RES facilities
Federal government,
state governments,
regional planning
bodies, municipalities
National government,
regional government,
Approval/authorization of
RES facilities
Federal government,
state governments,
districts, municipalities
National government
Regional government,
Information provision, advise State governments,
districts, municipalities
National government
Regional government,
Institutional support, REC
competence/coordination centers,
one stop shops, networking
Federal government,
state governments,
districts, municipalities
National government
Regional government,
Technical assistance, capacity
development for local
authorities and RECs
Federal government,
state governments,
districts, municipalities
National government
Regional government,
R&D, experimentation, regulatory
sandboxes, living labs, etc.
Federal government,
state governments,
districts, municipalities
National government
Regional government,
Sustainability 2022,14, 7181 18 of 24
Table 6. Cont.
Elements Germany Italy
Consideration of RECs in support
schemes for RES (investment
support, operational support)
Federal government,
state governments
National government
Regional governments
Dedicated support schemes
for RECs
Federal government,
state governments
National government
Regional governments
In the past, there has been strong criticism from both science [
] and practice [
lamenting the insufficient vertical coordination between the federal and the state level in
the area of the German energy transition. With its latest amendments to the RESA in 2021,
already the previous federal government responded to this criticism and took promising
measures to institutionalise cooperation between the federal and state governments by
establishing a new cooperation committee (Bund-Länder-Kooperationsausschuss). In its
coalition agreement, the new federal government committed itself to further strengthen
this cooperation between the federal government, the states and municipalities to achieve
the accelerated expansion of RES [
]. This committee has currently a focus on re-aligning
federal and state expansion targets for RES and on the removal of administrative barriers
in the field of spatial planning and project authorisation, which can be regarded as an
important step towards the creation of a more effective enabling framework for RECs. It is
unclear yet to what extent the competences of this committee might be expanded in the
future to address other important elements of an enabling framework including market
design reform, financial support or capacity development.
Whereas, in Germany, political support for CE initiatives on the federal level has
decreased in recent years, Italy has enacted a set of promising and mutually reinforcing
policy measures and incentives. The recent Legislative Decree nr. 199/2021 provides a
direct incentive for newly installed RES plants up to 1 MWp owned by RECs and collective
self-consumers, who are exempted from auctions. In general, auctions are required only for
RES plants exceeding 1 MWp. Pursuant to this decree, the extension of the maximum size
of a RES plant from 200 kWp to 1 MWp to access the incentive for shared energy in RECs,
and the possibility of consumers and prosumers to stay connected to the low and medium
voltage grid and to the same HV/MV primary substation has considerably increased the
potential participation perimeter of RECs and the number and type of customers that can
join energy communities. Moreover, the decree has simplified authorisation procedures for
the installation of PV plants up to 50 kWp and also for larger plants. So far, dispositions of
Legislative Decree no. 199/2021 still require a set of implementing Ministerial Decrees and
Resolutions of the National Energy Authority expected in the next months. Only after their
promulgation issue will the legislative framework be definitive and clear. Nevertheless,
based on provisions of Legislative Decree no. 199, in Italy, RECs are expected to increase
both in number and size in the coming years.
7. Conclusions
7.1. Lessons Learned
Creating enabling frameworks in line with the EU intentions calls for systematic,
comprehensive and coherent policy approaches which need to address both the setup
of RECs and their integration in the energy market. Hence, the creation of enabling
frameworks has to embrace a broad spectrum of issues, such as inclusiveness of RECs and
new market activities, planning and authorisation procedures, support schemes, overall
market design and integration. These developments are unfolding both in Germany and in
Italy against the background of a policy framework still characterised by path dependencies
and a heavy reliance on fossil fuels—a fact that became particularly clear in the aftermath
of the invasion of the Ukraine—and a still high influence of market incumbents. Although
CE development is generally more advanced in Germany, transposition of the RED II
Sustainability 2022,14, 7181 19 of 24
provisions is slow and incomplete. The stakeholder dialogue conducted in Germany in
the framework of the project COME RES pointed out several implementation deficits,
some of which are of structural nature (e.g., the role of the DSOs) or are historically
determined (a pre-existing definition of community energy before the RED II inception)
or are of political nature (e.g., distributional fairness considerations, new market design
for electricity). In Italy, by converse, the findings of the stakeholder dialogue confirmed
that lacking regulations and a previous definition for community energy helped the RED
II to play a catalyst role for the planning and implementation of CE initiatives. In our
comparison of the two countries, we found many similarities but also striking differences.
Important parallels are listed as follows:
Both countries have deep roots and traditions of energy cooperatives which played a
key role in the rural electrification in the beginning of the 20th century.
Both countries have a federal or quasi-federal political system which requires intensive
vertical and horizontal policy coordination efforts.
Regions/municipalities enjoy political and a certain financial autonomy. These actors
have partly taken up a pioneer role regarding the promotion of RECs.
The development of CE initiatives in both countries has been facilitated by supportive
policies based on a wide range of incentives and a remarkable reduction in technology
costs. However, the discontinuation of price-based support schemes led to a slump in
new RES installed capacity and investments [83].
On the other hand, several differences were noticeable, particularly in the following areas:
The sectoral focus of RECs and corresponding political support in Italy is mainly
on PV. RECs are primarily organised around the legal form of nonrecognised asso-
ciations. In Germany, by contrast, cooperatives dominate in the PV sector, whereas
hybrids of limited companies and partnerships are the preferred form for community
wind farms.
Germany experienced a highly dynamic development of modern CE initiatives in-
cluding energy cooperatives, particularly between 2006 and 2013 due to a supportive
legal and policy framework. However, due to the instrumental shift characterised by
auctions for large PV, wind and biogas and the phase-out of feed-in tariffs/premiums
for the development of CE lost momentum. On top of that, there have been policy
design failures that led to misuse by commercial developers and ended up discrediting
the concept of CE. RECs have been increasingly “kept in quarantine” [84].
Whilst in Italy the combination of pro-active regional governments with strong political
commitment and a partly pro-active national government led to the design of support
schemes that created a wide interest in developing RECs, in Germany there has been
hardly a strategic and coherent planning approach towards RECs in the recent years,
and the levels of “transformative vision” and “directionality” [
] have been poor.
The governments under Angela Merkel showed low political commitment to advance
CE, and policy development was guided by a market-based rationale rather than by
the energy related and socio-economic benefits of CE. In Italy instead, elements of an
effective enabling framework have started to take shape two years ago, before the full
transposition of RED II.
RED II has delivered new stimuli to the development of RECs, but the transposition
dynamics and their effects are different in the two countries analysed. Although the
previous federal government in Germany took measures to consider the specificities
of community wind energy initiatives in support scheme design, these measures were
not effective in compensating for the structural disadvantages RECs are facing in
auctions. Moreover, the past government has been reluctant to facilitate collective
self-consumption and energy sharing as required by the RED II. On the other side,
there have been several promising and innovative initiatives from the subnational
level. The RED II transposition has been distinctly more dynamic than in Germany
where the negligent transposition hindered a new lease of life for REC development.
Sustainability 2022,14, 7181 20 of 24
However, there are clear indications that the creation of an enabling framework is
gaining momentum under the new federal government.
From our two-country comparison, we can distill a number of lessons for policy. The
implementation of enabling frameworks is advancing in both countries, albeit with different
pace and political support. However, in both countries, administrative bottlenecks in
planning and authorization processes remain serious barriers for the mainstreaming of CE
in general and RECs in particular. Therefore, both countries need to enhance coordination
between national and regional governments. Moreover, in this early stage of the RED
II transposition at the national level, it is not possible to detect multi-level dynamics
that reinforced each other over time and resulted in more ambitious policy outcomes.
In Italy, there has been a certain activism of regional and local governments that has
encouraged positive practices in terms of local energy strategies for enhancing renewables,
including RECs. However, so far, the existing interdependencies between policy making at
regional and national levels and the lack in coordination mechanisms have failed to give
life to a ‘multi-level reinforcement’ that helped in compensating for the lack of efforts at
a certain level of governance. Overall, a widespread uptake of RECs requires structural
adjustments of the governance system of both countries. A more coherent and strategic
approach is required, particularly in Germany. In Italy, existing mechanisms for vertical
coordination have proved to be barely effective. Moreover, because of the persistence of
different incentives at different levels and the formal and informal mechanisms for vertical
intergovernmental coordination, there is still an urgent need for coherence and effectiveness
for those policies that involve several actors at different territorial scales [
]. Therefore,
political engagement remains crucial. Whereas in Italy political commitment found new
momentum with the National Recovery and Resilience Plan which may represent a major
driver for the enhancement of RECs, in Germany there are indications that the new federal
government aims to improve vertical policy coordination and to streamline and accelerate
planning and approval procedures in cooperation with the Länder. It is too early to
assess whether and to what extent coordination efforts will be enhanced. It would be
commendable to broaden the focus of this committee to address other important elements
of an enabling framework for RECs, such as re-shaping market design to enable energy
sharing and collective self-consumption, financial support or capacity development.
7.2. Implications and Fields for Further Research
This article has tried to contribute to the understanding of complex regulatory and
legal challenges influencing the mainstreaming of community energy in two similar,
but—as we have seen—to some extent also different countries. Innovative bottom-up
approaches involving local actors in both countries helped to foster a positive link between
acceptance of (renewable) energy projects and decentralised local activities, yet more than
the social and acceptance barriers, it is rather the still existing regulatory challenges that risk
to curb the process and the development of RECs. In both countries, structural adjustments
to the governance system are taking place, but a number of structures and regulations
are still being defined. Therefore, it is not clear yet what governance architecture is to be
pursued and which will ultimately emerge in order to accommodate the changes brought
about by RECs. Further research is needed on the effectiveness of different policy instru-
ments that governments employ to support RECs [
] and on how interactive dynamics
in systems of multi-level governance can trigger positive policy feedbacks that increase
support for the policy and its effectiveness. Multi-level reinforcing dynamics enable us to
explain a policy change on the basis of interdependencies between policymaking on the
European, and regional levels. Moreover, ‘multi-level reinforcement’ can compensate for
the lack of resources at a certain level of governance as interested political actors can anchor
their policy preferences and ambitions at another level [
]. It would be interesting
to detect and monitor both those reinforcing dynamics that have contributed to foster
the German and Italian energy transition and those negative policy feedbacks hindering
the process [
]. Finally, an interesting research avenue could involve the analysis of the
Sustainability 2022,14, 7181 21 of 24
consistency, coherence and synchronisation of policy development when designing the
enabling frameworks for RECs.
Author Contributions:
Conceptualization, M.K., M.R.D.N., M.C. and E.D.L.; theoretical framework,
M.R.D.N. and M.K.; methodology, M.K. and M.R.D.N.; validation, all authors; formal analysis, all au-
thors; investigation, all authors; resources, all authors; writing—original draft preparation, M.K. and
M.R.D.N.; writing—review and editing, all authors; supervision, M.R.D.N.; project administration,
M.R.D.N. and M.K.; funding acquisition, M.K. and M.R.D.N. All authors have read and agreed to the
published version of the manuscript.
This research was funded as part of the project COME RES (“Community Energy for
the uptake of RES in the electricity sector”) under the European Union’s Horizon 2020 research
and innovation program, Grant Agreement 953040. We acknowledge support by the Open Access
Publication Fund of the Freie Universität Berlin.
Institutional Review Board Statement: Not applicable.
Informed Consent Statement:
Informed consent was obtained from all subjects involved in the study.
Data Availability Statement:
The data presented in this study are available on request from the
corresponding author. The data are not publicly available due to privacy restrictions.
We thank three anonymous reviewers for providing helpful feedback. Special
thanks go to Helena Michalke for her technical support.
Conflicts of Interest: The authors declare no conflict of interest.
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... Energy communities loom large as a key player in the energy transition program outlined by the European community [1]. They attract private sector investment and contribute to the public acceptance of energy projects which, in the long term, will allow for taking advantage of renewable resources. ...
... The number of energy cooperatives in Austria, Germany, Great Britain, and Denmark[1]. ...
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Renewable energy communities, first outlined in the European Directives and recently transposed into the Italian regulatory framework, are introduced as innovative entities capable of fostering cooperation between active and passive users involved in the production, sharing, and use of locally produced energy according to innovative management schemes. Renewable energy communities empower the end-customers. Citizens and legal entities are committed to a rational and economical use of energy to achieve the community’s climate neutrality goals and pursue the ecological and energy transition objectives defined in the national recovery and resilience plan. In the future, a significant number of energy communities different actors participating from the residential, industrial, commercial, and tertiary sectors are expected to develop within city districts or in suburban settings. This paper proposes and develops a methodology capable of bridging the complexity that can characterise the prototyping, implementation, and management of an energy community within a positive energy district. The approach presented here can also be extended to other application contexts in urban or rural settings. Requirements and best practices for administrative, technical, and technological management have been identified to achieve this goal. Italy is one of the first states to embed in its regulatory framework the European Directives regarding renewable energy communities. These will have a significant impact on network management models and will provide new ways for creating social inclusion that may help achieve climate sustainability goals. A governance model has been formalised for the empowerment of energy community members, outlining a framework useful for planning the proper implementation of a renewable energy community according to current Italian regulations.
... However, realizing such visions requires targeted support for local solutions and place-based strategies (see also Section 4.4), because each region has different conditions for different types of renewable energy in terms of availability and negative impacts on residents and the environment. In this context, renewable energy communities play an important role in the transition from centralized power plants towards a more distributed energy production [77]. ...
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Rural areas in Europe have been undergoing structural change for years, resulting in strong functional differentiation and fragmentation into prosperous and structurally weak areas. Rural areas are as diverse as the challenges they face. Not only various megatrends but also social, economic, technological, ecological, and political trends influence and shape the development of rural areas. In order to understand the problems and causes of the current development of rural areas, this paper provides a differentiated trend analysis for rural areas at the European level. A content analysis of more than 70 EU-funded project reports on rural areas and rural development is carried out. The aim is to identify trends and their drivers over the last decade and to summarize opportunities and challenges for successful rural regeneration. These external and overarching trends, particularly in the context of a sustainable transition, renewable energies, the emergence of new technologies and growing awareness of environmental impacts, offer rural areas more opportunities than ever before. The interplay between external incentives (e.g., European Union policies) and endogenous regional development (e.g., local actors) is crucial for the successful exploitation of these opportunities for rural regeneration.
... The impact of the RED II has been, for example, particularly strong in Italy and its transposition encouraged the foundation and growth of ECs. The contrasting development in Germany highlights the strong influence of regulation and governance structures on ECs' growth (Krug et al., 2022). A key barrier to the development of ECs is uncertainty of citizens about new projects. ...
... An LEC can be, for example, formed by different parties living in the same building or by multiple households in a neighborhood. With the revised renewable energy directive (RED II) from 2018 and the internal electricity market directive (IEMD) from 2019, the European Union (EU) established a legal framework for LECs [2]. In 2022, the EU launched the Energy Communities Repository initiative for supporting the setup of LECs [3]. ...
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The concept of local energy communities is receiving increasing attention. However, the question of how to distribute the benefit of a community among its members is still open. It is commonly desired that the benefit distribution is fair and stable. While benefit distribution schemes such as the nucleolus, Shapley value and Shapley-core are known to perform well in terms of fairness and stability, studies have shown that none of them can guarantee full fairness and stability at the same time. However, the existing studies neglect the temporal component. Hence, in order to gain more insights into the stability and fairness of the three aforementioned distributions in practice, we investigate their performance over time in simulation experiments on real-world data from Australian households. In about 90% of the cases, the Shapley value yielded a reasonably stable distribution, while the nucleolus yielded a reasonably fair distribution in about 75% of the cases. Furthermore, the experiments show an impact of the community size on the stability and fairness of the investigated distributions. One can conclude that for small communities, the Shapley value is the best choice, but that the nucleolus and Shapley–core become more and more attractive with increasing size of the community.
... However, as of 2013, the feed-in benefits are no longer available, and there is now stagnation of new projects. A public investment portfolio that includes regional development of renewables and promotes strengthened partnership across government layers can enhance multi-lever governance (S5) [94], which may in turn promote a decentralised power system (S14) and support energy communities (S15) [95] by easing planning and authorisation procedures, engaging with local actors, and promoting knowledge transfer via one stop-shops [96]. From a regulatory reform perspective, such a strategy can also enhance capacity for multi-level governance (S5) [97] and align targets and actions across regions [98]. ...
... ECs provide a unique combination of impact that is relevant for the EU's combined objectives, namely increasing security of energy supply, reducing energy consumption, decentralising the grid infrastructure, and providing environmental and social benefits which hit on climate targets. 158 ECs also arguably provide capacity building for a new, green workforce. Given the ambitions of the EU budget are to create a just, sustainable transition, there is a unique opportunity to shed light on the role that ECs can play in this new world. ...
... Moreover, it can enhance human participation in and awareness of the energy system, guarantee inclusiveness, and have a long-term positive impact [6]. Nevertheless, national and local policies are the main factors responsible for properly implementing the RECs in their own countries, since these must transpose the EU directives into national and local regulatory frameworks [7]. In light of this, this work analyzes two EU Member States that nowadays present significant differences in the RED II transposition state concerning the ECs: Italy and the Netherlands, defined as "laggard" and "early adopter" or "pioneer" countries, respectively. ...
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Energy communities are a promising strategy for a global energy transition. European Union (EU) regulatory frameworks are already established and clearly explained, aiming to develop as many projects as possible in the different European countries. Accordingly, it is necessary to present two different types of countries: the laggards and the pioneers, two categories that highlight the discrepancies in policy, bureaucracy, culture, and usage of alternative sources and technologies, such as renewable energy, towards the implementation of energy communities. This work compares two representative case studies to qualitatively understand the differences between laggard and pioneer countries: Italy