French regulator proposes tightening up controversial carbon footprint rules


The French Energy Regulatory Commission (CRE) has proposed tightening the divisive carbon footprint rules applied to solar power project development.

The suggestion was made in a report highlighting how the cost of building large-scale solar projects in France has fallen around 32% in three years.

To be eligible to compete in French public tenders, utility-scale PV projects must use components that comply with rules requiring certified low carbon manufacturing processes.

Although the rule has been criticized in some quarters as a back door local content requirement favoring domestic module suppliers, notable Far Eastern module manufacturers have so far secured certification of compliance for their products, with others now in the process of being certified.

The true price of shipping modules

The regulator has mooted the idea of including a review of the carbon footprint methodology to include aspects such as transport all along the module supply chain – a change which would again make life difficult for non-European PV manufacturers.

“More broadly, a reflection to include in particular the carbon footprint of transport should be launched, in a context where supply chains are increasingly segmented and globalized,” the CRE report states. “Beyond the single carbon footprint, the reflection should be extended to the other environmental aspects by assessing the relevance of taking into account in this notation the differentiated impact of the extraction conditions of the different materials entering, even in small proportions, in the composition of modules.”

The proposal emerged on a day when the South Korean government suggested similar plans to factor carbon footprints into eligibility rules for PV project development.

Projects for €600/kW installed

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The suggestion came after the CRE revealed headline figures about falling solar project development costs. The report stated average investment costs in France have fallen to around €800 per kilowatt installed for ground-mounted solar and €1,100/kW for installations on buildings and carports. “The cheapest utility-scale PV projects are now approaching a cost of €600 per kilowatt installed,” the authors of the study added.

The CRE analysis states the average production cost of solar power – calculated from recent CRE4 tenders for utility-scale PV – ranges from €62-99/MWh depending on size and type. The regulator added, approximately 30% of the most competitive large-scale ground-mounted projects – whose size limit for eligibility for public tenders has been increased from 17 MW to 30 MW – now have production costs of around €48/MWh.

“These levels are comparable to the full costs of production observed abroad,” stated the CRE report. “In Germany, the levels presented in the March 2018 report of the Fraunhofer ISE were between €40 and €70/MWh for large-scale photovoltaic plants. In the United States, the full cost of large, ground-based power plants is now between €35 and €40/MWh.”


Those costs, says the CRE, are close to or below current market prices for electricity in France. “This situation is likely to allow the projects concerned to develop without public support, as has been observed in other European countries,” the report stated.

Reacting to solar tenders which have been less successful than envisaged, the CRE has recommended examining the reasons for under-performance and revisiting aspects such as the volume and frequency of PV tenders.

The regulator also said tender rules prioritizing projects on degraded land mainly favor the north of the country, where more brownfield sites are located, whereas the sunnier south has more potential for large-scale, ground-mounted projects.

The CRE is recommending again raising the size limit for projects eligible for tenders, this time to 100 MW. “This will re-balance the installed power between the regions; in addition, it will enable larger and less expensive projects to be developed by avoiding any conflicts of use,” the report said.

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