Comparative Analysis of Green Electricity Promotion Strategies in Germany and Türkiye

While Germany and Türkiye differ from each other in a number of areas, including geography, economy, politics, and law, this article makes the case that it is nevertheless beneficial to absorb and use each other's best practices. It recommends that their individual energy transitions include carbon price plans, competitive and tariff aspects, and both. Nevertheless, the book highlights that regional and worldwide cooperation is required to effectively combat climate change; local energy changes alone would not be sufficient. Although essential, EU collaboration is not sufficient. For this reason, the proposal promotes "climate and energy partnerships" with countries in Eastern Europe, the Middle East, and North Africa in addition to EU members. That is why it is advised that Germany and Türkiye form just such a collaboration.

The Case of Germany

Gaining an understanding of Germany's energy sector's legislative framework is essential to understanding its support of green electricity programs. The groundwork is laid by the German Basic Law (Grundgesetz), which protects the right to life and bodily integrity, including the right to energy access. One such provision is Article 2(2). Germany is obligated to provide inexpensive energy provisions as a social state, as stated in Article 20(1). Additionally, Article 20a mandates environmental preservation, which may have an impact on energy policies. The legislative authority of the federal and state governments over economic issues, including energy, is delineated in Articles 28(2), 74(1)(11), and 72.[1]

The Federal Constitutional Court does not classify the energy industry as an administrative monopoly, but it has highlighted the need of energy supply for a dignified living. Energy was regulated in the past by laws such as the Energy Industry Act of 1935, which prepared the ground for later liberalization initiatives spearheaded by EU regulations in the 1990s. The 1998 Energy Industry Act and its ensuing revisions focused on market transparency, competition, and unbundling.[2]

Further unbundling was enforced in 2009 by the EU's Third Energy Package, which resulted in the German Energy Package of 2011.[3] This package prioritized updating the energy grid, increasing renewable energy sources, and phasing out nuclear energy. Germany's energy constitution, established by the Energy Industry Act of 2011, placed a premium on safe, cheap, and ecologically sustainable electricity. It also made German regulations compliant with EU law.[4]

Energy-related matters are supervised by federal agencies, chiefly the Federal Ministry for Economic Affairs and Climate Action and the Federal Network Agency. Local energy concerns are handled by state regulatory authorities, although market development has varied the sources and uses of electricity. Through organizations such as the European Energy Exchange (EEX), the liberalized market promotes renewable solutions for customers. Energy regulations and climate legislation are intertwined; emissions from energy installations are governed by the Federal Emission Control Act.[5]

Acts such as the Energy Line Expansion Act and the Grid Expansion Acceleration Act have legislated grid expansion planning, particularly with the move away from coal and nuclear power. The integration of renewable sources and grid reliability are the goals of these initiatives.[6]

The energy transition is significantly aided by German planning law, however there may be delays. In the more competitive generation sector, grid planning is the domain of federal organizations. Germany's energy sector strives for efficiency and innovation through regulatory competition, despite regulatory constraints. To support its green electricity projects, Germany's energy law essentially combines national and EU legislation, placing a strong emphasis on competitiveness, sustainability, and system modernization.

The Case of Türkiye

The legislative structure and regulatory environment of Türkiye are deeply entwined with the legal underpinnings of the nation's green electricity promotion. Gaining an understanding of Türkiye's legal framework and how it conforms to EU criteria is essential to appreciating the background of different promotion programs. Let us examine the salient features of Türkiye's regulatory apparatus, legislative framework, and the constitutional provisions that oversee the energy industry.[7]

Türkiye's legal system has always been centralized, with a large amount of authority held by the Ankara-based central government. The capital often issues directives that are implemented locally, with designated province governors acting as local delegates. Türkiye's legislative landscape is influenced by its continuous "Europeanization" process, which is driven by its EU admission negotiations, despite its centralized structure. The EU is pressuring Türkiye to harmonize its laws with EU standards in a number of areas, including the energy sector.[8]

Under the EU-Türkiye Association Council's supervision, Türkiye's laws must be periodically brought into compliance with EU standards as required by the EU-Türkiye Customs Union Agreement. EU legislation and policy, despite occasional adoption gaps, have a big impact on Türkiye and result in reforms that follow EU guidelines, particularly when it comes to promoting green energy. Several authorities in the energy sector are empowered under the Turkish legal system. The Ministry of Environment and Natural Resources, as well as the Ministry of Energy and Natural Resources, are important agencies that work closely with the Presidency to develop and carry out energy policy. In order to safeguard consumers and maintain market competition, the Energy Market Regulatory Authority (EPDK) supervises the energy industry.[9]

As Türkiye's energy sector transitioned from a state monopoly to partial privatization, a number of state-owned and private businesses emerged. The framework for market liberalization and private sector engagement was established by the Electricity Market Law of 2001 (EPK 2001) and its revisions, most notably EPK 2013. A licensing system for a number of roles in the electricity market was implemented by EPK 2013 in order to promote competition and private investment.[10]

The allowance for unlicensed generation, which enables smaller investors to take part in green energy projects with less red tape, is one important feature of EPK 2013. In order to guarantee equitable access to the grid for renewable energy projects, the law also requires auctions for new grid connection capacity. The energy industry is indirectly governed by constitutional articles such as the state's control over natural resources and the right to a healthy environment. Türkiye's energy sector has also evolved throughout time due to laws like the TEK Act and EPK 2001, which place a strong emphasis on privatization and market liberalization.[11]

All things considered, Türkiye's green electricity promotion legislation strikes a balance between private sector involvement, EU alignment, and centralized governance. Through comprehension of these legal underpinnings and regulatory frameworks, interested parties can effectively traverse Türkiye's energy market and promote sustainable expansion in the production of green electricity.[12]

Examining Policies, Challenges, and Future Prospects in Comparison

Due to the distinct political, economic, and environmental settings of Germany and Türkiye, there are notable disparities between the two countries' approaches to the promotion of green electricity. Nevertheless, in spite of these differences, both nations have the chance to benefit from one another's experiences and take up "best practices" in order to progress their respective energy transitions. First, in terms of the constitution, neither Germany nor Türkiye have clear-cut provisions that support the development of green electricity. Nonetheless, as social states, both nations are dedicated to protecting the environment, with accessible and reasonably priced energy being essential components. Both countries have been able to pursue policies that support green electricity since there are no constitutional impediments; nevertheless, Germany has advanced more than Türkiye because of its coal phase-out strategy.

Both nations are bound by a number of international accords, including the Paris Agreement and EU state aid rules. Türkiye's compliance is impacted by its status as an EU candidate, whereas Germany is subject to harsher sanctions because of its membership in the EU. Due to differing duties, Germany relies more on transmission system operators than Türkiye does, which raises questions about state control and distorted competition. This has an impact on their advertising plans.

In addition, Germany is subject to more scrutiny under WTO law than Türkiye since it is a worldwide trade power. This has an impact on how each country handles the growth of green industries; Germany is more circumspect because of possible WTO issues. Türkiye, on the other hand, has taken steps to more actively encourage its green industry. In terms of domestic government, Germany's federal system differs from Türkiye's highly centralized one in terms of energy promotion and control. Although the regulatory agencies in Germany and Türkiye are comparable in their oversight of the development of green electricity, Germany's federal limits make policy execution more difficult than in Türkiye, which takes a more centralized approach.

Germany has transitioned from feed-in tariffs to bidding processes in terms of promotion schemes, whilst Türkiye still mostly uses feed-in prices with minimal tendering. Türkiye should take note of Germany's shift to market-oriented procedures in order to improve its marketing strategies and lessen the cost to consumers. The two nations differ in their approaches to regional development, systems of segmentation, and allowances for combined heat and power installations, which are indicative of their distinct capacities and priorities. In order to support the integration of green electricity, both countries also provide grid-related assurances, albeit within the limitations of their own regulatory regimes. Germany and Türkiye have different approaches to energy accessibility and affordability. Germany provides subsidies to enterprises that use a lot of energy, whereas Türkiye uses tariffs to directly control the price of electricity.

Conclusion

There are chances for mutual learning and cooperation even though Germany and Türkiye have different strategies for boosting green electricity. By learning from one another's experiences, both nations may improve their marketing campaigns and make more meaningful contributions to the worldwide fight to tackle climate change. As suggested, forming energy and climate partnerships at the regional and global levels could hasten their shift to sustainable energy systems.