Buying  Vattenfall’s lignite business could be a risky bet

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Jänschwalde (photo Michael Lehmann, 2013)

Jänschwalde (photo Michael Lehmann, 2013)

Vattenfall is currently looking for a buyer for its German lignite assets. However, any potential investor faces a high risk that they will find themselves forced to wind down the business before earning back their investment, write Julian Schwartzkopff and Sabrina Schulz of international environmental organisation E3G. In this article, a shortened version of their new report Vattenfall’s Lignite Business – a Risky Bet for Investors, they explain why the future of Vattenfall’s lignite activities and the German lignite sector in general looks bleak.

Vattenfall announced its intention to divest its German lignite business back in October 2014, in order to improve its CO2 emissions performance. On 22 September 2015, the company formally opened the bidding process, which closes on 22 December. The portfolio for sale includes the lignite-fired power plants Jänschwalde, Boxberg, Lippendorf and Schwarze Pumpe, along with the associated opencast mines as well as ten hydropower plants located close to the lignite plants. So far, German utility Steag, as well as Czech companies EPH, ČEZ and Czech Coal are known to have submitted bids.[1]

However, the deal is riskier than it might look. With its half-year report for 2015, Vattenfall already announced a write-down of €1.9bn (SEK 17.8bn) on its lignite power plants and mines due to “poorer production margins […] and higher business risk”.[2] This massive write-down was conducted in response to regulatory developments, i.e. the energy transition putting pressure on profit margins, an updated plan for recultivation of lignite mines, as well as the German government’s first legislative moves against lignite. This illustrates the considerable effect that the regulatory framework has on the value of lignite assets.

While the devaluation might make the sale seem like an attractive business opportunity, it is unlikely that it took into account the full extent of the risks relating to lignite power generation in Germany today. Consultancy Energy Brainpool in October 2015 published an economic analyis of the lignite business on offer and determined its net present value at €468m.[3] This assessment was based on parameters specified by Greenpeace, including plant closure dates to 2030 and a sharp rise in CO2 prices, representing a low-end estimate of the value of the portfolio, essentially putting a number on what it would be worth with a foreseeable increase in climate policy ambition. An analyst at Landesbank Baden-Württemberg estimated the value of the business at €2-3bn.[4] This represents a high-end estimate based on the current economic and political situation.

protest against Vattenfall in Hamburg, August 2015 (photo Robin Wood)

protest against Vattenfall in Hamburg, August 2015 (photo Robin Wood)

However, several factors are working against the long-term profitability of the lignite business. Indeed, the situation looks worse than last year, when a report by the German Institute for Economic Research already highlighted serious risks to Vattenfall’s lignite portfolio.[5] ‘Business as usual’ will not be a good guide to the future as Germany’s energy transition progresses, moving away from coal and fundamentally reinventing the electricity market along the way. Below we describe three major risk categories for potential buyers: political, economic and legal risks.

Political Risks

1) European and domestic climate commitments require a lignite phase-out

Germany has adopted a commitment to remove CO2 emissions from its economy almost completely by 2050.[6] The country aims for an emissions reduction of 80-95% compared to 1990 by 2050. The EU has adopted the same goal in its Energy Roadmap 2050.[7] According to a number of studies, Germany needs to phase out coal by 2040 at the latest to achieve this, with lignite going even earlier.[8] This is because the mitigation potentials in other sectors such as transport, industry or agriculture are either limited or very costly. This means that there is a significant risk that any new investments into coal power generation from now on will be unable to recoup their costs and essentially become stranded assets.

Table 1 gives an overview of Germany’s various energy and climate targets.

Table 1: Overview of Germany’s climate and energy targets

Vattenfall table 1

Source: DIW (2014) Gestaltungsoptionen im Rahmen des Braunkohleausstiegs

These goals are unanimously supported by all major and minor parties in Germany.

Figure 1 shows graphically what Germany’s climate targets mean for its emissions balance over time. As can be seen, the targets leave very little room for lignite beyond 2030. Assuming a linear reduction trajectory, current lignite emissions would equal all of the permissible power sector emissions by around 2035. Considering that Germany plans to rely increasingly on gas-powered electricity generation to complement renewables, it is clear that lignite will have to be phased out substantially before this date.

Figure 1: German power sector CO2 emissions and reduction pathway

Vattenfall figure 1

Source: Institute for Applied Ecology presentation at parliamentary hearing on 15/09/2015, based on official data

2) The German lignite phase-out has already started

Apart from Germany’s ambitious climate targets which will impact the future value of any lignite investments, the regulatory and political context for lignite has become decidedly more unfavourable in 2015. The government in late October adopted a package of measures where 2.7 GW of lignite capacity will be put into a “climate reserve” in four chunks of 900 MW per year between 2017 and 2020.[9] The lignite units will receive compensation for staying on standby to provide backup capacity and will be shut down after four years. This will also affect Vattenfall’s power plants. Two Jänschwalde lignite units will be transferred into the reserve in 2018 and 2019 to be be shut down in 2022 and 2023.[10]

This decision marks the first time that the German government has explicitly legislated to reduce lignite power generation. The political battle around the measures has fuelled the German debate on a coal phase-out. It showed that there is practically no disagreement about the necessity of transitioning out of coal and lignite in particular. Differences in opinion only relate to whether to do it sooner or later. During and after this year’s debate, several influential voices have publicly stated their positions: [11]

  • German Environment Minister Barbara Hendricks (SPD) has been calling for a coal phase-out in 20-25 years at the COP21 in Paris.[12]
  • The German Advisory Council on the Environment (SRU), the government’s scientific advisory body for environmental questions, published 10 theses on the future of coal in Germany in June this year.[13] In this, they called for a complete coal phase-out by 2040.
  • In a recently held consultation on the upcoming Climate Action Roadmap 2050, a coal phase-out law was a central measure proposed both by associations and by Germany’s federal states.[14]
  • Even though Energy Minister Sigmar Gabriel has been careful not to talk about a coal phase-out in public, he has recently stated in a speech at the BDEW, the association of German utilities, that emissions reductions from the power sector would have to accelerate drastically after 2020, as a reduction of 200Mt CO2 is required by 2030.[15] As Figure 1 shows, this is not possible without phasing out lignite.
  • Trade union IG BCE chairman Michael Vassiliadis has conceded in a recent interview that a coal phase-out by 2040 would be economically feasible.[16]

Several studies have independently modelled pathways for a decarbonised energy system in Germany. The German Aerospace Center[17], the German Advisory Council on the Environment[18], the Federal Environment Agency[19], the energy consultancy enervis[20] and the German Institue for Economic Research[21] have all found in their studies that coal will be practically phased out by 2040 and that there will be a considerable drop in capacity before 2030. Lignite is generally reduced earlier and more substantially in these studies than hard coal.

3) Further action on lignite is very likely

While the political and regulatory environment have already become more negative for lignite in 2015, future legislative action is virtually assured. This is because Germany is not on track to meet its climate targets. The political deal to close the gap towards Germany’s 2020 targets with the climate reserve as well as additional efforts on energy efficiency and cogeneration has supposedly put the country on a path to close the emissions gap to 2020. However, the recently published fourth official  monitoring report on the energy transition raises serious doubts whether these additional efforts will actually materialise.[22] To achieve the 2030 targets, Germany will have to drastically increase climate policy ambition after 2020 to deliver savings of about 200 million tons of CO2.[23] The climate agreement recently reached in Paris makes it only more likely that Germany will have to adopt additional measures to reduce lignite emissions.

Vattenfall's Lausitz lignite plant (photo Robin Wood, November 2015)

Vattenfall’s Lausitz lignite plant (photo Robin Wood, November 2015)

It is highly unlikely that the government will accept Germany failing its climate and energy targets, since the Energiewende remains overwhelmingly popular with the German public, as poll after poll has shown, with support ranging form 57% to 89% of respondents.[24] Coal, on the other hand is viewed very unfavourably. A recent poll found that only 5% of Germans are in favour of using coal power in the future.[25]

There are two scenarios in which lignite could already face further regulation before 2020.

First, uncertainty arises from the fact that the climate reserve might still be struck down by the European Commission as impermissible state aid. The European Commission has indeed already stated that it classifies the climate reserve as state aid.[26] As a result, it will have to sign off on the measure before it can become law in Germany. The reserve will further be subject to detailed scrutiny under the Commission’s sectoral investigation into capacity mechanisms that was started this year.[27]

The reserve is also facing legal challenges from within Germany. Trianel, a joint venture of several municipal utilities, is currently preparing a lawsuit against the climate reserve before the European Court of Justice on the grounds that it distorts competition in the power sector and hampers the introduction of clean energy technologies.[28]

Secondly, a review clause in Germany’s proposed electrictiy market bill[29] stipulates that the progress on emissions reductions through the climate reserve will be reviewed in 2018, with additional measures being required if it is found to be insufficient. Even if the climate reserve passes the test of EU law, further action is thus very likely to follow in 2018.

4) Capacity markets will not come

Prior to 2015, many observers had thought that the introduction of capacity markets might still throw a lifeline to Germany’s ailing coal industry. This is because capacity markets involve payments to energy companies to maintain a certain amount of dispatchable capacity, regardless of the power price at any given moment. This would have allowed older fossil-fueled plants to compete despite the downward pressure that ever-higher shares of renewable energy exert on baseload power prices.

But Germany’s new electricity market law puts an end to this idea.[30] It only includes provisions for a capacity reserve which is quite small and clearly separate from the market. It is also mainly intended for gas power plants. This follows a thorough consultation process in which scientific expertise and stakeholder contributions where collected and evaluated. The idea of a capacity market was overwhelmingly rejected, except by utilities and related groups like the trade union IG BCE.[31] Following this, the electricity market white paper published in July 2015 also explicitly rejected the idea of introducing a capacity market in Germany.[32]

Economic risks

1) Carbon prices will rise because of ETS reform

A substantial reform of the EU’s Emissions Trading System (ETS) is currently underway. The explicit aim is to raise CO2 prices, which would significantly reduce the profitability of lignite power. The Market Stability Reserve (MSR) approved by the EU, which will enter into force in 2019, is expected to substantially tighten the surplus in the market, and most analysts forecast that carbon prices will rise accordingly.[33]

Another Commission proposal to reform the ETS after 2020 is currently going through the legislative process.[34] Among other things, this would significantly increase the linear reduction factor (LRF) by which the number of certificates are reduced each year from the current 1.74% to 2.2%.

Further reforms to restrict the availability of EU Emission Allowances (EUAs) would likely result in further increases in the CO2 price.  This could happen through a variety of proposals. The 2030 EU GHG target is “at least 40%”, and there is a strong possibility this could be negotiated to be higher than 40%, constricting supply in the carbon market.

These developments have already led several market analysts, including Bloomberg New Energy Finance and Point Carbon to significantly raise their ETS price forecasts, as can be seen in table 3.

Table 3: Overview of current EUA price forecasts

Vattenfall table 3

The emissions intensity of Vattenfall’s lignite power plants indicates how vulnerable individual units are to higher EUA prices. As can be seen in Table 4, most Vattenfall units have a carbon intensity of around 1.15 t CO2/MWh. This is almost twice the marginal carbon intensity of German power, which is estimated around 0.65 t CO2/MWh.[35] This means a higher carbon price would raise costs by twice as much as revenues for Vattenfall’s lignite plants. For every €1 EUA price increase, lignite will lose €0.5/MWh.

Table 4: Specific emissions of Vattenfall’s power plant fleet

Vattenfall table 4

Higher EUA prices will therefore have an increasingly negative effect on the profitability of Vattenfall’s lignite plants. If carbon prices doubled to €16/t CO2 on Vattenfall’s current production of 55TWh, this would reduce profits by €220m per year.

It would be virtually impossible for potential buyers of Vattenfall’s lignite plants to make a profit under those conditions – even if drastic cost-cutting measures are enacted. As power generation in Germany is not granted free allocation under the ETS (unlike in Eastern Europe) this will furthermore serve to erode the cost advantage that lignite currently has over other fossil fuels such as hard coal and gas in the German market.[36]

2) Electricity prices are set to fall further in the medium term

The Energiewende is fundamentally transforming Germany’s power sector, making it ever harder for fossil fuels to compete. Baseload electricity prices have been falling since 2011 and are currently below €30/MWh.[37]  All indications are that prices will continue to fall.

Figure 4 shows the development of baseload electricity prices since 2011. They have fallen precipitously by 55% since their peak in July 2011. In the last 3 months alone, the forward electricity price for 2019 fell from €31.60 to €26.85.[38]

The drop in baseload electricity prices and the growing malaise of traditional power generation in Germany has been fuelled by a number of factors. Last year, renewables surpassed lignite for the first time as Germany’s predominant electricity source.[39] This trend is only set to go on as renewable energy continues to enjoy policy support. Early next year, the German government is set to pass an electricity market law designed to prepare the power system for an increasingly large share of renewable energy.[40]

Figure 4: Development of power prices in Germany since 2011

Vattenfall figure 4

Source: EEX, Phelix Base Year Futures

Fossil fuels have been finding it increasingly difficult to compete with subsidised renewable energy, which is operating at near-zero marginal cost and is prioritised in the merit order. At the same time, there are considerable overcapacities of about 10 GW in Germany.[41] This is not likely to change until 2017.[42] Taking into account cross-border electricity trading, overcapacities are even larger. There is about 60 GW of overcapacity in the electricity trading area that Germany has access to.[43]

Rapidly falling installation costs for renewable energy have been another key factor. This trend has historically been underestimated in virtually all major energy forecasts such as the IEA’s World Energy Outlook.[44] The future growth of renewables is likely still being underestimated today.[45] Advances in the area of energy storage present another potentially disruptive technological development. Citibank predicts that the costs of battery storage will decline sufficiently by 2020/2021 to pose “very significant – and in cases terminal – challenges” to energy companies.[46] This is because renewable energy generation coupled with cheap storage provides a viable alternative to baseload power generation.

Moorburg power plant (photo Gerhard Kemme, 2014)

Moorburg power plant (photo Gerhard Kemme, 2014)

Negative power prices on spot markets are a related problem that will become increasingly important in the future. Negative price hours have been occurring increasingly often in Germany. While negative power prices were only registered during 97 hours in 2013, this is set to rise to 1,200 hours (or 14% of the entire year) by 2022 in a business-as-usual scenario.[47] Negative power prices are especially difficult for lignite as they arise from inflexible baseload power generation, which usually does not shut down completely in times of high renewable energy production.

In 2013, for instance, lignite power stations continued to run at 40-50% of capacity even when renewables supplied 65% of electricity. Scaling back production even further would have meant shutting down, and restarting a lignite unit is costly (and becomes more costly the longer it has been switched off).[48] In essence, keeping a lignite power station running under negative prices means losing money, but it is still cheaper than switching it off and back on again. This inability to respond to price signals is a serious competitive disadvantage of inflexible base load power generation such as lignite.

3) European gas prices are collapsing

Another factor that is likely to impact coal power generation is the sharp fall in gas prices that is currently being observed. Gas prices have fallen by 25% since their peak in March 2015,[49] following a collapse in international prices for Liquefied Natural Gas (LNG). According to energy consulting group Wood McKenzie, this trend is likely to continue for some years.[50] This is because the LNG market is structurally oversupplied for the foreseeable future and the cost of developing gas is falling.

The falling gas price should stop or significantly slow the mothballing of gas plants in Germany, which makes a future resurgence in electricity prices due to a sudden capacity shortfall much less likely. It will also help alleviate any future security of supply problem that Germany might have as a result of nuclear power and coal being phased out. It is thus another factor working against the introduction of a capacity market in Germany.

Taken together with rising prices for emissions certificates under the ETS, the falling gas price should bring the day closer when gas will have cost advantage over lignite.

 4) New pollution limits under the EU Industrial Emissions Directive will require retrofits after 2021

Additional cost burdens for lignite power plants will also arise from the EU Industrial Emissions Directive (IED), which sets limits on how much pollution a power plant is allowed to emit.[51] Pollution limits under the IED will be tightened significantly, most likely by 2021.

Even though German coal power plants have generally lower pollutant concentrations compared to the EU average, some of Vattenfall’s lignite plants will be affected by the new limits. All of Vattenfall’s lignite plants are significantly above the SO2 limit set by the LCP BREF and will thus likely require retrofits.

5) Higher-than-expected land remediation costs may have to be paid

The German Federal Mining Law establishes responsibility and liability of mining companies to clean up and restore all areas used for mining. The buyer of Vattenfall’s lignite assets will be responsible for the rehabilitation of all opencast mines that the company currently operates.

While it is difficult to estimate the full extent of the follow-up costs, the costs of remediating lignite mines from the former German Democratic Republic (GDR) gives a rough indication of the scale involved. From 1992 to 2017, these costs will amount to about €12.9bn for remediating of an area of 120,000 ha.[52] Restoring Vattenfall’s 23,000ha[53] of opencast mines will certainly be less expensive. Vattenfall has so far indicated cumulated liabilities of €1.1bn for remediation in its accounts. However, recent studies have raised concerns that the indicated liabilities will be insufficient to clean up all the mining-related damages.[54]

Legal risks

Lignite mining causes environmental damages which are costly to clean up or mitigate. In Germany, liability for mining-related damages is a contentious issue and controversial cases often end up in court. Mining-related environmental damages usually fall under provisions of the EU Habitats Directive[55] or the Water Framework Directive (WFD).[56] The legal standing of citizens and associations, i.e. the right to bring such suits, has been strengthened considerably by recent judgements of the German Constitutional Court[57]  and the European Court of Justice.[58]

Potential buyers of Vattenfall’s lignite portfolio should be aware that a number of lawsuits against Vattenfall’s lignite business are already pending or are likely to be brought in the future. Their outcomes are uncertain at best and they will at the very least entail administrative costs, legal fees and operational delays. (More on this in the full report on which this article is based.)

Thus, we conclude that a confluence of political, economic and legal risks puts the future profitability of German lignite in question. The time window in which Vattenfall’s lignite plants can still be run profitably is closing quickly – so quickly that investors would likely be unable to recoup their costs.

Editor’s Note

This article is based on the report Vattenfall’s Lignite Business – A Risky Bet for Investors, published in November 2015 by E3G. Please follow the link to read the full annotated report.

[1] Greenpeace Nordic also submitted a statement of interest, but was subsequently rejected by Citibank as a potential buyer.

[2] Vattenfall (2015) Interim Report January–June 2015

[3] Energy Brainpool (2015) Economic analysis of Vattenfall’s lignite power plants offered for sale

[4] Boomberg (2015) Greenpeace says can find cash to buy Vattenfall coal assets, 6 October 2015

[5] DIW (2014) Risks of Vattenfall’s German Lignite Mining and Power Operations – Technical, Economic, and Legal Considerations, Politikberatung kompakt 87

[6] German Federal Government (2010) Energiekonzept für eine umweltschonende, zuverlässige und bezahlbare Energieversorgung

[7] European Commission (2011) Energy Roadmap 2050, COMM/2011/0885

[8] See page 11 for sources, see also E3G (2015) G7 coal phase out: Germany – A review for Oxfam

[9] German Federal Government (2015) Entwurf eines Gesetzes zur Weiterentwicklung des Strommarktes (Strommarktgesetz)

[10] FAZ (2015) Teilausstieg aus der Braunkohle besiegelt, 24 october 2015

[11] International pressure is increasing as well, with the UK committing to a 2025 coal phase-out and the Netherlands reportedly also considering to end coal power generation.

[12] Berliner Zeitung (2015) Bundesregierung will Ausstieg aus Kohleverstromung fix machen, 25 November 2015

[13] SRU (2015) 10 Thesen zur Zukunft der Kohle bis 2040

[14] German Environment Ministry (2015) Zusammenstellung aller Maßnahmenvorschläge der Bundesländer, Kommunen und Verbände für den Klimaschutzplan 2050

[15] Sigmar Gabriel (2015) Herausforderung Energiewende: “Die Stunde der Überschriften ist vorbei”, speech at BDEW Congress 2015, 30 June 2015

[16] Interview with Michael Vassiliadis, Die Zeit, 24 April 2015

[17] Joachim Nitsch (2013) „Szenario 2013“ – eine Weiterentwicklung des Leitszenarios 2011. Deutsches Zentrum für Luft- und Raumfahrt (DLR), Stuttgart, Deutschland

[18] German Advisory Council on the Environment (2011): Sondergutachten: Wege zur 100 % erneuerbaren Stromversorgung

[19] Federal Environment Agency (2010): Energieziel 2050 – 100% Strom aus erneuerbaren Quellen

[20]  Hilmes, U., Herrmann, N., (2014): Der „ideale Kraftwerkspark“ der Zukunft; Flexibel, klimafreundlich, kosteneffizient – Maßstab für einen optimierten Entwicklungspfad der Energieversorgung bis 2040; Energiewirtschaftliche Untersuchung. enervis energy advisors GmbH, Berlin.

[21] DIW (2014) Braunkohleausstieg – Gestaltungsoptionen im Rahmen der Energiewende (No. 84), Politikberatung kompakt

[22] BMWi (2015) Die Energie der Zukunft – Vierter Monitoring-Bericht zur Energiewende

[23] Sigmar Gabriel (2015) Herausforderung Energiewende: “Die Stunde der Überschriften ist vorbei”, speech at BDEW Congress 2015, 30 June 2015

[24] WiWo (2014) Allensbach-Umfrage: Hohe Zustimmung für Energiewende, 14 June 2015; BDEW (2015) BDEW-Umfrage: Große Mehrheit unterstützt die Energiewende – Umsetzung wird kritisch beurteilt, 11 February 2014; Innovationsforum Energiewende (2015) Deutscher Energie-Kompass 2014: Das Stimmungsbarometer der Energiewende

[25] Zeit (2015) Allensbach-Umfrage: Kohle unbeliebter als Atomkraft, 16 September 2015

[26] FAZ (2015) EU stellt deutschen Braunkohlekompromiss in Frage, 14 September 2015

[27] European Commission (2015) State Aid: sector inquiry into capacity mechanisms – frequently asked questions, press release, 29 April 2015

[28] Rheinische Post (2015) Stadtwerke wollen gegen Braunkohle-Reserve klagen, 4 November 2015

[29] Art. 13g (8) in Draft Electricity Market Law, agreed by the Cabinet on 4 November 2015

[30] Draft Electricity Market Law, agreed by the Cabinet on 4 November 2015

[31] The responses to the consultation are available here

[32] BMWi (2015) White paper: An electricity market for Germany’s energy transition

[33] Council of the EU (2015) Greenhouse gas emissions: creation of a market stability reserve approved, press release, 18 September 2015

[34] European Commission (2015) Proposal for a directive to enhance cost-effective emission reductions and low-carbon investments, COM(2015) 337

[35] This estimate is based on a based on a reasonable mix of mostly efficient hard coal, as well as some gas, renewables and lignite.

[36] Council of the EU (2015) Greenhouse gas emissions: creation of a market stability reserve approved, press release, 18 September 2015

[37] Phelix Base Year Future price, November 2015

[38] Checked on 16 November 2015

[39] http://www.agora-energiewende.de/fileadmin/downloads/publikationen/CountryProfiles/Agora_CP_Germany_web.pdf

[40] Draft Electricity Market Law, agreed by the Cabinet on 4 November 2015

[41] BMWi (2014): Ein Strommarkt für die Energiewende,

Diskussionspapier des Bundesministeriums für Wirtschaft und Energie (Grünbuch)

[42] BMWi (2014) Leistungsbilanzbericht 2014

[43] ENTSO-E (2014) Scenario Outlook and Adequacy Forecast. This region includes Germany, its neighbours and Italy.

[44] Carbon Tracker (2015) Lost in Transition: How the energy sector is missing potential demand destruction

[45] Metayer et al. (2015) The projections for the future and quality in the past of the World Energy Outlook for solar PV and other renewable energy technologies

[46] Citigroup (2014) Energy Storage: Game Changer for Utilities, Tech & Commodities

[47] Agora Energiewende (2014) Negative Strompreise: Ursachen und Wirkungen

[48] Intertek Aptech (2012) Power Plant Cycling Costs

[49] EEX natural gas spot market data, 30/10/2015

[50] Fuel Fix (2015) LNG oversupply likely to burden spot prices, 27/10/2015

[51] Directive 2010/75/EU on industrial emissions

[52] Bund-Länder-Geschäftsstelle für die Braunkohlesanierung (StuBA)

[53] Green Budget Economy (2014) Kostenrisiken für die Gesellschaft durch den deutschen Braunkohletagebau

[54] Green Budget Economy (2015) Gesellschaftliche Kosten der Braunkohle

[55] Council Directive 92/43/EEC

[56] Directive 2000/60/EC

[57] Judgement BvR 3139/08 and associated press release

[58] Judgement C-137/14

Comments

  1. S. Herb says

    I am not politically sophisticated, but I do not see how a sales deal can be made without some sort of agreement with the German government, for example a minimum run time coupled with a dedicated remediation fund (as opposed to a a balance sheet liability). My impression was that the Greenpeace initiative was pushing in this direction. Anything else is likely to turn into very messy politics somewhere down the road.

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