EWA Responds to SDE++ 2026 Consultation: A Call for Fair Recognition of Energy from Water

By Maarten Berkhout (SeaQurrent) and Peter Scheijgrond (Bluespring)

The Ministry of Climate and Green Growth (KGG) has requested the Netherlands Environmental Assessment Agency (PBL) to provide advice on the SDE++ scheme for 2026. As part of this process, the PBL has published a consultation paper and invited stakeholders to respond. In parallel, the consultation for the SCE scheme (Subsidy Scheme for Cooperative Energy Generation), aimed at smaller local energy initiatives, is also underway.

The SDE++ scheme (and its predecessors) has played a vital role in supporting the energy transition in the Netherlands and has now expanded to include a wide range of CO₂-reducing technologies. This broadening necessitates a careful and future-proof positioning of the various technologies, ensuring that public funds are allocated to solutions that truly contribute to the energy transition.

On behalf of the board of the Dutch Energy from Water Association (EWA), we hereby share the key points from our response to the consultation.

1. CO₂ Reduction from Energy from Water is Underestimated

In the consultation paper, a CO₂ reduction of only 0.13 kg per kWh of renewable electricity from water is assumed. This low value results in a limited “unprofitable top” (ORT), and therefore insufficient financial support through the SDE++. We believe this is unjustified.

Our argument includes the following points:

• Energy from water (such as tidal energy and osmosis) generates power precisely when solar and wind do not. This helps achieve 100% renewable energy, 100% of the time.

• These technologies relieve pressure on the congested electricity grid and enable cable pooling.

• The KEV model, on which the CO₂ reduction estimate is based, lacks transparency and relies on ambitious assumptions, such as 40 GW of offshore wind by 2040. Given current market signals, that is far from certain.

• Other sectors that need to electrify (such as buildings, transport, and agriculture) will increasingly require reliable, renewable electricity in the future.

  
  

👉 We therefore advocate for a revision of the emission factor used, so that technologies providing energy during times of scarcity are valued more fairly.technologieën die leveren tijdens momenten van schaarste eerlijker gewaardeerd worden.

2. Uneven Playing Field Between Technologies

The expansion of the SDE++ means that technologies such as CCS (Carbon Capture and Storage) are now also eligible for support. A gas plant with CCS saves approximately 0.35 kg CO₂/kWh, receiving nearly three times the subsidy of an energy-from-water project. That is problematic.

Hydrogen production via electrolysis is also attributed a much higher CO₂ reduction (0.458 kg CO₂/kWh) than direct generation from water (0.13 kg), creating a skewed picture and unfairly favoring indirect routes over direct renewable electricity generation.

👉 We call for a revision of the calculation methodology to ensure a fair comparison between technologies.

3. Higher Subsidy Intensity Needed for Reliable Sources

The SDE++ currently uses two subsidy intensities: €300 or €400 per ton of CO₂ avoided. The higher category is reserved for, among others, heat applications and the production of sustainable molecules.

Especially in winter, when heat demand peaks and solar and wind are less reliable, stable electricity sources are essential. Energy from water is particularly well-suited to meet this need: it is predictable, weather-independent, and reliable.

👉 We advocate granting energy from water access to the higher subsidy intensity of €400 per ton of CO₂, in line with other key building blocks of the energy system.

4. Recognition of Broader Geopolitical Significance

The European Renewable Energy Directive (RED) mandates that at least 5% of new renewable capacity must come from innovative technologies. The current classification of hydropower on the "bulk list" seems inconsistent with this and hinders innovation.

Moreover, energy autonomy is an explicit European objective, driven partly by the desire to reduce dependence on Russian energy and Chinese technology. Energy from water presents a unique opportunity here: developed locally, produced in Europe, and without the need for scarce raw materials.

👉 We call for greater recognition of innovative technologies developed in the Netherlands and Europe.

5. Unfair Limits in the SCE Scheme

The SCE scheme currently imposes a maximum capacity of 150 kW for hydropower projects, while solar and wind projects can apply for up to 6 MW. This is unnecessarily restrictive.

👉 We advocate for equal capacity limits for all technologies within the SCE.

In Conclusion

We hope our comments contribute to a more balanced and effective design of the SDE++ and SCE schemes for 2026 — one in which innovative, reliable, and locally developed technologies such as energy from water receive the recognition and support they deserve.

Kind regards,On behalf of the board of the Dutch Energy from Water Association (EWA)Maarten Berkhout (SeaQurrent) & Peter Scheijgrond (Bluespring)