The Ministry of Sustainable Development and Infrastructure (MDDI) refuses building permissions for ground-mounted PV installations. The official statement often includes environmental issues, e.g. animal crossing points that are interrupted due to fences that have to be built in order to protect the PV installations. The main reason for the denial of building permissions for ground-mounted PV installations is the unwillingness of the Government to use these spaces for PV.

The DSO in Luxembourg (CREOS / ENOVOS) has the monopoly, which leads to the frequent occurence that the electricity produced by PV installations cannot be fed into the grid, since e.g. the transformers do not have enough capacity or there is no sufficient connection possibility (there is no obligation for the DSO to feed-in the electricity). Unfortunately, these decisions are in many cases not comprehensible. In case of doubt, the electricity producer has to pay the additional costs of grid connection, which in consequence leads to the fact that the whole project is no longer affordable.

A huge step towards the development of wind power in Luxembourg has been taken by the issue of development plans for wind energy, which define spaces that are eligible for this technology. However, these plans, which were developed by the Ministry of Sustainability in cooperation with SOLER, which is the strongest wind power developer in Luxembourg, are not officially published and to this regard not accessible to the public. This is seen as a strong burden for other potential wind power producers as the accessibility of potential spaces is limited and administrative procedures might take longer.

There are not yet regulations concerning self-consumption of renewable electricity. The new technical connection specifications require the use of three different smart meters, which leads to a high financial burden for the producers of self-consumed renewable electricity. Furthermore, it is not clear whether or not self-consumers are exempted from the electricity tax. Currently, the excess electricity generated is remunerated by the Prix du Marché, which is the minimum price that the DSO has to pay according to the law. However, progress is made as the regulator together with the grid operators is currently developing a performance-based grid charge that is specifically designed for self-consumption systems. These developments will have to be further substantiated in the near future and have not yet been published. In addition, there is a law change project, which is publicly available, in which self-consumption will get its own legal framework. The incentive for self-consumption systems is that no energy tax is charged on the self-consumed portion of the generated electricity. In addition, there is also the possibility to form so-called Energy Communities, collectives for self-consumption.

The increase of the feed-in tariffs could also be considered counterproductive to the increased consumption of self-produced electricity, as this electricity becomes less profitable.

Regarding wind energy, some local protests can be observed, not leading to a project stop, but to a certain delay. As these protests are not organised by larger groups, this barrier has only minimal effect on the deployment of wind power in Luxembourg. A reason for the increase of public acceptance is the increased involvement of local residents in wind projects (by SOLER). In particular, the municipality of Fischbach is protesting against the wind power project "Mersch" in Rollëngerbierg due to concerns about health issues, as the planned site is situated close to the municipality (Commune de Fischbach, 2019).

On 15 February 2011, the new Agriculture Act (Loi du 18 avril 2008 concernant le renouvellement du soutien au développement rural) entered into force, only entitling biogas plants to investment aid if they meet the following criteria:

• Only national agro-industrial waste materials shall be used in the biogas plant (imports from the border region is prohibited)

• National input materials shall originate only from a radius of 25 kilometres around the biogas plant

• Supply contracts for biomass must run for at least 10 years

Due to this ministerial decision, the scope of action concerning the biomass is substantially limited. The average investment aid for agricultural biogas plants amounts to approx. 50%. Without this aid, an economically viable operation of the biogas plants is not possible.

The rising prices for animal feed also let to a sharp rise of the substrate costs for biogas plant operators during recent years. For systems in which a specific target has to be achieved in order to meet their heat supply contracts, an additional acquisition of substrates is unavoidable. On average, the substrate inputs cause half of the total cost of the biogas operation.

The current thermal regulation imposes the use of renewable energy in buildings.The use of wood burning systems is fairly limited, when Luxembourg conditions would allow a good profitability of such facilities. One observes instead the existence of negative communication regarding the maintenance constraints of wood burning installations in order to maintain their performance.

Although financial support is rather high, stakeholders point out that suppliers tend to adjust their prices depending on the level of subsidies. Thus, one observes that the market price of solar thermal installations has fallen sharply along with the level of subsidies. The barrier lies in the fact that consumers are technically not competent enough to detect the abuse of some installers. The latter namely sometimes charge installations at too high prices, justified through unnecessary options.

In order to avoid these abusive situations, stakeholders suggest that experts determine each year the accurate market price of an average installation for each renewable energy technology. The calculation could be supervised by the government.

The support system in place in Luxembourg provides financial support up to 50% for heat production systems from solar energy. However, this funding is still too little known among households. In fact, no governmental information campaign has been running so far to raise the public awareness on the existence of such support schemes.

There are discussions ongoing on the substitution of solarthermal installations through the use of PV for the heating of boilers. It might therefore be the case that solarthermal installations will be less used in the future.

Even though the official national strategy aims at concentrating on biofuels, the support policy implemented for biofuels is rather limited. First, the existing support scheme solely consists in the definition of biofuel quota to be fulfilled by oil companies selling gasoline or diesel for transport purposes, whereas other European countries provide additional support measures for biofuels, such as reduced energy tax rates. On the other hand, the has pronounced itself against first generation biofuels and plans not only to limit their maximum incorporation rate, but also to condition their support upon social and ecological criteria. According to the government, first generation biofuels have proven not to meet the requirements of sustainable development. Instead, the government has committed itself to supporting the development of second generation biofuels.

Numerous advocates of RES in Luxembourg criticize the strategy of the Government hitherto to focus on the development of biofuels in RES-T. In this regard, a communication platform composed of several NGOs has been created to protest against the further production and use of biofuels. The main arguments of the platform called “cerealkiller-lu” are that biofuels are dangerous for global food security and impede biodiversity. Moreover, they are too expensive and their effects on the reduction of CO2 emissions are unsatisfactory. Another main argument against biofuels relates to the ILUC factor, which underpins the argument contesting the ecological interest of first generation biofuels. In fact, opponents of biofuels argue that the additional CO2 emissions resulting from the conversion of forests into arable land, annuls the initial positive effects of biofuels.

Regarding the use of biogene material in the transport sector, there are mainly biogas plants in Luxembourg. In addition, a few rapeseed fields are cultivated. The Government intended to further expand the cultivation of rapeseed. However, due to the resistence of the population these plans were not realised. This barrier leads to a stagnation of the development of the biofuels sector in Luxembourg.

Despite the availability of investment grants for the purchase of electric vehicles, only very few vehicles have been registered. This is because the Luxembourgers misconceived the need of electric mobility at first as the range of this kind of vehicles is low. In 2019, only 2000 electric vehicles were operated in Luxembourg.