“G-component fee” (payment for access and connection to the distribution system or grid fee, also known as “G-component fee”) was introduced in the “Ordinance on price regulation in electricity” (Decree No. 221/2013 Coll.) in July 2013 by the regulatory body (ÚRSO). From January 2014, a new fee for grid capacity reservation was applied to all electricity producers. The amount of payment ranges from € 17,000 to € 21,000 per year per 1 MW of installed capacity. Producers of green energy constantly criticised the regulator for illegal introduction of an obligation to pay “G-component fee” based only on the contract of connection to the grid. The exception from “G-component fee” applies only to small hydroelectric power installations (up to 5 MW) and “small sources” (installations up to 10 kW) whose owners do not do a business in energy sector. The majority of stakeholders have identified this payment as the key retroactive measure with negative effects. Furthermore, in July 2016, the finding of the Constitutional Court of the Slovak Republic (Finding No. 220/2016 Coll.; “PL. ÚS 17/2014-132”) declared the “G-component fee” as unconstitutional. Although the distribution system operators (DSOs) did not taken this decision into account and they further applied the fee at the beginning, now they are obliged to return back this fee to RES-E producers for the last years (for the period before 1 January 2019). For instance, on 26 September 2018, the Regional Court in Žilina ("Krajský súd v Žiline") confirmed the decision of the District Court Žilina, which as the first court in the country reflected the aforementioned findings of the Constitutional Court in June 2017. As a result of it, the distribution company Stredoslovenská distribučná (SSD) is obliged to return the grid fee to the producers of electricity from solar energy amounting to € 100,000. Moreover, there are numerous other lawsuits against DSOs currently ongoing. According to the law firm Poláček & Partners, if all DSOs have to return to the G-component fee under this precedent, it will amount to approx. € 150 million. The core of the dispute lied in the difference between the terms of access and connection to the distribution grid. According to the Finding, entities having no contract on access to the distribution system have no reason to pay the fee. Therefore, only those producers who use distribution system for trading or have a contractual relationship with a DSO are obliged to pay it. Regarding the retroactivity of the measure, the finding of the Constitutional Court states that the contested provisions are not retroactive (but still unconstitutional) because they have not imposed the obligation to pay fees retroactively for the period prior to the date of entry into force of the Decree, but they apply to the future price regulation. As of 1 January 2019, the "G-Component fee" is in accordance with the law since the decision-makers reflected the aforementioned Finding of the Constitutional Court of the Slovak Republic in the major reform of RES Act. As a result of this change, RES-E producers are legally obliged to pay the fee from 2019 onwards. The inclusion of such a provision into the Slovak legislature was and is still heavily criticised by the Slovak Association of Photovoltaic Industry (SAPI). Currently, RES operators can carry the burden of such payment, however, the situation might be worse once the operational support (FiT) for RES-E plants expires.

Since December 2013, the entire Slovak RES sector has been facing a connection moratorium (so-called Freeze Status) because all three regional distribution system operators (DSOs) stopped issuing licenses (except for “small sources” up to 10 kW). The transmission system operator (Slovenská elektrizačná prenosová sústava, a.s.) carried out a study in late 2012, which says that wind and photovoltaic plants with a higher performance destabilise the grid and belong to the category of unpredictable energy sources. All three DSOs announced a full or at least partial connection moratorium for all RES installations a year later. According to Slovak legislation, the DSO is obliged to connect new sources only if there is a free capacity in the distribution grid. If there are other sources present nearby the connection point and the capacity is full, the regional DSO can deny the request. According to the Slovak Association of Photovoltaic and Renewable Energy Industry (SAPI), the Ministry of Economy (MH SR) finally overcame this major barrier on 27 February 2019. Based on an amendment of the RES Act (No. 309/2009 Coll.), which entered into force on 1 January 2019, the MH SR officially announced capacities for new RES amounting to 43 MW in total this year. These capacities are divided into two categories – RES promoted via feed-in-tariff (12 MW in total; excluding PV and wind plants) and RES meeting the criteria of the so-called Local Energy Source (up to 500 kW; 31 MW in total) without any claim for direct financial support. However, these limits apply only to three Regional DSOs, each one with more than 100,000 delivery points. According to an energy expert, in the case of local DSOs, no limits were stated in the law and no new RES excluding the so-called small sources can be connected to the grid. With regards to the Local Energy Source, there is still a degree of uncertainty in relation to its implementation since two regional DSOs decided to connect these sources to high voltage network and information system simultaneously which may result in serious operational issues. Moreover, some experts assume that the Freeze Status (in a different form) still prevails for the new RES, which will not be connected once the aforementioned upper limits are reached. Finally, for large scale RES with an installed capacity over 500 MW, the MH SR aims to launch auctions for new RES-E amounting to 200 MW per year (incl. 2019) this summer. Since the new measures have not been fully implemented yet, uncertainty about the Freeze Status in the Slovak RES-E sector still persists.

According to the RES Act, when requested the Distribution System Operators (DSOs) are obliged to disclose the capacity data for any individual connection point. Unfortunately, none of the DSOs fulfilled this obligation completely; the only distribution company to publish at least some of the data was VSD (Východoslovenská distribučná, a.s.), which is active in the eastern part of Slovakia. Therefore, it is impossible for RES plant operators to verify whether the capacity limit has truly been reached at the particular connection point. Additionally, DSOs require from households (installations up to 10 kW) to fulfill requirements that are considered to go beyond rules set by the RES Act (with regard to complexity and duration of administrative process).

In order to construct a RES plant with a higher output than 1 MW and solar PV installations with a higher output than 500 kW (as of 1 January 2019), a permission of the Ministry of Economy (MH SR; certificate for power facility construction) as well as an opinion of the Regulatory Office for the Network Industries (ÚRSO) for RES exceeding 1 MW is needed (§ 12 par. 2 Energy Act No. 251/2012 Coll.). This increases the administrative burden for investors. According to the MH SR, there are great concerns in Slovakia that if the wind power projects get realised, they will cause instability in the transmission system.

Since the end of 2015, the national project Green to Households ("Zelená domácnostiam") has theoretically made possible to install small wind power systems (“small sources” up to 10 kW), however, certain policy changes are more than inevitable. The problem is that there is a lack of certified professionals (installers certified by the Ministry of Economy) who should perform wind power installations, since the legislation on certification of installers is not intended for installers of wind power plants (see § 13a Act No. 309/2009 Coll.) and therefore installers who are certified by the Ministry of Economy (MH SR) do not operate in the market. They can be trained, but the MH SR is not allowed to issue a certificate. On the other hand, certified installers from other Member States are recognised in Slovakia. With the aim of addressing this problem, political opposition (Karol Galek and Anna Zemanová from political party "Sloboda a Solidarita") proposed respective amendments to the RES Act. However, they were rejected by the parliament (NR SR) in September 2016. The same amendments to the RES Act were suggested by the Chamber of End-Users and Producers of Renewable Energy Sources (KUVOZE) in the RES Act reform comment procedure in March 2018. Since this change was not even introduced by the major amendment of RES Act, which entered into force on 1 January 2019, this barrier still prevails in Slovakia.

Amend the existing § 13a Act No. 309/2009 Coll. on certification of installers and add the category “e) wind turbines”

Since the end of 2015, the national project Green to Households ("Zelená domácnostiam") has theoretically made possible to install small wind power plants (up to 10 kW). Currently, all wind power installations including the micro ones must elaborate “full” environmental impact assessment (EIA) procedure. The whole process lasts more than a year; the required measurements cost thousands of Euros. In addition, for small and even medium wind turbines it can be considered as an excessive requirement from decision-makers. One expert has noted that in the National Council of the Slovak Republic (NR SR) there existed amendments of the Acts No. 24/2006 Coll. and No. 309/2009 Coll., which proposed also an exception in elaborating the EIA for wind power plants with lower performance (e.g. for electricity generation for households). However, these changes have not been supported by the majority of the Slovak Members of Parliament (MPs) until now.

Amend the existing appendix No. 8 to the Act No. 24/2006 Coll. and establish EIAs thresholds for wind plants to 50 kW

Support schemes for RES have been active in Slovakia. A key instrument is a tariff for the system operation (“TPS”), which is part of the final price of the electric energy for final power customers (TPS is set at € 25.988 per MWh by the Regulatory Office for Network Industries (ÚRSO) for 2019). This tariff includes also the financial support for RES-E which according to the current data amounts to approx. € 400 million per year. It is estimated that a typical household pays on average approx. € 60 per year for the RES support. Due to their impact on final electricity prices, renewable energy sources (especially PV) have a very negative reputation in Slovakia. The reason is that in case of photovoltaics, the guaranteed feed-in tariffs (FiT) were rather generous in the period 2009-2011 and therefore large capacities of volatile energy sources were connected to the grid. Distribution System Operators (DSOs) have allocated the major part of the costs for the support scheme to final consumers through the TPS which raised their electricity bills considerably. In addition, in case of wind power plants, municipalities would (do) not approve their construction due to prevailing opinion of citizens on their possible negative impact on characteristic features of natural landscape.

The state should also take over a part of the financial burden that is related to the development of RES, not only the final power customers (via the tariff for system operation).

In July 2011, there was a big change in the sector of photovoltaics. Since the amendment of the Act No. 309/2009 Coll. has become effective, only roof-top installations and installations on the outer wall of a building are allowed and subsidised, while no ground-mounted installations are subsidised in Slovakia.

On the basis of Act No. 609/2007 Coll. (§ 7 par. 1 Letter e), the electricity produced from RES (RES-E) is exempt from excise tax, if it has a proven guarantee of origin and is produced by solar power, wind power, geothermal, hydro or biomass facilities. Nevertheless, no other influential tax incentives or fiscal benefits boosting RES-E were identified in Slovakia. Moreover, “G-component fee” (payment for access and connection to the distribution system or grid fee) for RES-E producers, which is in accordance with the law since 1 January 2019, is considered a type of a “hidden tax”. It amounts to approx. € 17,000 to € 21,000 per year per 1 MW of installed capacity.

The Regulatory Office for Network Industries (ÚRSO) has been for long facing the criticism on lack of transparency (e.g. calculation of FiT, "G-Component fee", etc.), and on non-systemic and non-conceptual decision-making process by the European Commission as well as by domestic entities on the energy market. Furthermore, numerous laws were breached by the ÚRSO in the last years, according to the findings of the Supreme Audit Office of the Slovak Republic (NKÚ) from February 2019. In addition, the ÚRSO seems to underlie the political pressure of the government. Therefore, a number of political parties proposed to change the monocratic management of the ÚRSO in their election programmes and it became part of their political agenda in the last parliamentary elections (2016). On 15 June 2017, the parliament (NR SR) finally approved the bill on the amendment of Regulatory Act No. 250/2012 Coll. that was previously vetoed by the president. According to the amendment, the ÚRSO Chairman is appointed solely by the Government, and the functions of the ÚRSO Chairman and the Chairman of the Board for Regulation are separated. Moreover, Ministries of Economy (MH SR) and Environment (MŽP SR) regained the competencies to comment on the ÚRSO's price decisions. These changes were strongly criticised by the political opposition as well as by the Council of the European Union in May 2017. Consequently, in July 2017, the Government (formed mainly by the ministers from the political party SMER-SD) approved the nomination of the selection board of ÚRSO and the former member of the parliament and the former Minister of Economy (a nomenee of the political party SMER-SD) Ľubomír Jahnátek became the Head of the Slovak regulatory body. Since then, no positive move has been observed. Few stakeholders even speak about the deterioration of the ÚRSO's decision-making. Last but not least, one of the interviewees highlighted the fact that ÚRSO is financed directly from the state budget, which is proposed by the Government which in itself means that the Regulator cannot be fully independent.

A public resistance against the construction of hydroelectric power plants is not seldom as it is evident from the cases in Eliášovce, Bešeňová or Farské lúky etc. As long as there is no broad agreement, no more economic activity on the water flows will be performed. Processing the management and protection of all water flows, which will be based on the participation of experts and general public (incl. associations) is inevitable. Not only the economic opportunities of such flows should be taken into account, but also the protection of ecosystems linked to water flows, tourism, public opinion and municipalities. Additionally, administrative burden that results from carrying out environmental impact assessment (EIA) as well as the duration of EIA are considered to hinder further development of hydropower plants' capacities in the country. For instance, potential hydropower operators are also obliged to develop studies on a hydropower plant's effects on trees and small aquatic animals. As a result of these studies, only a project preparation may last about nine years. Therefore, the project risk is much higher compared to other RES technologies since the level of support at the time when it becomes operational is unknown, according to the Union of Small Hydropower Plants (Zväz MVE).

Management of watercourses and river basin management of water flows should be based on broad agreement and engagement of all concerned stakeholders (activists, public, municipalities, etc.). Another solution is to change the Building Act, which will require positive referendum in municipalities in the area that is directly and indirectly affected by the construction of small hydroelectric power plants (total installed capacity up to 10 MW).

The state supports the development of electricity from renewable energy sources (RES-E) mainly via Feed in Tariff (FiT), which is secured through the so-called Tariff for the System Operation (“TPS”), representing part of the electricity price for final electricity consumers (households as well as businesses). The main part of TPS goes for the support of RES-E, which according to the current data amounts to approx. € 400 million per year. The TPS forms a significant part of final electricity price since it also subsidises combined heat and power production (CHP) plants (approx. € 115 million per year), and it incentivises the domestic coal mining (approx. € 100 million per year), too. According to the Director of the Slovak Association of Photovoltaic Industry (SAPI), the TPS represents approx. 22% of the final electricity price. In Slovakia, the TPS increased from € 2.72 per MWh in 2009 to € 26.988 per MWh in 2018. In December 2018, the Regulatory Office for Network Industries (ÚRSO) decided to lower the TPS for the year 2019. According to the ÚRSO’s calculation, its amount decreased by € 1 to € 25.988 per MWh due to the increase of electricity price, therefore, the surcharge was reduced. The ÚRSO highlighted that the TPS might have been decreased even more, i.e. by almost € 2, however, the Regulator decided to use these funds to lower the acummulated tariff deficit of three regional distribution system operators (DSOs), which is currently estimated at approx. € 462 million. It remains equivocal how the ÚRSO calculated precisely the value of € 1, according to the SAPI. This issue was caused by the presence of constant differences in the planned amount of support and the actual amount of received support that was only semi-balanced to DSOs with a 2-year delay (so-called "T-2 model"). This should be changed from 2020 when a new subject should start buying out RES-E instead of DSOs. Moreover, since 1 January 2019, the TPS is reduced only in the case if a request for compensation is submitted by the so-called energy-intensive enterprise which is also fulfilling the following criteria: annual electricity consumption exceeded 1 GWh in a previous calendar year, the share of gross value added from eligible activities is at least 50% of the total value of the enterprise, they have properly paid the TPS, are not bankrupt, etc. These companies will be given a compensation, i.e. reimbursing part of the already paid fees via TPS. Although it should promote the competitiveness of approx. 200 companies operating in energy-intensive sectors in Slovakia, it may be considered an environmentally harmful subsidy. The finance gap of approx. € 40 million per year, which results from the change, will be compensated directly from the state budget. In addition, enterprises producing electricity for self-consumption are also obliged to pay the TPS (except for the so-called Local Energy Sources up to 500 kW as of 2019). It is considered unfounded since these companies reduce the load on electricity grid. Furthermore, according to national experts, the question is if the TPS mechanism is not a state support scheme that should have been notified and approved by the European Commission. Last but not least, there is also a dispute whether the ÚRSO is legally entitled to collect fees via its regulations.

Producers of electricity from water warn that in case of hydro power plants the electricity production is becoming less and less attractive each year, from an investment point of view. Slovenské elektrárne, a.s. as a dominant hydro electricity producer with 32 hydroelectric power plants, states that high fees are the crucial reason. These fees include a fee for the use of hydropower potential (“HEP”; it rose from € 9.10 per MWh in 2005 to € 16.60 per MWh in 2015), a fee for access and connection to the distribution system (also known as “G-component fee”) as well as a payment for water collection from water courses (§ 3 of Government Regulation No. 755/2004 Coll.). Since January 2019, the duration of authorisation for the use of HEP is limited to a period of 10 years (§ 21 par. 4 Letter h of the Act No. 364/2004 Coll.), which even exacerbates the investment burdens for hydropower plants. Moreover, there is no exception for the small hydropower plants with installed capacity up to 10 MW. According to the information provided by the Union of Small Hydropower Plants (Zväz MVE), a usual payback period of small hydropower plants is approx. 15 years in Slovakia and therefore the operators must apply for the authorisation twice during this period, which may even discourage some investors from such projects.

On 1 January 2019, auctions for renewable energy sources (RES) were introduced to the Slovak legislative framework via an amendment (Act No. 309/2018 Coll.) of the RES Act No. 309/2009 Coll. According to the aforementioned law, to the eligible group of energy sources which may be incentivised through auctions belong RES producing electricity (RES-E), i.e. wind, photovoltaic, hydropower, geothermal as well as biogas, and high efficient combined heat and power (CHP) facilities with a capacity of 10 kW up to 50 MW (§ 3 in conjunction with § 5c of Act No. 309/2009 Coll.). In fact, mainly the large-scale RES plants over 500 kW should be supported by a feed-in premium (FIP) through the system of auctions in Slovakia. The market-based support in the form of FIP will be guaranteed for applicants offering the lowest prices for a period of 15 years. According to the latest information, approx. 200 MW of new sources promoted through auctions per year (incl. 2019) is expected. Although there is no restriction in terms of promoted RES technologies in the law, it is not clear yet whether the auctions will be technology-neutral or not. The Ministry of Economy (MH SR) in cooperation with the Regulatory Office for Network Industries (ÚRSO) should publish more details on auctions in the second half of the year 2019. More concretely, the notice of initiation of the selection procedure, the conditions for participation in the selection procedure and the criteria for the evaluation of applications should be published in the Commercial Bulletin as well as on the MH SR’s website at least two months before the date of applications’ deadline. The MH SR may also limit the maximum electricity price that can be offered in the selection procedure. Whether the auctioneer will be the MH SR itself or other subject is still a matter of discussion. As for April 2019, the auctions have not been launched yet and the first one should be launched in the summer of 2019 at the earliest. Currently, there is a certain uncertainty on the auctions’ implementation, which has been highlighted by numerous stakeholders operating in the Slovak RES sector in March 2019. For instance, the RES Act only defines that the selection procedure should be non-discriminatory and transparent, and more information (i.e. implementing decrees) should only be publicly known only in the summer 2019.

Since January 2019, the Regulatory Office for Network Industries (ÚRSO) is legally entitled to withdraw any kind of support from operators of renewable energy sources producing electricity (RES-E) in the case they make any upwards adjustments of the original installed capacity of RES plant. The capacity might have previously been increased by 5% (compared to the original one) without losing the right of support. Since the provision § 3b par. 2 Letter a of the RES Act (No. 309/2009 Coll.) has been amended, a certain uncertainty prevails about its implementation, according to an energy expert. Currently, there is very limited information on how the ÚRSO will deal with such situations (e.g. repair vs. modernisation or reconstruction).

Even though Slovakia has officially declared to further develop its renewable energy capacities in the heating sector in order to meet the EU-2020 targets, the Slovak Energy Policy rather focuses on developing the country’s nuclear energy facilities. In reality, RES in the heating sector therefore receive very little attention by the decision makers. Currently, only CHP plants are entitled to receive state support in the form of Feed-in Tariffs (Decree No. 18/2017 Coll. of ÚRSO).

The existing subsidy programmes are hampered by unnecessary bureaucracy. RES investors that apply for subsidies are obliged to provide many legal documents, which according to the Slovak biomass association were not needed in other EU Member States and thus only posed an unnecessary administrative barrier.

Since the year 2015, the revised Thermal Energy Act (No. 657/2004 Coll.) has severely worsened and de facto even prevented consumers from disconnecting from the systems of centralised heat suppliers. According to the Law, a centralised heat supplier has a legal right to reject household's request on disconnection since they participate in the construction management procedure of RES plant (e.g. solar thermal collectors, heat pumps, etc.). If an appartment owner wants to secure its own heat supply he has to tackle the obstacles that are difficult to overcome. The aforementioned matter raised the issue of constitutionality before the Constitutional Court of the Slovak Republic, which in October 2016 confirmed the claims of centralised heat suppliers in its accordance with the Constitution. As a result, residents still need a statement from their current heat suppliers, if they want to be disconnected.

The area of biofuels suffers from numerous legislative changes resulting in investment instability. The revision of directives and policies at the EU level takes place every two years. Therefore, investors have only limited time for implementation before a further change is introduced. Furthermore, tendentious food vs. fuel debate or unfair competition from other production sectors are aspects that confuse the general understanding of biofuels. The Association for Production and Use of Biofuel (ZVVB) also highlighted that biofuels are one of two valid ways of transport decarbonisation (incl. electromobility) and at the same time an important partner for agrosector as uptaker of agriculture production and feed supplier. They assume that the role of biofuels is crucial in the decarbonisation of transport in Slovakia as the study called 2030 Transport Decarbonisation Options (Ecofys, 2019) shows, demonstrating the potential of the Central and Eastern Europe (CEE) region for biofuel production.

The development of electric vehicles and charging infrastructure has been progressing slowly in Slovakia. The Slovak Government is still considered the least active at promoting alternative fuels for transport in the whole Visegrad Group’s (V4) region. However, this should be gradually overcome by the implementation of the Action Plan on Electromobility Development in the Slovak Republic approved by the Government via its Resolution No. 110/2019 on 13 March 2019. According to the Action Plan, which has been largerly positively evaluated by the Slovak Electric Vehicle Association (SEVA), the following measures should be implemented in the years of 2019-2020: 1) Incorporation of the topic of electromobility into all relevant national strategies and policies, 2) Accelerated (or shortened) depreciation of electric vehicles and charging stations for electric vehicles, 3) Indirect financial support for electric vehicles (in the form of lower motor-vehicle taxation and registration fee), 4) Information campaign, 5) The electromobiles’ European Vehicle Number (EVN) colour introduction differentiating them from other road vehicles and allowing them driving in dedicated lanes or parking in low-emission zones, and 10 other measures were introduced. Although the aforementioned measures were assessed as positive ones, uncertainty about their successful implementation prevails. Furthermore, in spite of these measures, Slovakia is still missing further innovative initiatives in the car industry (e.g. autonomous cars) or the remission of highway tolls in the case of electromobiles, according to the Director of the Slovak Electric Vehicle Association (SEVA). Regarding the charging infrastructure, the main investors in the infrastructure are the company GreenWay Infrastructure s.r.o. and Západoslovenská energetika, a.s. (ZSE), which with a support from the EU funding instrument named the Connection Europe Facility (CEF), expands the network of charging stations. The problem is that these investments are targeted to the primary road infrastructure only (so-called TEN-T corridors). However, according to the Action Plan on Electromobility Development (Measure No. 3), the Ministry of Economy (MH SR) and the Ministry of Transport and Construction (MDV SR) should implement financial instruments covering also the infrastructure development in not-targeted regions as of 2019. Moreover, a slow expansion of electric vehicles should be addressed by the continuation of the state subsidy programme in the years 2019-2020 (Measure No. 2). In addition, the Ministry of Environment (MŽP SR) in cooperation with the Environmental Fund ("Environmentálny fond") launched a new follow-up scheme for municipalities and regions with the maximum subsidy of € 10,000 per vehicle and a minimum co-financing rate of at least 5% in March 2019. It has to be nothed that in the previous year, May 2018, the parliament (NR SR) had approved the amendments to the Energy Act (No. 251/2012 Coll.), which implemented European Commission’s requirements related to the transposition of the Third Energy Package on internal EU gas and electricity market. Among the most relevant changes belonged defining such terms as an "electric vehicle" or "charging station" that had been missing in the Slovak legislature so far.

Insufficient expertise of state officials and insufficiently qualified administrative capacity of stakeholders, especially at the Ministry of Economy (MH SR), were identified as crucial barriers hindering further development of RES-T in Slovakia. These weaknesses result in a content of legislative proposals and strategic documents that are considered to be poorly prepared. Furthermore, knowledge sharing, exchange of expertise and constructive discussion between the involved stakeholders do not work very well either.

The Government approved the National Policy for the Implementation of Alternative Fuel Infrastructure in the Slovak Republic as well as the National Political Framework for the Development of Alternative Fuels Market in November 2016. These documents should have transposed the Directive 2014/94/EU of the European Parliament and of the Council on the Deployment of Alternative Fuels Infrastructure. However, both documents were approved by the Government in the form of the Government's resolution (No. 504 and 505/2016), and according to the lawyers, this cannot be considered a proper transposition in legal terms. The reason is that the transpositions should be implemented into national legal frameworks by legally binding normative acts, and the Government's resolution is not one of them. Although the problem is not considered a significant barrier, it still poses a few constraints.

As stated by the Association for Production and Use of Biofuel (ZVVB), there is an uneven playing field between different decarbonisation options (i.e. biofuels, electricity, hydrogen) in the renewable energy sources in the transport sector (RES-T). Currently, a full life cycle assessment is absenting in the case of hydrogen and battery technology. On the other hand, the use of biofuels is regulated based on their total carbon footprint taking into account the whole life cycle, including growing the feedstock on field (seeding, cultivation, fertilising, harvesting), transport of feedstock to a biofuels production plant, processing feedstock in a biofuels production plant, biofuels distribution as well as their combustion in motors. Alternative technologies (hydrogen, batteries) have been advantaged since they are not obliged to demonstrate their full carbon footprint through the whole life cycle. In the case of these technologies, GHG emissions from the following activities are not counted: a) mining of feedstock for electricity production, e.g. natural gas or coal (electricity later used for hydrogen production from water or directly in electric vehicles); b) transport of feedstock for electricity production, e.g. trains or ships of coal, natural gas pipelines – methane leakage and natural gas pipelines compressors – based on electricity or natural gas (electricity later used for hydrogen production from water or directly in electric vehicles); c) combustion of feedstock for electricity production – e.g. coal or natural gas powerplants (electricity later used for hydrogen production from water or directly in electric vehicles); d) batteries production itself (high energy demanding process); e) mining, resp. production of feedstock for hydrogen production (natural gas, oil, carbon black, petrol coke or other fossil hydrocarbons); f) transport of feedstock for hydrogen production (natural gas, oil, carbon black, petrol coke or other fossil hydrocarbons); g) energy production for hydrogen production from natural gas, oil, carbon black, petrol coke or other fossil hydrocarbons. To sum up, proper analysis and comparison on the same backgrounds means that GHG friendliness of hydrogen and batteries technologies is much worse than proclaimed nowadays and real GHG emission are much higher, certainly not zero as widely promoted, according to the ZVVB. This uneven approach is considered a real obstacle in achieving higher biofuels usage in transport (and thus higher RES-T utilisation), and an equivalent approach in the case of all technologies should therefore be introduced. Finally, the double-counting of advanced biofuels also counteracts their deployment in the RES-T sector, according to the ZVVB.

According to the Association for Production and Use of Biofuel (ZVVB), there is a strong interconnection of fuel markets and multinational refineries. Today, oil refineries produce and sell on several markets, causing that markets are to some extent integrated (e.g. HU+SK+CZ and/or PL+CZ). As a result of this process, pushing forward the change is even more difficult. Moreover, refineries are major employers and still have strong influence on governmental decisions also in the RES-T sector. As reported by the ZVVB, refineries perceive each litre of biofuels as an “enemy” to their fossil product, and the ZVVB perceives refineries as one of the major obstacles hindering wider RES implementation in the Visegrad Group's (V4) region, including Slovakia.