UAE Law and Practice Contributed by: Brendan Hundt, Dan Feldman, Sam Anastasiou and Saiesh Kamath, King & Spalding LLP
own target to meet 60% of its total energy demand from renewable and clean sources by 2035. Dubai continues to expand its world-leading Moham- med bin Rashid Al Maktoum Solar Park and to pursue its clean-energy strategy through DEWA-led procure- ment and distributed solar initiatives. These initiatives are cornerstones of Dubai’s Clean Energy Strategy 2050, which targets 36% of its energy demand being supplied from clean sources by 2030 (recently revised upward from 25%), increasing to 100% by 2050. The Mohammed bin Rashid Al Maktoum Solar Park is expected to exceed 8,000 MW capacity by 2030 and represents an investment of approximately AED50 bil- lion. These clean-energy policies are driving the procure- ment of new renewable and BESS assets, project design, grid reinforcement, storage requirements, decarbonisation expectations and the way large elec- tricity users present their demand to utilities. 1.8 Unique Aspects of the Power Industry The UAE power sector is distinctive because nation- al energy policy is ambitious, but implementation remains highly emirate-specific. Abu Dhabi and Dubai have developed formal utility-scale procure- ment models for IPP and renewable projects, while Sharjah and the Northern Emirates remain more inte- grated and utility-led, with limited “IPP-style” excep- tions. The UAE also combines large-scale gas-fired generation with rapid deployment of solar and battery storage, which makes system planning more complex but also gives utilities multiple tools to use to pursue decarbonisation initiatives and improve reliability. This system, while complex, balances core energy policy goals: procuring energy that is secure, affordable and, increasingly, low-carbon. The inclusion of nuclear power in the UAE is distinc- tive – the UAE was the first Arab nation in the world to build and operate a commercial nuclear power plant. The Barakah Nuclear Energy Plant in Abu Dhabi’s Al Dhafra region comprises four 1.4 GW reactors, total- ling 5.6 GW, and is capable of producing around 40 TWh of electricity annually. When all four units came online, Barakah was reported to provide approxi- mately 25% of the UAE’s electricity needs, though
the actual generation share in 2024 may have been 20% as overall electricity demand continued to grow. A further distinctive feature is the development of clean-energy attribute products alongside physical electricity procurement. Abu Dhabi’s Clean Energy Certificates scheme allows renewable and nuclear electricity attributes to be tracked, issued and traded through the International Renewable Energy Cer- tificates (I-REC) framework, with the Department of Energy acting as issuer and EWEC acting as the single registrant for clean electricity injected into the grid from licensed generation entities. This is impor- tant for corporate customers because it provides a recognised route to claim low-carbon electricity use without creating a right to buy electricity directly from a generator. A feature that distinguishes the UAE from most power markets is that electricity and water are often pro- cured, planned and dispatched together. The single- buyer utilities (EWEC in Abu Dhabi, DEWA in Dubai) are water-and-electricity entities and generation is his- torically delivered through the combined Independent Water and Power Producer (IWPP) projects model. This tight coupling means decarbonisation targets extend to “nearly emissions-free water production by 2030”. A further distinctive feature of Abu Dhabi’s model is the speed with which the sector can adjust pro- curement to meet strategic demand growth. EWEC’s central role in demand forecasting, capacity planning, procurement and system dispatch allows Abu Dhabi to pursue large-scale clean energy procurement while also securing dispatchable capacity where required for reliability. This has become important in the context of AI and digital infrastructure demand. For example, the 1 GW Al Dhafra Gas Turbine Power Plant is being developed at an accelerated pace under a 24-year PPA with EWEC to supply power to data-centre pro- jects and support the UAE National Strategy for Artifi- cial Intelligence 2031. Separately, EWEC’s Al Nouf IPP is planned as a carbon-capture-ready CCGT project of up to 3.3 GW, providing transitional capacity and system flexibility while renewable and clean-energy capacity is integrated into the grid. These examples demonstrate the flexibility of Abu Dhabi’s single-buyer
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