Australia’s new $10 billion Clean Energy Finance Corporation, which will provide investment and green loans to businesses, is similar in concept to policies underway in the United Kingdom and the United States.

Half of the money from the CEFC will go to energy efficiency and low emissions measures and the other half will go to renewable energy projects. But success overseas has been varied, with high expectations, company collapses and problems with financial viability.

In the UK — where Prime Minister David Cameron promised to lead the “greenest government ever” — his administration is still in the processing of developing its Green Investment Bank. Its executive director Oliver Griffiths announced this week that the GIB should be fully operational by the end of 2012 — several months later than originally planned — although initial investments were beginning this month.

The £3 billion project will be the world’s first environmental investment bank, and plans to invest £775 million in its first financial year. It won’t have any borrowing power until at least 2015, but there are other programs already up and running, including UK Green Investments which will invest in green infrastructure — £200 million in total — until the GIB receives state aid approval.

Offshore wind has proved a popular renewable investment in the UK, although they cost double as much as onshore turbines and offshore wind companies remain reliant on the £1 billion paid annually in government subsidies.

Plus, a three-year deal between Siemens and the Carbon Trust was recently announced which will see £550 million worth of business loans handed out to help increase energy efficiency measures in businesses, with the reduction in energy bills expected to match loan repayments. The Carbon Trust is a government-funded organisation, although Cameron sliced its funding by 40% last year.

Across the Atlantic, the US government has been guaranteeing green loans over the last few years rather than fronting up the cash. Not that loans are the most critical part for businesses investing. “The cash is almost a secondary issue, it’s who takes the credit risk on the guarantee,” Dr Stuart Nettleton, a senior lecturer in management and systems and energy policy at UTS, told Crikey.

Yet just this week it was announced that First Solar — a US solar panel manufacturer — will close a German plant and lay off 2000 workers internationally, partly due to a reduction in solar subsidies in Germany. It will now be forced to write down US$150 million in assets and return US$30 million in government funding. First Solar has previously received a US$1.46 billion loan guarantee from the US Department of Energy.

“We have to carefully distinguish between energy projects and production of devices such as solar panels,” Nettleton told Crikey. He noted Germany — whose KfW bank will commit 100 billion euros for green loans over the next five years — is phasing out its solar power subsidies due to high costs and inefficient returns.

First Solar is not the only high-profile government-backed renewable company with problems, reports Sunil Sharhan in Fortune:

“Solyndra, the solar company that received US$535 million and shuttered last summer; battery company Ener1, which after receiving US$118 million declared bankruptcy this year; and auto company Fisker, which was awarded US$529 million from a US$25 billion Advanced Technology Vehicle Manufacturing program created in 2007, received US$193 million in 2010, but is struggling now to draw down the remaining US$336 million from the Department of Energy. Reportedly over US$16 billion of federal green loans have been given to companies either run or primarily owned by Obama financial backers.”

What CEFC investments are likely to succeed in Australia? “Perhaps the only renewable energy technology approaching cost-effectiveness is indeed fourth-generation nuclear,” said Nettleton. “Nuclear at the moment is illegal in Australia, but I suspect that will change over time because the answer in the future is a mixture of nuclear and solar and geothermal if that’s possible.”

Solar technology will also struggle to viability. “[It] depends how much the government is prepared to suffer financial hurt as to how much it will go with solar,” Nettleton said. “For a solar project to proceed at the moment would actually be very unlikely in terms of feedback of financial returns and risks that I’ve seen in the market.”

Don’t discount solar energy projects yet though. “It does have a future role, but it doesn’t yet fulfil the potential that people had hoped it would in terms of driving viable projects,” he added.

And another issue: the Greens demanded carbon capture and storage technology be banned from the CEFC. “There is no solution at the moment without the success of carbon capture and storage or without the acceptance of nuclear power or without the fortuitous ability to use geothermal,” said Nettleton.