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Fitness check – energy security architecture

Energy

The EU has a comprehensive, yet sectorally divided, energy security architecture. During the energy crisis caused by Russia’s invasion of Ukraine, gaps in the EU’s legislative framework were identified, while the ongoing clean energy transition is changing the energy landscape. In that context, the Commission aims to evaluate the performance of the EU’s energy security architecture by means of a fitness check.

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Public consultation

ID: 14392

Lobbying Activity

40 responses

Environmental groups urge complete shift to renewables for energy security

European Environmental Bureau, 26 Nov 2024

The organization demands EU prioritize 100% renewable energy and energy efficiency over continued fossil fuel and nuclear dependence. They argue LNG prolongs fuel dependency and nuclear creates security risks through Russian imports. They call for decarbonization through heat pumps and building-integrated solar, emphasizing energy demand reduction as the most important security tool.
This would advance their climate agenda while eliminating competing energy sources.
Nuclear and gas industries lose market access and existing infrastructure investments.

Eurelectric urges new strategy focused on homegrown electrification

Eurelectric aisbl, 26 Nov 2024

The association proposes a 'Security of Supply 2.0' strategy centered on home-grown electrification. They want broader system assessments including flexibility, cybersecurity, and resilience to extreme climate events.
This framework provides industry members with investment certainty for new power infrastructure.
Non-EU fossil fuel suppliers lose market power as Europe seeks energy independence.

ENGIE calls for market-based energy security with sector integration

ENGIE, 26 Nov 2024

ENGIE requests maintaining undistorted price signals on wholesale markets while completing missing framework pieces like bilateral solidarity agreements. They emphasize energy efficiency, supply diversification, and sector integration across electricity, gases, and heat. Emergency demand reduction measures should remain temporary.
This would protect their gas infrastructure investments and create demand for flexibility services.
Consumers lose stronger protections against price volatility and market manipulation during crises.

Ørsted urges EU to prioritize renewables for energy security

Ørsted A/S, 26 Nov 2024

Ørsted advocates for phasing out fossil fuel imports in favor of domestic renewable energy. They call for enhanced protection of offshore infrastructure against state-sponsored sabotage and hybrid warfare. They also stress maintaining integrated energy markets while avoiding disruptive price interventions.
This would make the company's energy production assets immune to global supply shocks.
Fossil fuel exporters would lose market share as Europe transitions to domestic energy sources.

BDEW calls for market-led approach to EU energy security

BDEW Bundesverband der Energie- und Wasserwirtschaft e. V., 26 Nov 2024

They advocate for market-based price signals and a stronger three-stage emergency mechanism. They also demand more flexible storage rules and clear gas demand scenarios.
Reducing regulatory complexity and demand uncertainty would lower costs and investment risks.
Vulnerable consumers lose protection if the EU prioritizes price signals over caps.

IOGP Europe urges EU to prioritize domestic energy production

International Association of Oil Gas Producers Europe, 26 Nov 2024

IOGP Europe calls for the promotion of domestic oil and gas production. They request realistic demand outlooks and stable, non-prescriptive regulatory frameworks. The association argues that direct government interventions should be avoided.
Less regulation would reduce compliance risks and facilitate investment in gas infrastructure.
Climate goals are threatened by a renewed focus on long-term fossil fuel infrastructure.

Equinor urges EU to protect gas infrastructure and market stability

Equinor ASA, 26 Nov 2024

Equinor recommends that natural gas networks be properly maintained and developed where necessary. They support funding policies that emphasize technology neutrality and caution against intervening in price setting.
Equinor safeguards its natural gas business while securing subsidies for its renewable energy transition.
Environmental groups lose if the EU delays the decommissioning of fossil fuel infrastructure.

Consultation response

European Alliance to Save Energy, 26 Nov 2024

Recent geopolitical crises and heightened climate risks have underscored the urgent need for a resilient and independent EU energy security framework. While the EU has made notable advances in reducing fossil fuel imports following the Russian invasion of Ukraine, the reliance on other non-EU…

Euroheat & Power calls for district energy in security framework

Euroheat and Power, 26 Nov 2024

Euroheat & Power demands integrating district energy into the EU security framework to reduce gas imports. They request streamlined State aid and new de-risking instruments for heat network investments.
These policy changes would facilitate significant capital investment and expand their market presence.
Foreign fossil fuel suppliers would lose significant market share as heat networks expand.

Coalition for Energy Savings urges demand-focused security architecture

The Coalition for Energy Savings, 26 Nov 2024

The Coalition calls for shifting focus from supply diversification to permanent energy demand reduction. They demand structural measures that align energy security with the EU's long-term climate goals.
Prioritizing efficiency justifies the group’s mission and lowers system-wide infrastructure maintenance costs.
Fossil fuel exporters and energy importers lose market share as consumption drops.

Bellona Europa Urges Linking Energy Security with Climate Action

Bellona Europa, 26 Nov 2024

The organization calls for prioritizing renewable energy targets and accelerating electrification to reduce reliance on imported fossil fuels. They advocate for boosting investment in cross-border infrastructure and energy storage to enhance system flexibility.
Implementing these changes would align EU energy policy with the organization's climate-focused environmental mission.
External fossil fuel suppliers would lose market share as Europe reduces its import dependency.

Eurima urges EU to prioritize insulation for energy security

European Insulation Manufacturers Association, 26 Nov 2024

Eurima calls for prioritizing building renovations and energy efficiency within the EU’s energy security framework. They recommend mandatory renovation targets for all buildings and subsidies for insulation audits.
The proposal would boost demand for insulation products and ensure stable market conditions.
Fossil fuel suppliers would face a sharp decline in demand for heating fuels.

Solar Council Urges EU Measures to Combat Chinese Import Dependency

European Solar Manufacturing Council, 26 Nov 2024

The council calls for concrete energy security measures and off-take commitments for solar manufacturers. They advocate for EU compensation of operational expenditures to level the playing field against China.
This would protect local industry and create more competitive market conditions for manufacturers.
Chinese manufacturers lose their market dominance if the EU implements these protective measures.

REScoop.eu calls for local ownership of renewable energy

REScoop.eu vzw, 26 Nov 2024

The organization calls for a framework that eliminates reliance on fossil gas. They want the EU to empower local communities to own energy production. The market should reward flexible production and consumption at local levels.
Cooperatives would gain financial stability and independence from volatile wholesale electricity markets.
Large energy companies would lose market dominance and access to public subsidies.

Statkraft defends market-based pricing for EU energy security

Statkraft AS, 26 Nov 2024

Statkraft emphasizes maintaining the marginal pricing principle to ensure efficient resource use during energy crises. They also highlight the need for integrated infrastructure to enable electricity flows between markets.
Retaining market-based prices protects the profitability of their renewable energy production.
Consumers face significantly higher costs when market prices respond to energy scarcity.

Solar thermal industry urges domestic heating strategy for energy security

Solar Heat Europe/ESTIF, 26 Nov 2024

The association calls for an urgent update to the European Union's heating and cooling strategy. They advocate for increasing thermal energy storage and utilizing local renewable resources to reduce dependency.
Prioritizing local heat generation strengthens the market position of European solar thermal manufacturers.
External energy exporters and developers of hydrogen fuels face reduced long-term influence.

Energy Cities urges local focus for EU energy security

Energy Cities, 26 Nov 2024

The organization requests that the EU prioritize reducing demand through sufficiency measures. They advocate for local ownership of renewable energy and integrated energy planning at the district level.
Local authorities would receive more funding and legal authority to transition away from fossil fuels.
Foreign fossil fuel suppliers and wholesale market operators would lose market share and price influence.

Naftogaz urges EU to integrate Ukrainian gas storage capacity

Naftogaz of Ukraine, 25 Nov 2024

Naftogaz requests that the EU allow Ukrainian gas storage to fulfill member state stockpiling requirements. They also advocate for harmonized transit tariffs and EU-backed financial guarantees to address war-related security concerns.
This would increase the commercial utilization of Ukraine's massive excess gas storage capacity.
European gas grid operators would lose revenue from accumulated transit fees and levies.

National Grid Urges Closer EU-UK Cooperation on Energy Security

National Grid Commercial Holdings Limited, 26 Nov 2024

The group requests a new efficient UK-EU electricity trading regime and linked carbon markets. They advocate for very close cooperation between grid operators on planning and cybersecurity.
Linking carbon markets would protect the company's revenue and business case for new interconnectors.
Consumers face billions in higher electricity costs and increased emissions without market integration.

EASE urges EU energy storage Action Plan

European Association for Storage of Energy, 26 Nov 2024

EASE requests a Commission Action Plan on energy storage with clear targets. They advocate for placing storage at the centre of electricity risk-preparedness. Harmonised policies and market designs are also sought to encourage infrastructure investment.
This would create strong investment signals and accelerate deployment of storage technologies.
Polluting gas power plants and fossil fuel providers lose their market position.

Tree Energy Solutions calls for EU renewable gas storage quotas

Tree Energy Solutions BV, 26 Nov 2024

TES requests a dedicated storage quota and an injection mandate for renewable gases. They advocate including hydrogen alternatives in security laws to protect industrial business continuity.
Incentivizing e-NG would reduce the company's investment risks and boost infrastructure utilization.
Suppliers from geopolitically challenging regions will lose market share to local renewable gas production.

CEWEP urges recognition of waste-to-energy as critical infrastructure

Confederation of European Waste-to-Energy Plants, 26 Nov 2024

CEWEP advocates for expanding domestic waste-to-energy capacity to strengthen energy security. They propose using non-recyclable waste to supply reliable electricity, heat, and industrial steam.
The sector would gain political and financial backing for new infrastructure projects.
Fossil fuel importers lose market share to local, waste-derived energy production.

Consultation response

Axpo Holding AG, 26 Nov 2024

Given Switzerland's central geographical position in Europe and its crucial role as an electricity hub for the synchronous grid of continental Europe, as well as its key role in trans-European gas and (future) hydrogen flows, EU-Swiss cooperation on energy security is of great importance for…

Consultation response

Future Cleantech Architects, 26 Nov 2024

EU's energy security architecture is critical as Europe seeks a sustainable, reliable energy supply. As a climate innovation think tank focused on decarbonizing hard-to-abate sectors and cleantech, we want to stress the need to align energy security with the clean energy transition. To secure a…

Consultation response

Sandbag Climate Campaign CIC, 25 Nov 2024

Energy security has risen to the top of the EUs political agenda, yet much remains to be done. The EU cannot continue relying on imported fossil fuels, putting its energy security in the hands of hostile nations. Solutions like wind, solar, battery storage, demand flexibility and electrification of…

Consultation response

European Academies Science Advisory Council, 20 Nov 2024

Europes national academies of science, through EASAC, have been working during 2024 on a report for EU policy makers on Security of Sustainable Energy Supplies, to be published in April 2025. Our report will present independent science-based advice on policies and measures for delivering secure…

Consultation response

The Shift Project, 26 Nov 2024

Despite increased awareness on energy dependency issues following the 2022 Russian gas crisis, the EU remains exposed to significant energy and strategic vulnerabilities.First, the EU is almost entirely dependent on imports for its oil and gas consumption 97.7% and 98%, respectively, in 2022. This…

EFIEES Urges EU to Make Energy Efficiency a Security Pillar

European Federation of Intelligent Energy Efficiency Services, 26 Nov 2024

EFIEES demands that the EU energy security framework shifts focus from supply-side measures to demand management. They want efficient district heating networks and energy management solutions integrated as central pillars.
This would expand the market for energy management solutions and local thermal infrastructure projects.
Fossil fuel importers lose business as efficiency gains significantly decrease the demand for energy imports.

Consultation response

Federation of European Tank Storage Associations, 21 Nov 2024

Please see the attached position paper and link to the related study on the role of storage infrastructure for both security of supply and the energy transition. https://fetsa.eu/wp-content/uploads/2024/07/FETSA-Energy-Transition-Publication-pack-01-07-24.pdf You can contact me for the full study…

Consultation response

UAP Coalitie Nederland, 21 Nov 2024

UAP Coalition Netherlands (UAPCNL) is a non-profit NGO dedicated to representing professionals from aviation, the armed forces, and law enforcement who have encountered Unidentified Anomalous Phenomena (UAP). UAPCNL commends the European Commission's efforts to enhance the security of EU energy…

Consultation response

Buildings Performance Institute Europe, BPIE ASBL, 25 Nov 2024

BPIE's feedback is attached in the enclosed PDF.

Consultation response

Cool Heating Coalition, 25 Nov 2024

CHC, an EU-level umbrella organisation of 16 NGOs and think tanks, welcomes the opportunity to provide input to the European Commission on the EUs energy security architecture. Our vision is for decarbonised, renewable and affordable heating and cooling (H&C) to be a reality in the EU by 2040, a…

Consultation response

Fronius International GmbH, 26 Nov 2024

To maximize European energy security and sovereignty, it is important and necessary that we continue to expand Europe's renewable energy supply as quickly as possible. However, framework conditions must be created as a matter of urgency to ensure that the sovereignty for remote control of the…

Consultation response

Fachverband der Elektro- und Elektronikindustrie, 26 Nov 2024

Goals of the EU Architecture for Energy Supply Security Comments: Devices connected to the internet require software updates to remain secure. For the software update, the manufacturer has full access to all functions of the device. This could also introduce unwanted additional functions, such as…

VÖWG Backs Systematic Review of Energy Security Rules

VÖWG, 19 Nov 2024

VÖWG supports the systematic fitness check of the energy security legal framework. They emphasize that regular evaluation is essential to address technological and geopolitical challenges.
Updated regulations help public service providers ensure long-term energy supply security.

U.Di.Con. demands structural EU measures to protect energy consumers

U.Di.Con. APS Unione per la Difesa dei Consumatori, 13 Nov 2024

The group demands stronger price limits and rules to stop speculators from driving up costs during crises. They want the EU to manage energy buying and storage collectively to ensure supply independence. They also call for clear labels to help people identify real renewable energy offers.
Stable energy prices would protect households from inflation and preserve their purchasing power.
Energy companies and financial traders would lose the ability to profit from market volatility.

French energy federation urges EU to prioritize heat decarbonization

Fédération des services énergie environnement, 26 Nov 2024

FEDENE demands that heating and cooling solutions become central to energy security. They advocate for district heating networks and energy efficiency to reduce gas imports.
Proposed changes would increase demand for services provided by FEDENE's member companies.
International fossil fuel suppliers lose market share as Europe prioritizes local heat production.

Consultation response

, 26 Nov 2024

Das geltende EU-Recht und weitere Rahmenbedingungen sind insgesamt geeignet, um Energiekrisen zu bewältigen und die Aufrechterhaltung in der Energieversorgung sicherzustellen. Das aktuell etablierte System, einschließlich der EU-Vorgaben und den nationalen Detaillierungen, kann als steady system…

Consultation response

ABE-METASystems, 14 Nov 2024

Inverters for solar energy are widespread in Europe. These inverters are key element for the plan of energy resilience for 2035 with 42% electricity capacities increase, splitter mainly between nuclear and renewables sources, which includes solar energy as main contributor. These inverters are…

Consultation response

imprenditori accademia digitale italia, 30 Oct 2024

Gli imprenditori accademia digitale italia, avente un gruppo scientifico di ingegneri che già sviluppano un progetti, e si avvalgono delle line guide europee, rientrano con la legislazione dellUE sulla riduzione delle emissioni nazionali di determinati inquinanti atmosferici, bisogna seguire una…