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Association for District Heating of the Czech Republic

ADH CR

Association for District Heating of the Czech Republic represents companies providing district heating and combined heat and power generation in the Czech Republic.

Lobbying Activity

Czech heating industry urges Taxonomy alignment with energy laws

5 Dec 2025
Topic — The initiative reviews technical screening criteria for the EU Taxonomy environmental acts.
Message — The association requests aligning the Taxonomy definition of district heating with the latest Energy Efficiency Directive to ensure regulatory stability. They also propose removing unfeasible cumulative emission requirements for gas-based cogeneration plants to facilitate coal replacement. Finally, bioenergy criteria should remain consistent with existing renewable energy rules rather than becoming stricter.123
Why — These changes would lower administrative burdens and unlock financing for necessary coal-to-gas infrastructure transitions.45
Impact — Climate advocates lose through weakened emission thresholds and extended deadlines for switching to renewable gases.6
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Czech heat industry urges EU to prioritize district heating networks

9 Oct 2025
Topic — The EU Electrification Action Plan aims to transition energy demand from fossil fuels to electricity.
Message — The group urges the EU to support district heating networks through dynamic electricity tariffs and the full implementation of carbon pricing. They also call for faster grid connections for flexible energy storage and heating technologies.12
Why — This would make large-scale heat pump investments profitable by reducing operating costs compared to gas boilers.34
Impact — Gas boiler operators and fossil fuel suppliers will face higher costs and reduced market share.56
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Czech district heating group urges stable regulations and funding

9 Oct 2025
Topic — New EU strategy aimed at accelerating the decarbonisation of heating and cooling.
Message — The association requests that policymakers avoid reopening current energy laws to maintain investment visibility. They also call for higher state aid limits and redesigned electricity tariffs.123
Why — Increased regulatory certainty and higher subsidies would lower capital costs for infrastructure projects.4
Impact — Industrial facilities and data centers may face mandatory requirements to share waste heat.5
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Czech heating industry urges lower 2040 EU emission target

8 Sept 2025
Topic — The European Commission is proposing a 90 percent greenhouse gas reduction target for 2040.
Message — The association requests lowering the 2040 climate target to 78 percent to match a steady reduction path. They also want to remove secondary targets and extend deadlines for gas and nuclear power.123
Why — Lower targets and extended deadlines would reduce financial pressure and maintain affordable heating prices.4
Impact — Environmental groups lose if waste-to-energy exemptions encourage landfilling over cleaner waste treatment options.5
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Czech district heating lobby seeks formal EU grid status

5 Aug 2025
Topic — EU initiative to modernize energy infrastructure and accelerate the green grid expansion.
Message — The group wants the EU to formally recognize district heating as a major energy grid. It calls for including thermal infrastructure in central planning and funding frameworks. They also seek faster permitting for clean heating and cooling projects.12
Why — Formal recognition would unlock significant investment and financial support for Czech heating networks.3
Impact — Inefficient electricity-only power plants would lose their current regulatory advantage over heat systems.4
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Response to Review of the State aid rules on the Services of General Economic Interest (“SGEI”)

31 Jul 2025

Association for District Heating of the Czech Republic (ADH CR) welcomes opportunity to comment on the initiative State aid - revision of the rules on services of general economic interest. Please find detailed comments in the Attachment.
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Response to Modernisation Fund - first evaluation of the operating rules

26 May 2025

Association for District Heating of the Czech Republic (ADH CR) welcomes opportunity to comment on the initiative Modernisation Fund first evaluation of the operating rules. Please find detailed comments in the Attachment.
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Czech District Heating Group Demands Fair Energy Performance Metrics

7 May 2025
Topic — A consultation on revising the methodology for calculating cost-optimal building energy performance levels.
Message — ADH CR requests allowing national metrics like non-renewable primary energy. They also demand treating nearby renewable energy the same as on-site production. This ensures technological neutrality between district heating and local heat pumps.12
Why — This ensures district heating remains a viable, cost-effective option compared to on-site alternatives.3
Impact — Providers of on-site technologies lose the competitive advantage granted by biased energy accounting rules.4
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Response to Ecodesign requirements for air heating and cooling products (review)

29 Aug 2024

Association for District Heating of the Czech Republic (ADH CR) welcomes opportunity to comment on the initiative "Energy efficiency ecodesign requirements for air heating and cooling products (review)". Please find detailed comments in the Attachment.
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Response to Environmental Implementation Review 2025

4 Jul 2024

Association for District Heating of the Czech Republic (ADH CR) welcomes opportunity to comment on the initiative EU environmental law 2025 implementation review. Please find detailed comments in the Attachment.
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Response to Evaluation of the National Emission reduction Commitments Directive

13 Mar 2024

Association for District Heating of the Czech Republic (ADH CR) welcomes opportunity to comment on the initiative National Emission Reduction Commitments Directive evaluation. Please find detailed comments in the Attachment.
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Czech heating association urges flexible rules for free allowances

2 Jan 2024
Topic — Update to rules for free allocation of emission allowances under ETS.
Message — The organization requests a mechanism to reduce free allocation proportionally to the cost of unimplemented energy audit recommendations. They also want to limit public disclosure of sensitive investment data within climate neutrality plans.12
Why — This protects heating providers from heavy financial penalties due to minor investment delays.3
Impact — Transparency advocates lose access to detailed corporate roadmaps for achieving climate neutrality.4
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Czech heating group urges exemptions from soil monitoring rules

3 Nov 2023
Topic — A proposal to define healthy soil and monitor its sustainable restoration.
Message — ADH CR requests that the directive excludes installations already regulated under the Industrial Emissions Directive. They argue existing baseline reports and integrated permits provide sufficient soil monitoring and protection.12
Why — This exemption would prevent district heating plants from facing redundant administrative burdens and costs.3
Impact — Environmental protection efforts could be delayed by postponing site assessments until plant closures.4
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Czech District Heating Group Urges Flexible Climate Neutrality Plans

1 Sept 2023
Topic — Rules defining the content and format of mandatory climate-neutrality plans for industrial installations.
Message — The association requests flexibility to adjust plans based on external factors like energy crises. They also suggest aggregating plans for multiple installations and focusing on milestones instead of emissions.123
Why — This would reduce administrative burdens and protect companies from penalties during unforeseen economic crises.4
Impact — Environmental transparency may suffer if binding emission reduction targets are replaced by flexible investments.5
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Czech heating group opposes retroactive EU energy fund rules

29 Aug 2023
Topic — Revision of rules for the Modernisation Fund supporting energy transitions in lower-income Member States.
Message — The association opposes retroactive rule changes for energy projects already approved before 2024. They propose increasing funding thresholds and removing extra stakeholder consultation requirements to speed up modernization.123
Why — This would protect existing funding agreements and minimize bureaucratic hurdles for major investments.45
Impact — Local residents lose a specific mandatory platform to influence large energy infrastructure developments.6
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Czech heating industry rejects proposed EU registry account fees

28 Aug 2023
Topic — The consultation updates the EU carbon registry to include maritime and aviation.
Message — ADH CR demands deleting provisions allowing the European Commission to charge annual fees. They advocate for maintaining rules where only national administrators can charge reasonable fees.12
Why — Avoiding these fees reduces financial pressure on heating operators undergoing expensive environmental transformations.34
Impact — The European Commission loses a new dedicated funding source for registry maintenance costs.5
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Czech district heating association urges flexible biomass and waste rules

23 Aug 2023
Topic — The consultation aims to update rules for monitoring and reporting greenhouse gas emissions.
Message — ADH CR requests that sustainability criteria only apply to specific units using biomass. They also propose lower emission factors for the non-biomass portion of municipal waste.12
Why — This allows association members to modernize plants gradually, reducing immediate capital expenditure and logistics.34
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Czech heating association urges support for large-scale heat pumps

26 May 2023
Topic — This consultation addresses an action plan to accelerate heat pump deployment across Europe.
Message — The association calls for mandatory local heating planning and zoning for cities to identify clean energy sources. They propose de-risking instruments and an EU guarantee scheme for large-scale geothermal and thermal-loop projects. Additionally, they request new grid connection products to reduce high fees for power-to-heat systems.123
Why — This would lower capital costs and financial risks for decarbonizing district heating systems.4
Impact — Municipalities would face new mandatory administrative burdens for local energy planning and zoning.5
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Czech heating association urges stability in electricity market reform

23 May 2023
Topic — The EU is revising electricity market rules to lower prices and support green energy.
Message — The association calls for flexible capacity mechanisms to support retiring coal plants and opposes new peak shaving products. They argue that energy storage development should be driven by market forces rather than targets.123
Why — Simplified capacity mechanisms would secure funding for the sector's expensive shift away from coal.45
Impact — Households could face higher energy bills if new products increase overall electricity system costs.6
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ADH CR urges wastewater heat recovery for district heating

14 Mar 2023
Topic — The EU is updating rules for urban wastewater treatment to enhance environmental protection.
Message — The group proposes using wastewater treatment plants as sources of clean thermal energy. They want the Commission to include heat recovery under energy neutrality rules.12
Why — This provides a cost-effective method to replace coal and reach carbon neutrality.3
Impact — Fossil fuel suppliers lose market share as heating systems transition to renewable heat.4
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Czech district heating group urges realistic air quality standards

14 Mar 2023
Topic — The EU is revising air quality standards to align with health recommendations.
Message — The organization insists that air quality standards must be technically and economically feasible to avoid disrupting the energy transition. They also request that pollution reduction measures be distributed fairly among all contributors rather than just targeting industry.12
Why — This would prevent costly technical upgrades for heating plants already scheduled for phase-out.3
Impact — Citizens seeking health damages lose easier legal pathways if the burden of proof remains unchanged.4
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Response to Review of cogeneration reference values

29 Dec 2022

Association for District Heating of the Czech Republic (ADH CR) welcomes opportunity to comment on the Proposal for a COMMISSION DELEGATED REGULATION (EU) amending Commission Delegated Regulation (EU) 2015/2402 as regards the review of harmonised efficiency reference values for separate production of electricity and heat in application of Directive (EU) 2012/27/EU of the European Parliament and of the Council. Please find detailed comments in the Attachment.
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Response to Fitness check of how the Polluter Pays Principle is applied to the environment

9 Dec 2022

Association for District Heating of the Czech Republic (ADH CR) welcomes opportunity to comment on the initiative Polluter Pays Principle fitness check of its application to the environment. Please find detailed comments in the Attachment.
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Czech district heating association opposes higher chemical agency fees

10 Oct 2022
Topic — This initiative aims to strengthen ECHA governance and adapt its future funding model.
Message — ADH CR is fundamentally against increasing current fees or even introducing new ones. They propose seeking financial resources through internal savings and existing agency tools.12
Why — Avoiding new costs helps utilities maintain energy affordability during the sector's transformation.3
Impact — Vulnerable households may suffer if fee increases lead to higher heating bills.45
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Czech district heating association calls for immediate landfilling ban

29 Jul 2022
Topic — The Commission is assessing Member States' progress on 2025 recycling and 2035 landfilling targets.
Message — The association suggests that EU reports should prioritize tracking greenhouse gas emissions and fires at landfill sites. They urge the Commission to recommend a total ban on landfilling municipal waste as soon as possible.12
Why — Diverting waste from landfills would secure a fuel source to help the sector replace coal.3
Impact — Landfill operators would lose business as nearly half of municipal waste is currently buried.4
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Czech heating industry urges monitoring of landfill environmental impacts

3 Jun 2022
Topic — The Commission is revising indicators to assess progress towards a circular economy.
Message — The association proposes that the monitoring framework prioritize tracking the negative impacts of landfilling. It suggests measuring greenhouse gas releases, material losses, and incidents of landfill fires.12
Why — Monitoring landfilling's downsides promotes waste-to-energy as a viable alternative to fossil fuels.3
Impact — Landfill operators face increased pressure as their environmental and energy losses are highlighted.4
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Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

31 Mar 2022

Association for District Heating of the Czech Republic (ADH CR) welcomes opportunity to comment on the „Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on the energy performance of buildings (recast)”. Please find detailed comments in the Attachment.
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Response to Waste Framework review to reduce waste and the environmental impact of waste management

22 Feb 2022

Association for District Heating of the Czech Republic (ADH CR) welcomes opportunity to comment on the call for evidence for an impact assessment „Environmental impact of waste management – revision of EU waste framework”. Please find detailed comments in the Attachment.
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Response to Act amending Implementing Regulation (EU) 2018/2066 on the monitoring and reporting of greenhouse gas emissions

10 Jan 2022

Association for District Heating of the Czech Republic (ADH CR) welcomes opportunity to comment on the „Proposal of Commission implementing regulation amending Implementing Regulation (EU) 2018/2066 of 19 December 2018 on the monitoring and reporting of greenhouse gas emissions pursuant to Directive 2003/87/EC of the European Parliament and of the Council”. Please find detailed comments in the Attachment.
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Response to Review of Directive 2012/27/EU on energy efficiency

19 Nov 2021

Association for District Heating of the Czech Republic (ADH CR) welcomes opportunity to comment on the „Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on energy efficiency (recast)“. Please find detailed comments in the Attachment.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

18 Nov 2021

Association for District Heating of the Czech Republic (ADH CR) welcomes opportunity to comment on the „Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Directive (EU) 2018/2001 of the European Parliament and of the Council, Regulation (EU) 2018/1999 of the European Parliament and of the Council and Directive 98/70/EC of the European Parliament and of the Council as regards the promotion of energy from renewable sources, and repealing Council Directive (EU) 2015/652“. Please find detailed comments in the Attachment.
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Response to Revision of the Energy Tax Directive

18 Nov 2021

Association for District Heating of the Czech Republic (ADH CR) welcomes opportunity to comment on the „Proposal for a COUNCIL DIRECTIVE restructuring the Union framework for the taxation of energy products and electricity (recast)“. Please find detailed comments in the Attachment.
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Response to Updating the EU Emissions Trading System

8 Nov 2021

Association for District Heating of the Czech Republic (ADH CR) welcomes opportunity to comment on the „Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Directive 2003/87/EC establishing a system for greenhouse gas emission allowance trading within the Union, Decision (EU) 2015/1814 concerning the establishment and operation of a market stability reserve for the Union greenhouse gas emission trading scheme and Regulation (EU) 2015/757“. Please find detailed comments in the Attachment.
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Response to Strengthing the Market Stability Reserve linked to the review of the EU Emissions Trading System

8 Nov 2021

Association for District Heating of the Czech Republic (ADH CR) welcomes opportunity to comment on the „Proposal for a DECISION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Decision (EU) 2015/1814 as regards the amount of allowances to be placed in the market stability reserve for the Union greenhouse gas emission trading scheme until 2030“. Please find detailed comments in the Attachment.
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Response to Guidance on REDII forest biomass sustainability criteria

28 Apr 2021

Association for District Heating of the Czech Republic (ADH CR) welcomes the opportunity to comment on the draft Commission implementing regulation on establishing operational guidance on the evidence for demonstrating compliance with the sustainability criteria for forest biomass laid down in Article 29 of Directive (EU) 2018/2001 of the European Parliament and of the Council. Sustainable forest biomass plays and will continue to play a crucial role in the energy transition of Czech district heating systems. It is one of the already available and proven solutions to cut CO2 emissions and reduce the dependence on fossil fuels. However meeting the ambitious general and renewable heating and cooling targets will require predictable and stable conditions for investments. Therefore, the focus should be on the robust and harmonised implementation of the existing stringent sustainability criteria. This will ensure that the biomass, used for efficient district heat production, meets a high standard of environmental protection while maintaining the legal certainty required for the development of new projects. Given the delay in the publication of the present implementing regulation, ADH CR calls for swift adoption, as well as a speedy process for the recognition of certification schemes to guarantee that sufficient tools are in place to demonstrate compliance for DHC operators. If this cannot be guaranteed, we would need to call for an additional transitional period to be able to meet and demonstrate compliance with the criteria with all the tools in place. ADH CR comments and targeted suggestions to improve the draft implementing regulation are in the Attachment.
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Response to Modification of the General Block Exemption Regulation for the Green Deal and the Industrial and Digital Strategies

5 Apr 2021

Association for District Heating of the Czech Republic (ADH CR) welcomes the opportunity to comment on Roadmap to Modification of the General Block Exemption Regulation for the Green Deal and the Industrial and Digital Strategies. The current framework has met the purpose of the 2014 reform of better targeted State aid. The inclusion of District Heating infrastructure in the guidelines as well as the updated notification threshold values for the DHC distribution network as well as CHP installations have resulted in quicker and easier access to aid for projects. Implementation of the European Green Deal will, however, call for more ambitious policies to deploy both renewable and waste heat to substitute direct use of fossil fuels and to fulfill the potential of system integration. In line with the 55% objective of CO2 reduction by 2030, the Commission’s 2030 Climate Target plan initiative estimates that the share of renewable heat should reach around 40% by 2030. In our opinion, the general approach governing State aid for DHC/CHP should be preserved while some adjustments must be made in the light of the experience gained with the case practice as well as to provide a framework fit-for-purpose to deliver the objectives of the Green Deal. In particular, the scope of GBER should be extended so that Member States can deploy national schemes that lead to faster access to aid for those projects aligned with the objectives of the Green deal while taking into account varying situation across Member states. Please find detailed comments in the Attachment.
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Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

22 Mar 2021

Association for District Heating of the Czech Republic (ADH CR) welcomes the opportunity to comment on Inception Impact Assessment to Revision of the Energy Performance of Buildings Directive 2010/31/EU (IIA). In light of such revision the following points should be addressed: ● Mandatory Minimum Energy Performance Standards (MEPS): Mandatory MEPS could be beneficial to further speed up building decarbonisation efforts. However, its effectiveness will depend on how this mandatory instrument will be designed. The possibility to connect to an efficient district heating network, where and when possible, should also be systematically evaluated and guaranteed within MEPS, since efficient heat supply is an essential component of a decarbonised building stock. MEPS should be consistent with EPCs and expressed in primary energy. ● Energy Performance Certificates (EPCs): EPCs are an instrument which is not yet used to its fullest potential. This is why we support the European Commission’s intention to update the EPCs framework; once this is done, EPCs should be considered as one of the main options to define MEPS. EPCs should continue to be based on primary energy with primary energy factors determined by Member states using EN 17423 "Energy performance of buildings - Determination and reporting of Primary Energy Factors (PEF) and CO2 emission coefficient – General Principles". They could also include data on the share of renewable energies in the energy mix of the building (produced and delivered both on-site as well as through district heating network), as well as recommendations on potential future works, including the potential connection to an efficient district heating network. ● Building Renovation Passports: They should consist of long-term step-by-step renovation roadmaps that include an evaluation on sustainable heating solutions, in particular on the potential to connect to an efficient district heating network. ● Promoting a district approach to energy renovation: The concept of a district approach was first introduced in the EPBD (Directive (EU) 2018/844) under article 19 and was further reiterated in Renovation Wave Initiative. This approach has numerous advantages when compared to building by building renovation: it can accelerate renovation efforts, promote faster decarbonisation of the heating and cooling through development and modernisation of district heating networks and can help identify possible interactions between various types of infrastructures and fuels, contributing towards the realisation of the smart sector integration concept. ● Decarbonisation of the fuel supply and the link between on-site and nearby RES: A revised EPBD should promote energy fuel switch from fossil to renewable energy sources, whilst ensuring equal treatment of on-site and nearby produced and supplied heat and cold. As already mentioned in Annex I of the EPBD (Directive (EU) 2018/844) and reiterated in the Renovation Wave Initiative, both on-site and nearby renewable energy sources contribute to the decarbonisation of buildings and districts of a specific area, hence a non-discriminatory approach among the two is needed. ● Renewable energy sources and waste heat: As rightly outlined in the Renovation Wave Initiative, both renewable energy sources and waste heat recovery play a key role in the decarbonisation of the EU building stock. Therefore, they should be treated equally when it comes to meeting the renewable targets for heating and cooling, district heating and cooling and buildings, especially in the framework of MEPS and Renovation Passports.
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Response to Revision of EU rules on Gas

10 Mar 2021

Association for District Heating of the Czech Republic (ADH CR) welcomes the opportunity to comment on Roadmap to Hydrogen and Gas markets Decarbonisation Package (Roadmap). AHD CR understands Gas markets decarbonisation as major tool how to deliver on ambitious EU targets for 2030 and 2050 as well. ADH CR would like to raise following issues: 1. AH CR emphasizes that district heating sector in the Czech Republic is still largely dependent of coal and thus faces enormous economic pressure to foster decarbonisation efforts driven by EU allowances price. Although other decarbonisation measures will be used (such as biomass), natural gas will still have significant share in the shift from coal at least in the midterm horizon. Gas decarbonisation is the only possible way how to deliver on ambitious GHGs emission reduction in the district heating sector in the Czech Republic where no other economically and technically available solution on necessary scale exists. Gas markets should be fully decarbonised until 2050 with start of gradual decarbonisation already before 2030. Gas decarbonisation measures should provide for decarbonised/low-emission gasses at competitive prices and acceptable technical parameters in order to secure affordable heat price for consumers. 2. Roadmap mentions the question whether gas TSOs should be allowed to operate electrolysers. ADH CR would like to emphasize that divided ownership of production, transmission and distribution facilities is essential in order to ensure level playing field on the gas market for all market participants. Possible ownership of production facilities (such as electrolysers) by TSOs goes against these principles and should be avoided. 3. ADH CR welcomes that options to improve integrating of infrastructure planning for gas, electricity, hydrogen and heating and cooling infrastructure will be explored. The objective of integrated infrastructure planning should be to avoid sunk cost and ensure that decarbonisation is achieved at lowest possible cost for final customers including households, industry and tertiary sector. 4. ADH CR welcomes the effort to include waste management in the initiative. However there is a need to avoid indirect subsidization of landfilling of municipal waste, which is inappropriate from environmental and circular economy perspective. Landfill gas should therefore not be recognized as green gas in the updated legislation.
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Response to Commission Decision determining the benchmarks values for free allocation in the period 2021-2025

4 Jan 2021

Association for District Heating of the Czech Republic (ADH CR) welcomes the opportunity to comment on the draft COMMISSION IMPLEMENTING REGULATION (EU) determining revised benchmark values for free allocation of emission allowances for the period from 2021 to 2025 pursuant to Article 10a(2) of Directive 2003/87/EC of the European Parliament and of the Council (hereinafter “Regulation”). The Regulation is crucial element in determining the free allocation for district heating utilities under the EU ETS. ADH CR would like to submit following comments to the draft Regulation: 1. The draft Regulation sets in Annex, Part 3 Heat and fuel benchmarks the values for heat benchmark for the period 2021-2025 on the 47,3 EUA/TJ and value for the Average value of the 10 % most efficient installations in 2016 and 2017 on the 2,6 tCO2 equivalents/TJ. The Directive 2003/87/EC establishing a system for greenhouse gas emission allowance trading within the Union (hereinafter “EU ETS directive”) requires in Article 10a paragraph 2 that harmonised rules on monitoring, reporting and verification of production-related greenhouse gas emissions with a view to determining the ex-ante benchmarks should be respected. The revised rules for monitoring and reporting in Commission Implementing Regulation (EU) 2020/2085 amending and correcting Implementing Regulation (EU) 2018/2066 on the monitoring and reporting of greenhouse gas emissions pursuant to Directive 2003/87/EC (hereinafter “MRR”) require from 1st January 2022 to prove the sustainability criteria of the biomass used for the production of energy in order to be considered as carbon neutral according to the rules set by the Directive (EU) 2018/2001 on the promotion of the use of energy from renewable sources (hereinafter “RED2 Directive”). The draft Regulation however does not provide any information if the installations considered for setting the benchmark value for heat production for the period 2021-2025 provided the verification of sustainability criteria required by RED2 Directive to prove that biomass used for heat production could be considered as carbon neutral. If this verification was not provided the emissions from biomass from these installations cannot be considered as carbon neutral and the calculations of both average 10% most efficient installations and the benchmark values for heat need to be reconsidered and recalculated. 2. The EU ETS directive requires in Article 10a paragraph 2 the consultation of the relevant stakeholders in defining the principles for setting ex-ante benchmarks in individual sectors and subsectors. The list of installations considered for benchmark calculation (10% most efficient installations) should be also discussed during these stakeholder consultations considering for example new monitoring and reporting requirements in MRR described in previous point etc. Although ADH CR welcomes the opportunity to comment on the draft Regulation, it has to be noted that the proper consultation of the relevant stakeholders during the drafting phase unfortunately did not take place. This runs against the better regulation principle and inclusive approach and should be avoided in the future.
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Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

Association for District Heating of the Czech Republic (ADH CR) welcomes the opportunity to comment on draft Commission delegated regulation supplementing Regulation (EU) 2020/852 of the European Parliament and of the Council by establishing the technical screening criteria for determining the conditions under which an economic activity qualifies as contributing substantially to climate change mitigation or climate change adaptation and for determining whether that economic activity causes no significant harm to any of the other environmental objectives. ADH CR acknowledges strong need for an increased leverage of private funds to boost decarbonisation and in particular in heating sector. For district heating sector to fully achieve its potential, replace coal and increase the share of renewable energy and waste heat from the industry and tertiary sector, investors and companies need regulatory certainty and legislative framework which would attract investments in a sector with high up-front costs. ADH CR welcomes inclusion of district heating and cooling in the Annexes to the Delegated act on taxonomy. Efficient DHC is fully considered as contributing to a net-zero emissions economy. Moreover ADH CR supports a decision to consider as eligible investments into construction and operation of pipelines and associated infrastructure for district heating and cooling in the system meets the definition of efficient district heat/cool systems in the EU energy efficiency directive. ADH CR also supports the decision to consider waste heat recovery and heat storage as fully eligible. We also welcome the eligibility of activities such as manufacturing of products, key components and machinery that are essential for eligible renewable energy technologies. ADH CR strongly believes that taxonomy should foster swift decarbonisation rather than hinder it by imposing unrealistic requirements and should also take into account different starting points in different Member states. District heating in the Czech Republic, which delivers heat comfort to 4 million citizens, covers 55 % of energy input by coal. ADH CR pledged to replace coal by 2035, while most of this replacement will need to take place until 2030. It is, however, not realistic to expect that coal can be fully replaced only by increased energy efficiency, use of renewables and waste heat. The role of natural gas as transitional fuel used in high efficiency CHP plants and boilers covering peak load will be indispensable. Since the coal phase-out will take place until 2035 we do not see any danger for long term decarbonisation goals until 2050 and technological lock-in since gas-fired plants can be replaced until 2050 or adapted to use of decarbonized gases when these are available. ADH CR underlines necessity to maintain clear references to existing legislation, as stated in the TEG Report and requested by the Regulation. In particular references to the definition of efficient DHC established by the directive 2012/27/EU, to the energy storage concept as defined in the directive 2019/9443 and bioenergy criteria defined by the directive 2018/2001 should be preserved. In light of the above ADH CR proposes the amendments in the Attachment.
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Response to Updating Member State emissions reduction targets (Effort Sharing Regulation) in line with the 2030 climate target plan

24 Nov 2020

Association for District Heating of the Czech Republic (ADH CR) welcomes the opportunity to comment on Inception Impact Assessment to Amendment of Regulation (EU) 2018/842 on binding annual greenhouse gas reductions by Member States from 2021 to 2030 contributing to climate action to meet commitments under the Paris Agreement (ESR Revision). This ESR revision is interlinked with simultaneous public consultation on Inception Impact Assessment to Amendment of the EU Emissions Trading System (EU ETS revision). AHD CR understands ESR as an additional tool to cover greenhouse gas emissions from sectors not covered by EU ETS or LULUCF regime. ADH CR would like to submit following comments to IIA for further consideration by the Commission: 1. ADH CR prefers option 3 described within ESR revision IIA to maintain in ESR only sectors not covered by ETS. ETS defines sectors with uniform EU wide price of carbon while ESR defines sectors where uniform price of carbon does not exist and emission reductions are in the responsibility of member states. From this perspective overlap between ESR and ETS would only lead to confusion. On the other hand inclusion of some sector into ETS does not exclude that further policy instruments on EU level will be applied when needed. This is for example the case of renewable electricity. While most of the electricity generation from fossil fuels is covered by ETS, there are still dedicated policies for fostering development of renewable energy sources. If for example sector of buildings is included in ETS, it will be covered by various instruments of EU energy policy which can be further improved if necessary (e.g. energy performance of buildings directive). We therefore do not see any added value in option 2. 2. Option 1 does not seem to be relevant in time horizon until 2030 as emissions covered by ESR will still be quite significant and member states should be motivated to decrease these emissions rather than cover them partially by LULUCF sinks. After 2030 merging of all three sectors should be considered as e.g. firms operating industrial activity should be allowed to offset this by financing concrete actions in LULUCF. However this kind of revolution cannot be meaningfully prepared within a half year and should be left to the next phase of ETS. 3. IIA does not provide any information regarding how total emission reduction until 2030 will be divided among ETS and ESR. It is clear that emission reduction in ESR will depend on sectors covered. On the other hand it should be clearly stated upfront on which basis emission reduction in different sectors (either included in ETS or ESR) will be based and how it was established.
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Response to Updating the EU Emissions Trading System

24 Nov 2020

Association for District Heating of the Czech Republic (ADH CR) welcomes the opportunity to comment on Inception Impact Assessment to Amendment of the EU Emissions Trading System (IIA). This EU ETS revision is interlinked with simultaneous public consultation on Inception Impact Assessment to Amendment of Regulation (EU) 2018/842 on binding annual greenhouse gas reductions by Member States from 2021 to 2030 contributing to climate action to meet commitments under the Paris Agreement (ESR Revision). ADH CR understands that following increase in overall ambitions in emission reduction until 2030 changes in ETS are necessary. ADH CR would like to submit comments to IIA for further consideration by the Commission (see attachment).
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Response to EU Action Plan Towards a Zero Pollution Ambition for air, water and soil

29 Oct 2020

Association for District Heating of the Czech Republic (ADH CR) welcomes the opportunity to comment on Roadmap to EU Action Plan Towards a Zero Pollution Ambition for air, water and soil (ZPAP). AHD CR understands ZPAP as the ambition aiming at consolidation of actions towards all aspects of pollution especially from sectors not already covered by dedicated EU legislation. ADH CR would like to raise following issues: 1. Already EU-regulated sectors and activities such as sectors covered by Industrial Emissions Directive or Medium Combustion Plants Directive should not be the subject of additional requirements stemming for ZPAP activities. Dedicated EU legislation should be the leading instruments to regulate these sectors not vice versa. ZPAP should focus on sectors and activities outside or below current EU regulation areas and thresholds. 2. ZPAP should carry a realistic ambition that reflects industry’s technical realities and historical progress, while addressing all European sectors equally. Possible potential of pollution reduction should be thoroughly consulted with broad participation of stakeholders including industry and sectors concerned. 3. ZPAP must pursue an integrated approach, balancing ambition with technical feasibility, and work to reduce pollution from all contributing sectors by: a. Reinforcing existing legislation and implementation, rather than going for new legislation. b. Ensuring that targeted additional actions do not tackle those who already contributed to lower emission levels. c. Controlling that new monitoring and outlook tools are science-based and exclude too high uncertainties. 4. Environmental policies need to be coherent, modern, based on scientific evidence and efficiently implemented to support the industrial transition. When developing ZPAP an integrated approach (recognising cross-media effects) for all climate and environmental aspects is needed whilst also recognising the better Regulation package (reducing regulatory burdens and red-tape). 5. Permits in Industrial Emissions Directive (IED) should be updated and granted based on a technology driven analyses and a transparent and robust methodology to derive emission limits. The IED itself is fit for its purpose. A review of the IED should continue recognising that GHG emissions are already regulated under the EU ETS. Aspects related to the circular economy are already being effectively developed under the EU Circular Economy Action Plan. BREF review processes are based on dedicated data collection and questionnaires from well performing plants, that have to be defined following the principle of environmental protection as a whole. This process, although time consuming, is necessary to avoid shortcuts that might only favour a plant or a technique that minimise impact on one pollutant but has cross media effects that should not be overlooked. The alternatives such as using EPRTR data to identify well performing plants do not abide by the same principle. 6. Reduce pollution within waste management sector means tackling landfilling and its related impacts (especially methane emissions as potential greenhouse gas).
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Response to Industrial pollution - revision of the European Pollutant Release and Transfer Register

26 Oct 2020

Association for District Heating of the Czech Republic (ADH CR) welcomes the opportunity to comment on inception impact assessment (IIA) of the Revision of the Regulation on the European Pollutant Release and Transfer Register (E-PRTR). AHD CR sees E-PRTR as efficient instrument to collect data from industrial activities covered by relevant legislation, especially Industrial Emission Directive (IED). ADH CR would like to raises following issues: 1. Concerning of the inclusion of additional pollutants so called Seville process should be the leading instrument how to reassess and consult additional pollutants within E-PRTR. Discussions under the E-PRTR Expert Group recently resulted in the definition of units and metrics for reporting certain contextual fields. These discussions are highly relevant for industry, at the very least given that it will have to implement these new reporting obligations. Therefore, and when relevant, industry should be invited to participate in discussions under this forum. 2. Access to information and participation in decision making is generally allowed by at EU level the Kyiv Protocol on Pollutant Release and Transfer Registers, which aims, in particular, to enhance public access to environmental information through the establishment of coherent, nationwide pollutant release and transfer registers. Regulation 1049/2001 governs public access to European Parliament, Council and Commission documents and the access, collection and dissemination of environmental information is governed by Regulation 1367/2006 (the 'Aarhus Regulation'). There is no evidence why to expand on existing measures concerning the public participation in decision making. If any such problems exist they need to be addressed by relevant legislation and after then possibly reflected in E-PRTR not vice-versa. 3. Continuity of the Seville process needs to be secured. The BREF process aims to identify BAT and BAT associated emission performance levels that apply to units/processes (e.g. a furnace or a boiler) expressed very often in concentration, sometimes using specific units. The Seville process is an example of good governance where confidential business information is handled with utmost caution (in particular through aggregation of plant data or anonymisation). At the very least, the same level of confidentiality than in TWG discussions should be ensured. On the other hand, the E-PRTR Regulation is about absolute amount of substances emitted by a facility during a year (e.g. a plant or a sub-installation most of time, i.e. covering more than one unit/process). As a consequence, E-PRTR data, even normalised, shall not be used to identify the best performers for the Sevilla process.
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Response to Revision of the EU Emission Trading System Monitoring and Reporting Regulation (MRR)

24 Jul 2020

Association for District Heating of the Czech Republic (ADH CR) welcomes the opportunity to comment on “Draft Implementing Regulation amending and correcting Implementing Regulation (EU) 2018/2066 on the monitoring and reporting of greenhouse gas emissions pursuant to Directive 2003/87/EC of the European Parliament and of the Council” (MRR revision). ADH CR welcomes that MRR revision recognizes role of biofuels and guarantees of origin (GO) in EU ETS Monitoring, reporting and verification process and thus pave the way to foster decarbonisation efforts in installations under the EU ETS regime. See the detailed comments in the Attachment.
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Response to Establishment of a smart readiness indicator for buildings

16 Jul 2020

Association for District Heating of the Czech Republic (ADH CR) welcomes the opportunity to comment on Smart buildings – smart readiness indicator (definition and calculation). AHD CR sees role of smart readiness indicator (SRI) as a tool to evaluate the buildings’ characteristics and emphasizes the role of district heating and cooling in this respect. ADH CR believes that SRI calculation methodology needs to be improved in terms of energy efficiency impact criterion where it is important that all heating sources are treated equally. The energy efficiency should be counted for the total energy needed in a building not only as “purchased energy” (e.g. heat coming from heat pumps should also take into account the heat from the ground or air). Thus system boundary should be set at the property line for the correct counting of energy efficiency. The functionalities (energy performance and operation, response to the needs of the occupants and energy flexibility) should also be applied to thermal grids. With regards to energy flexibility for instance, DHC networks can provide the flexibility and enable demand response-like functions to electricity network. A level-playing field and technological neutrality should be guaranteed also in the smart-ready service catalogue as set out in Annex VI.
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Response to Strategy for smart sector integration

8 Jun 2020

Energy sector integration in the broader sense could represent the easiest and most efficient path for the EU to accelerate its decarbonisation efforts, and possibility to tap often unexploited potential. The concept of smart energy sector integration should be understood and applied in its holistic approach, going well beyond the narrow understanding of only electricity and gas coupling. Exploiting the synergies between energy carriers, infrastructures, transport and industry sectors will be key instrument in bringing this necessary flexibility, as well as ensuring the stability and reliability of grids. The use of existing technologies and solutions such as combined heat and power, thermal storage and district heating, should play an important role in the wider energy transition, linking parts of the system that have traditionally been isolated from each other in order to fulfil the goals set out by the EU legislation. For these reasons, ADH CR asks Commission to consider the following elements in the EU strategy on energy sector integration as described in the attached document.
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Response to Climate Law

1 May 2020

Association for District Heating of the Czech Republic (ADH CR) welcomes the oportunity to comment on the Proposal for a Regulation of the European Parliament and of the Council establishing the framework for achieving climate neutrality and amending Regulation (EU) 2018/1999 (European Climate Law). Detailed comments in the Attachment.
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Response to Climate change mitigation and adaptation taxonomy

27 Apr 2020

Association for District Heating of the Czech Republic (ADH CR) welcomes opportunity to comment on inception impact assessment for Commission Delegated Regulation on a climate change mitigation and adaptation taxonomy. ADH CR agrees that the initiative will have to be developed in accordance with the Taxonomy regulation and would like to point out that the article 10 paragraph 1. a) clearly refers to directive EU 2018/2001, which should entail also sustainability criteria for biomass. ADH CR believes that in order to provide for certainty and decrease unnecessary administrative burden, electricity and heat production from sustainable biomass according to the directive 2018/2001 should qualify as activity substantially contributing to climate change mitigation. ADH CR believes that CHP can substantially contribute to decreasing emissions from electricity production. It should be noted that this electricity by definition competes in the market with electricity from conventional sources and not with electricity from wind or photovoltaic power and should be therefore compared to conventional sources of electricity using fossil fuels rather than to average electricity mix which can be highly misleading and lead to unintended consequences where electricity only production is ultimately preferred to CHP which would run against efficiency first principle. ADH CR believes that investments in refurbishment of district heating networks should be regarded as activity substantially contributing to climate change mitigation. In order to deploy renewable energy and surplus heat, heat distribution network need to be refurbished and adapted to low temperature operation before it makes sense to invest in replacing heat source. In order to facilitate transition to low-carbon district heating the Delegated Regulation on climate change mitigation and adaptation taxonomy should take into account that transition of existing district heating system is a long-term step-by-step process and typically cannot be done overnight with one project. If individual steps ultimately leading to low-carbon district heating cannot be regarded as activity contributing to climate change mitigation then unintended consequences of actually hindering transition to low carbon energy system would clearly be manifested. Renovated district heating network in no way conserves the heat sources currently used. On the other hand, it enables use of many renewable energy sources and waste heat which could not be otherwise used. ADH CR regrets that the Commission does not foresee specific public consultation on delegated act. Even though TEG work contributed substantially to the subject, it could not reflect on the final text of the Regulation. It would therefore make sense to collect stakeholder views on how this is reflected in proposal of delegated act. Quality of delegated acts should be preferred to quantity and speed of their adoption especially when they are of profound importance for decarbonisation and can easily lead to unintended consequences.
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Response to EU rules on industrial emissions - revision

21 Apr 2020

Association for District Heating of the Czech Republic (ADH CR) welcomes the opportunity to comment on inception impact assessment (IIA) of the Revision of the Industrial Emissions Directive (IED). AHD CR has actively participated in the elaboration process of the Large Combustion Plants BREF, the Waste Treatment BREF and the Waste Incineration BREF within the framework of the IED. We fully confirm that the combination of international and EU environmental regulations, technological development and investments in pollutant abatement technology, greatly contributed to the reduction of pollutants emissions released into the air. There is a clear downward trend with regards to the emissions of SOx, NOx dust and particles, according to the data published by the European Environmental Agency. ADH CR submits following comments and suggestions (see Attachment).
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Response to 2030 Climate Target Plan

15 Apr 2020

Association for District Heating of the Czech Republic (ADH CR) welcomes the opportunity to comment on inception impact assessment of the Communication 2030 Climate Target Plant. ADH CR submits following comments and suggestions (see Attachment).
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Response to Revision of the Energy Tax Directive

1 Apr 2020

Association for District Heating of the Czech Republic welcomes opportunity to comment on inception impact assessment of revision of Directive 2003/96/EC (ETD). We fully share the opinion of the Commission that well-designed taxes play a key role in decarbonisation effort by sending the right price signals and providing the right incentives to consumers and producers of energy. We also agree that ETD is currently not in line with EU decarbonisation ambitions and needs to be urgently revised. We strongly believe that ETD need to be aligned with the EU emission trading system and provide similarly strong signal on carbon cost to users of fossil fuels in stationary installations not covered by the ETS. The possibility for Member States to apply total or partial exemptions or reductions in the level of taxation for fossil fuels, including coal, used by households (Article 15(h)) runs directly against decarbonisation policies and must be omitted. Moreover, taxation of coal used in households or small boilers without proper flue gas treatment should take into account exceptionally high external costs caused by emissions of small particles from these sources. In order to provide for level playing field, only fuels used for heating in installations covered by EU ETS should be automatically exempted from carbon tax or the tax should be fully refundable. Level playing field should also apply to renewable energy sources produced on-site and delivered by energy carrier such as district heating. In order to avoid harmful market distortions, renewable energy should be taxed the same regardless of whether it is produced/collected on site (e.g. in the multifamily house) or supplied from external source. Double taxation should be avoided. Therefore supplies of excess heat/cold from industry or other sources (where fossil fuels used were already taxed or are covered by ETS) should be exempted from energy tax.
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Response to Commission Implementing Regulation on the Modernisation Fund

16 Mar 2020

Association for District Heating of the Czech Republic (ADH CR) welcomes the opportunity to respond to the EC consultation on the Draft Commission Implementing Regulation on the Modernisation Fund. Modernisation fund is indeed very important tool for transition to low carbon economy in the Czech Republic where modernization of district heating systems should be a priority. Detailed rules of operation of the Modernisation fund should provide for smooth distribution of its financial resources to the beneficiary Member States. It is, therefore, necessary to ensure that even larger and more complex projects can be approved in expedite manner. Preparation of such projects takes typically several years and should not be postponed by cumbersome approval process hindered by unnecessary self-imposed administrative obstacles. The approval process needs to be streamlined, efficient and comply with the Directive 2003/87/EC. Please see detailed comments in the Attachment.
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Response to Revising the rules for free allocation in the EU Emissions Trading System

9 Jul 2019

The Association for District Heating of the Czech Republic (ADH CR) calls for the official publication of the ALC regulation as soon as possible in order to leave a timeframe long enough to adapt to the new rules. ADH CR also raises comments specified in the enclosed document.
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Response to Methodology for assessing the potential for efficient heating and cooling

10 Jan 2019

Association for District Heating of the Czech Republic welcomes the Commission’s proposal to amend and further improve the framework on the promotion of efficient heating and cooling under article 14 of the Energy Efficiency Directive 2012/27/EU (EED) by reviewing the assessment rules in the annex VIII of EED. We welcome that the Commission takes into account technology and policy developments since adoption of the directive as well as the lessons learnt in the first reporting period. The review is the logical next step following the EU Strategy on Heating and Cooling and more recently the crucial changes in the EU energy legislation such as the consideration of waste heat and cold. However, in order to ensure, that reviewed annex VIII reflects technological and legislative progress as well as lessons learnt in the best possible way Association for District Heating of the Czech Republic would like the Commission to consider concrete suggestions made available as comments directly in the draft annex in a separate file.
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Response to Free allocation of emission allowances

23 Nov 2018

The Association for District Heating of the Czech Republic calls for the official publication of the FAR regulation as soon as possible in order to leave a timeframe long enough to adapt to the new rules and to progress on the corresponding benchmarks. Secondly, we would like to ask for the implementation of the monitoring methodology plans (MMPs) into the current monitoring plans. Several facts required by MMPs are already involved in the current MPs.
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