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EnBW Energie Baden-Württemberg AG

EnBW

EnBW is one of the largest energy supply companies in Germany and Europe.

Lobbying Activity

Meeting with Aleksandra Baranska (Cabinet of Executive Vice-President Teresa Ribera Rodríguez), Thomas Auger (Cabinet of Executive Vice-President Teresa Ribera Rodríguez)

26 Jan 2026 · The Industrial Accelerator Act and the European Grids Package

Meeting with Andreas Glück (Member of the European Parliament)

8 Jan 2026 · Climate and Energy Policy

Meeting with Christian Ehler (Member of the European Parliament) and Vattenfall and

12 Dec 2025 · Energiepolitik

Meeting with Estelle Goeger (Cabinet of Executive Vice-President Stéphane Séjourné) and Bundesverband der Deutschen Industrie e.V. and

4 Nov 2025 · Overview of the Commission's Single Market Strategy.

Meeting with Jens Geier (Member of the European Parliament)

17 Oct 2025 · Exchange on Grid Action Plan

German utility EnBW backs EU recycling targets for wind turbines

9 Oct 2025
Topic — EU rules on environmental sustainability requirements for public procurement of clean technologies.
Message — EnBW supports the 70% recyclability target for wind turbine blades but stresses that sufficient qualified service providers must be available during decommissioning to offer recycling at competitive prices. The Commission should facilitate development of recycling infrastructure across Member States.123
Why — This ensures competitive recycling markets exist when their wind farms reach end-of-life.45
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Meeting with Angelika Niebler (Member of the European Parliament)

9 Oct 2025 · Omnibus I, CSRD, CSDDD

Meeting with Jens Geier (Member of the European Parliament) and Uniper

8 Oct 2025 · Exchange on current developments on the Gas and Electricity Markets

Meeting with Andreas Glück (Member of the European Parliament)

2 Oct 2025 · Energy Policy

Meeting with Tiemo Wölken (Member of the European Parliament)

30 Sept 2025 · General exchange on digital, data & AI policy

Meeting with Christian Ehler (Member of the European Parliament) and EPIA SolarPower Europe and

26 Sept 2025 · Energy policy

Meeting with Paula Rey Garcia (Head of Unit Energy) and Climate Action Network Europe and

18 Sept 2025 · Electrification, tripartites contracts, storage and flexibility, and grids

Meeting with Martin Häusling (Member of the European Parliament)

3 Sept 2025 · Treffen zu Industrie-Investition & Biomethan in Hessen

Meeting with Damian Boeselager (Member of the European Parliament)

29 Aug 2025 · Data Act

Meeting with Christian Ehler (Member of the European Parliament)

28 Aug 2025 · Low carbon fuels DA

EnBW Urges Binding Zero-Emission Quotas for Corporate Fleets

28 Jul 2025
Topic — The EU is consulting on setting minimum requirements for zero-emission corporate vehicle fleets.
Message — EnBW requests a law with binding quotas for buying zero-emission cars and vans. They suggest increasing targets every three years to reach 100% by 2035.123
Why — Mandatory electrification would drive higher utilization for EnBW’s extensive German charging network.45
Impact — Businesses that do not transition their fleets face legal monitoring and penalties.6
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Meeting with Andreas Glück (Member of the European Parliament) and MB Energy Holding GmbH Co.KG

15 Jul 2025 · Climate and Energy Policy

Meeting with Jens Geier (Member of the European Parliament)

14 Jul 2025 · Exchange on the affordable Energy Action Plan

Meeting with Anne Katherina Weidenbach (Cabinet of Commissioner Dan Jørgensen)

24 Jun 2025 · Climate Neutrality in the Power Sector

Meeting with Sven Simon (Member of the European Parliament)

15 May 2025 · Energy

Meeting with Andrea Wechsler (Member of the European Parliament) and Siemens Energy AG and

14 May 2025 · EU Energy and industry policy

EnBW urges further simplification of EU Taxonomy reporting rules

26 Mar 2025
Topic — This initiative aims to make sustainability reporting simpler and more cost-effective for companies.
Message — The company requests voluntary OpEx reporting and individual activity-level materiality thresholds. They also suggest that EU law compliance should automatically fulfill environmental safety criteria.123
Why — These changes would significantly lower auditing costs and reduce the internal administrative burden.45
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Meeting with Andreas Glück (Member of the European Parliament)

6 Mar 2025 · Climate and Energy Policy

Response to Implementing Act on non-price criteria in renewable energy auctions

20 Feb 2025

Please find our feedback in the attachment
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Meeting with Thomas Geisel (Member of the European Parliament)

18 Feb 2025 · Event on Europe’s Energy Transition

Meeting with Christian Ehler (Member of the European Parliament)

12 Feb 2025 · Net-Zero Industry Act

Meeting with Christian Ehler (Member of the European Parliament)

10 Feb 2025 · Net-Zero Industry Act

Meeting with Anne Katherina Weidenbach (Cabinet of Commissioner Dan Jørgensen)

4 Feb 2025 · System integration & affordable energy

Meeting with Johannes Ten Broeke (Cabinet of Commissioner Wopke Hoekstra)

4 Feb 2025 · Presentation of EnBW activities and exchange of views on the upcoming Clean Industrial Deal on energy and hydrogen.

Meeting with Jutta Paulus (Member of the European Parliament)

3 Feb 2025 · EU energy policy

Meeting with René Repasi (Member of the European Parliament)

3 Feb 2025 · Austausch zu den Themen Wettbewerbsfähigkeit, Industriepolitik und Zukunft des Green Deals

Meeting with Michael Bloss (Member of the European Parliament)

24 Jan 2025 · Austausch Energie und Industriepolitik

Meeting with Christian Ehler (Member of the European Parliament) and EPIA SolarPower Europe and

24 Jan 2025 · Energiepolitik

Meeting with Christophe Clergeau (Member of the European Parliament)

20 Dec 2024 · ITRE

Response to Data types for alternative fuels infrastructure

19 Dec 2024

The Q&A for AFIR clarifies that for fulfilling the targets of Art. 3 AFIR the theoretical maximum charging power of the charging point is decisive, not the actual charged current or the actual grid connection capacity. This needs to be also clarified in the AFIR regulation, because we noticed different and wrong interpretations of national authorities. Furthermore, vehicles also need to be obliged to send data to the relevant market participants, not only charge point operators. Without non-discriminatory, free, and transparent sharing of vehicle data, services like smart charging or bidirectional charging cannot be offered by the market participants (except for OEMs). In this regard, an In-Vehicle-Data Act at a European level or an adaptation of RED III Art. 20a (which currently contains not all needed data points and lacks specific definitions of the data points) is needed. Furthermore, the implementation of RED III Art. 20a obligations needs to be well monitored by the European Commission. In general, we recommend adding to the data list whether the submission of the data type is optional. As we highlight in our following feedback, some data points should be handled as optional. Regarding the following additional static and dynamic data types for publicly accessible recharging infrastructure, we see a need for clarification or difficulties in fulfilling these provisions - (see the enclosed file)
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Response to Standards for wireless recharging, electric road system and vehicle-to grid-communication of recharging infrastructure

17 Dec 2024

We welcome the fact that the delegated act addresses the need for the rapid implementation of ISO15118-20 in vehicles. However, the current in our view non-binding recommendation for OEMs to implement the standard in new electric vehicles is not sufficient. There is an urgent need for a binding regulation requiring OEMs to implement ISO15118-20 in all new vehicles, along with all corresponding features, especially smart charging. Without such regulation, experience has shown that the implementation will not be fast enough, and important services for the energy system, such as smart charging and bidirectional charging, cannot be realized. We also support that Regulation (EU) 2023/1804 should ensure an interoperable and secure implementation of plug-and-charge. However, this must also include a binding standardization of the plug-and-charge services, especially the standardization of the installation process. For the (non-OEM) market participants, it is crucial that the installation process to the vehicle is open to all relevant market participants, free, and standardized. OEMs need to be obliged to apply one standardized installation process, as it would otherwise be an enormous effort for the relevant other service providers to fulfill specific requirements by various OEMs.
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Meeting with Andreas Glück (Member of the European Parliament)

16 Dec 2024 · Climate and Energy Policy

Meeting with Christian Ehler (Member of the European Parliament) and BDEW Bundesverband der Energie- und Wasserwirtschaft e. V. and

6 Dec 2024 · Energiepolitik

Meeting with Andrea Wechsler (Member of the European Parliament) and Novo Nordisk A/S

2 Dec 2024 · EU Energy and Industry Policy

Meeting with Andrea Wechsler (Member of the European Parliament)

20 Nov 2024 · EU Energy and Industry Policy

Meeting with Andreas Glück (Member of the European Parliament)

15 Nov 2024 · Climate and Energy Policy

EnBW warns EU rules could hamper low-carbon hydrogen uptake

25 Oct 2024
Topic — The regulation defines a methodology for certifying greenhouse gas reductions from low-carbon fuels.
Message — EnBW requests Power Purchase Agreements for electricity sourcing to ensure investment certainty. They propose simplified accounting rules for indirect energy use and project-specific measurements.123
Why — These flexible rules would significantly reduce hydrogen production costs and improve electrolyser efficiency.45
Impact — Climate groups lose out if simplified accounting leads to higher greenhouse gas emissions.6
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Meeting with Michael Bloss (Member of the European Parliament)

18 Oct 2024 · Fachgespräch Elektroladeinfrastruktur

Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

10 Oct 2024 · Meeting with Dr. Georg Stamatelopoulos new CEO of EnBW on NZIA, Clean Industrial Deal and hydrogen.

Meeting with Andrea Wechsler (Member of the European Parliament)

1 Oct 2024 · Brussels

Meeting with Christian Ehler (Member of the European Parliament) and RWE AG and

13 Sept 2024 · Energiepolitik - allgemein

Meeting with Angelika Niebler (Member of the European Parliament) and BASF SE and ENGIE

10 Sept 2024 · EU Energy Policy

Meeting with Andrea Wechsler (Member of the European Parliament) and BASF SE and

10 Sept 2024 · EU Energy Policy

Meeting with Christian Ehler (Member of the European Parliament) and BASF SE and ENGIE

10 Sept 2024 · Low-carbon hydrogen

Meeting with Christian Ehler (Member of the European Parliament)

1 Aug 2024 · Low-carbon hydrogen

Meeting with Jens Geier (Member of the European Parliament) and ENGIE and EUROGAS

18 Jul 2024 · Exchange on Low Carbon Hydrogen

Meeting with Christian Ehler (Member of the European Parliament) and ENGIE and

11 Jul 2024 · Energiepolitik allgemein

Meeting with Christian Ehler (Member of the European Parliament) and BDEW Bundesverband der Energie- und Wasserwirtschaft e. V. and

31 May 2024 · Energiepolitik allgemein

Meeting with Christian Ehler (Member of the European Parliament)

21 Mar 2024 · Energiepolitik allgemein

Meeting with Henrike Hahn (Member of the European Parliament, Shadow rapporteur) and Verband der Automobilindustrie and

21 Mar 2024 · Critical Raw Materials

Meeting with Andreea Ticheru (Cabinet of Executive Vice-President Margrethe Vestager), Christiane Canenbley (Cabinet of Executive Vice-President Margrethe Vestager)

12 Mar 2024 · the energy sector in Germany

Meeting with Jens Geier (Member of the European Parliament, Rapporteur)

22 Feb 2024 · Exchange on the European hydrogen market

Meeting with Daniel Mes (Cabinet of Commissioner Wopke Hoekstra)

19 Feb 2024 · Energy priorities towards 2040

Meeting with Kadri Simson (Commissioner) and

17 Feb 2024 · Upcoming delegated act on low carbon hydrogen, wind offshore auction design and Net Zero Industry Act.

Response to Guidance to facilitate the designation of renewables acceleration areas

12 Feb 2024

Ausgestaltung des Leitfadens: Aus Sicht der EnBW sollte der Leitfaden nicht so detailliert bürokratisch ausgestaltet sein, dass sich die Umsetzung in den Mitgliedsstaaten hierdurch verzögert. Es sollte positiven bestehenden Regelungen sowie bereits in der Verwirklichung befindlichen politischen Vorhaben daher nicht in Detailregelungen entgegenstehen. Am wichtigsten ist die zügige Ausweisung von Flächen und die Genehmigungsbeschleunigung. Festlegung von konkreten Maßnahmen auf Ebene der Flächenausweisung: Die Regelung zur Festlegung von Schutz-/Vermeidungs-/Minderungsmaßnahmen sollte derart ausgestaltet werden, dass die ausführenden Behörden der Mitgliedsstaaten lediglich Regeln/Kriterien für Maßnahmen bei der Flächenausweisung festlegen sowie sofern erforderlich die Ausnahme in Aussicht stellen. Im deutschen Bundesnaturschutzgesetz (BNatSchG) werden in Anhang 1 Abschnitt 2 bereits sehr konkrete Maßnahmen vorgegeben, auch wenn wir uns noch ein paar wenige Details zusätzlich wünschen würden. Aus unserer Sicht sollte keine einzelne Maßnahme vorgegeben werden, sondern alle für die jeweiligen potenziell betroffenen Arten zur Verfügung stehenden Maßnahmen, einschließlich aktuellerer Vorgaben und neuer Maßnahmen, die bis zur Genehmigung vorliegen könnten. Widerlegung des Bedarfs von Maßnahmen: Es muss weiterhin möglich sein, auf Ebene der Genehmigung zu widerlegen, dass man tatsächlich eine Schutzmaßnahme benötigt und zwar sowohl durch (Horst-)Kartierungen (Negativnachweis von Horsten im relevanten Abstand zu den Einzelanlagen) als auch durch die tatsächliche fachwissenschaftliche und rechtliche Bewertung des Kollisionsrisikos der potentiell betroffenen Brutpaare.
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Meeting with Christian Ehler (Member of the European Parliament) and BDEW Bundesverband der Energie- und Wasserwirtschaft e. V. and

26 Jan 2024 · Energiepolitik allgemein

Meeting with Andreas Glück (Member of the European Parliament)

12 Jan 2024 · General exchange

Meeting with Jens Geier (Member of the European Parliament) and BDEW Bundesverband der Energie- und Wasserwirtschaft e. V. and

12 Jan 2024 · Exchange on industrial and energy policy

Meeting with Christiane Canenbley (Cabinet of Vice-President Věra Jourová)

20 Nov 2023 · Competitiveness & Net-Zero Industry Act

Meeting with Jens Geier (Member of the European Parliament, Rapporteur)

11 Sept 2023 · Exchange on the gas market directive (staff level)

Meeting with Andreas Glück (Member of the European Parliament) and BASF SE

24 May 2023 · Reform des Strommarktdesigns

Meeting with Jens Gieseke (Member of the European Parliament)

23 May 2023 · Wirtschaftspolitik

Meeting with Ditte Juul-Joergensen (Director-General Energy) and Siemens AG and

9 May 2023 · Energy markets; CEO meeting under the Baltic Offshore Wind Forum; Other participants: Litgrid, Latvenergo, AST, Gasgrid Finalnd, Suomen Hyötuuli

Meeting with Michael Bloss (Member of the European Parliament) and BDEW Bundesverband der Energie- und Wasserwirtschaft e. V.

27 Apr 2023 · Strommarktdesign (Staff level)

Meeting with Jens Geier (Member of the European Parliament) and Amprion GmbH

18 Apr 2023 · Exchange on the electricity market design (staff level)

Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton)

23 Mar 2023 · Net-zero industry act, energy transition

Meeting with Jens Geier (Member of the European Parliament)

14 Feb 2023 · Exchange on the electricity market design (staff level)

Meeting with Jens Geier (Member of the European Parliament, Rapporteur)

9 Feb 2023 · Exchange on the gas market directive

Meeting with Peter Liese (Member of the European Parliament, Rapporteur) and BUSINESSEUROPE and

20 Dec 2022 · ETS

Meeting with Jens Geier (Member of the European Parliament, Rapporteur)

23 Nov 2022 · Gasmarktrichtlinie

Meeting with Peter Liese (Member of the European Parliament, Rapporteur) and European Environmental Bureau and

14 Oct 2022 · ETS

German grid operator EnBW urges delay in gas equipment phase-out

28 Jun 2022
Topic — The EU is revising regulations to eliminate potent greenhouse gases from electrical equipment.
Message — EnBW requests a two-year extension for medium-voltage equipment transition periods. They propose that supply bottlenecks and delivery times serve as valid exceptions. They also demand continued access to spare parts for existing infrastructure maintenance.123
Why — This prevents expensive project delays caused by equipment shortages or technical redesigns.4
Impact — Climate advocates lose as delayed phase-outs permit the continued use of warming gases.5
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EnBW urges flexible emission rules to accelerate hydrogen investments

17 Jun 2022
Topic — This consultation establishes a methodology for calculating greenhouse gas savings for synthetic and recycled fuels.
Message — EnBW requests applying this methodology to the gas package and allowing annual emission factor updates. They advocate for using actual emission data and removing transport emissions from calculations.123
Why — These changes would provide regulatory certainty for investments while cutting administrative costs.45
Impact — Climate monitoring accuracy could suffer if emissions from storage and distribution are excluded.6
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Meeting with Michael Bloss (Member of the European Parliament)

27 May 2022 · Fit for 55

EnBW Urges Flexible Intervals for Methane Leak Detection

14 Apr 2022
Topic — EU legislative proposal for monitoring and reducing methane emissions in energy.
Message — Leak detection and repair intervals should reflect technical and economic feasibility. Operators should use best available technologies instead of compulsory prescribed tools. The responsibility for methane emission reporting should generally be with the operator.123
Why — This approach would lower costs and avoid impossible winter inspections of networks.45
Impact — Energy consumers would face higher bills if monitoring costs increase gas tariffs.6
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Response to Revision of EU rules on Gas

23 Mar 2022

As EnBW, we very much welcome that large parts of the proposals of the Directive and Regula-tion on the internal gas market for the establishment of a hydrogen market, correspond to the model of the existing and functioning internal gas market. However, we see some points in the draft that could considerably delay the rapid development of a hydrogen market. In our position paper (document attached) we analyzed and layed out the articles of the Gas Directive and Gas Regulation, The most important topics for the development of a hydrogen economy are: - proposed unbundling rules - definition of conditionla capacities - certification of low carbon hydrogen
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Response to Requirements for Artificial Intelligence

23 Jul 2021

Aus Sicht der EnBW Energie Baden-Württemberg AG wurde mit dem Gesetzesvorschlag der EU-Kommission zu Künstlicher Intelligenz (KI), eine Regulierung entworfen, welche Chancen eröffnet. Nach erster Betrachtung, hiermit unsere erste kurze Rückmeldung aus energiewirtschaftlicher Perspektive sowie dem Betrieb von kritischer Infrastruktur. Auf der letzten Seite des angehängten Dokuments findet sich eine Übersicht mit KI Use-Cases in Einordnung auf einem Risikospektrum.
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Response to Revision of Non-Financial Reporting Directive

14 Jul 2021

EnBW welcomes the proposals for the revision of the CSR Directive published by the EU Commission on 21 April 2021. We support the goal of increasing transparency with regard to sustainable aspects and thus meeting the growing demand for sustainability-related information to an even greater extent. The CSRD with further Green Deal measures makes an important contribution to strengthening the competitiveness of Europe as a business location and of European companies. This position paper explains how EnBW assesses the essential further developments of the CSRD directive and the central cornerstones of the current proposal. o The strengthening of integrated reporting and the direct locating of sustainability information in the management report is supported. o A moderate expansion, consolidation and concretisation of the reporting obligations of companies with regard to sustainability aspects is welcomed. o The inclusion and detailing of the principle of dual materiality (outside-in or inside-out) is welcomed, but implementation should be practicable, risk-based and feasible with an appropriate and justifiable effort of justification. o Expanding the scope of companies increases the impact of EU sustainable finance efforts - however, proportionality should be maintained, especially in the case of "SMEs". o The concretisation of the material sustainability requirements within the framework of the governance aspect in the sense of the "G" of the ESG canon is welcomed. o We support the retention of the exemption option of preparing a separate non-financial statement, provided that the parent company submits a non-financial group statement. o Linking the CSRD requirements with established sustainability standards is just as desirable as a meaningful linking of the CSRD requirements with the requirements of the EU Taxonomy Regulation. o The digitalisation of relevant sustainability information in the sense of electronic formats is welcomed in principle, but should be carefully prepared. • EnBW is in favour of introducing minimum requirements for the verification of sustainability information in the management report of the annual report.
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Response to Commission Delegated Regulation on taxonomy-alignment of undertakings reporting non-financial information

2 Jun 2021

EnBW fully supports the objective of the Taxonomy regulation and believes that ambitious and forward-looking reporting can unleash a huge potential for sustainable investments. However, having already applied the EU Taxonomy for the 2020 reporting year on the basis of the draft versions for the technical screening criteria for selected activities, we would like to highlight following selected critical elements of the draft Delegated Act on reporting obligations: 1. Granularity level of KPI break-down and reference on environmental objectives, Draft DA p. 6, 21 (Turnover), 23 (CAPEX), 24 (OPEX) Issue: We strongly oppose the proposed granularity - related to the respective activities as well as the environmental objectives -, which doesn’t seem to lead to relevant information requested by internal and external audiences. Recommendation: - Reporting of all Taxonomy-eligible activities on (aggregated) segment level (with reference to NACE codes) within the meaning of IFRS 8 as a pragmatic and feasible solution - Focus on one environmental objective dependent on the most significant contribution of an industry 2. Usage of forward-looking metrics (CAPEX) instead of static metrics (OPEX) and general calculation of KPIs, Draft DA, p. 3, Annex I KPIs of non-financial undertakings 1.1.1, 1.1.2.1, 1.1.3.2 Issue: Reporting of OPEX in general, definition of KPIs - The need to include reporting requirements for environmentally sustainable OPEX should be carefully reconsidered (i.a. in a future review of the taxonomy regulation), as the added value in content terms is not clear. - The calculation of OPEX would need clarification, as under IFRS non-financial undertakings can choose between nature of expense and cost of sales method for the presentation in P&L: e.g. using cost of sales method should provide „operational and maintenance costs incl. R&D“ and using nature of expense method should provide costs that are similar or come near to it. - The proposed calculation of the KPI CAPEX doesn't consider CAPEX included in joint ventures that are accounted in accordance with IAS 28 using the equity method. - CAPEX under the proposed Taxonomy also comprises additions to right-of-use assets under IFRS 16 which adds to complexity. - Relating to the definition of the KPI turnover we assume that there is an error in the norm referenced to. - A very detailed presentation of KPIs per activity, related targets and additional information leads to overreporting and often contains commercially sensitive information. Recommendation: OPEX: - reconsidering the general added value of OPEX reporting - clarification on whether calculation should cover overheads CAPEX: - option to consider IFRS 16 on a voluntary basis - include CAPEX in joint ventures under IAS 28 turnover: - reference to IAS 12 - no forecasting of Taxonomy’s KPIs due to a missing forecasting of the corresponding financial KPIs 3. Disclosure of CAPEX plan, Annex I, 1.1.2.2. (p. 15ff), Annex I 1.2.3.2. (p. 18) Issue: - The CAPEX plan shall be disclosed and approved by the Management Board of non-financial undertakings which disregards that it very often contains commercially sensitive information. - Non-financial undertakings shall disclose the key information about each of their CAPEX plans referred to in sections 1.1.2.2. and 1.1.3.2. Recommendation: - No disclosure of CAPEX plans - Removal of 7-year-criterion for expenditures to be considered as sustainable CAPEX 4. Reporting periods covering the KPIs and contextual information, Art. 9 (3), p.12 plus Annex I 1.2, 1.2.3 Issue: - Non-financial undertakings shall provide in the financial report the KPI covering the previous 5 years - Required explanation of the calculation of each KPI Recommendation: - Align reporting concept of Taxonomy disclosures to IFRS/local GAAP reporting standards by reporting current and previous year measures only - Provide a qualitative description of the calculation of each KPI instead of quantitative breakdown
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Meeting with Walter Goetz (Cabinet of Commissioner Adina Vălean)

12 Mar 2021 · enBW position paper re-AFI-D

Meeting with Stefanie Hiesinger (Cabinet of Executive Vice-President Frans Timmermans)

11 Mar 2021 · The role of the EU ETS on the path towards reaching climate neutrality

Response to Revision of EU rules on Gas

10 Mar 2021

General observations EnBW Energie Baden-Württemberg AG shares the vision of a climate neutral energy system and supports the objective of EU-climate neutrality. Renewable and decarbonized gases like biomethane and hydrogen will have to play a key role to reach this objective. For this reason, EnBW is engaged in the EU Clean Hy-drogen Alliance, working on projects along the gas value chain. We think that the revisions of Directive 2009/73/EC and Regulation (EC) No 715/2009 have the potential to enable the needed swift transition towards a climate-neutral gas sector and energy system. As regards hydrogen, today the high costs of the technology are the main barrier and therefore need to be reduced as quickly as possible by achieving economies of scale. EnBW welcomes the European approach for an EU hydrogen strategy and thus its implementation in the upcoming revision of the gas markets package. Main recommendations In our view, the following elements are important: • Broad application of hydrogen in distribution grids needed: As 60% of industry (registering power measurement as well as standard load profile) are connected to the distribution grid, 80% gas sales occur at distribution grid level. As the German Monitoring report points out, large emis-sion reductions could be achieved by blending of 20-25% H2 as of 2030. • Fast inclusion of hydrogen in the current regulatory EU framework on the premise that H2 will replace gradually natural gas in all applications/sectors: In order to achieve the Green Deal targets, uptake and scale-up in renewable and decarbonized gases need to take place in a very fast manner. The existing regulatory framework for natural gas is an established and proven framework that can achieve this task. It is familiar to all market participants and offers a strong degree of long-term predictability and reliability. In addition, it prevents possible fragmen-tation by the Member States. • Adoption of existing unbundling rules for hydrogen: Since the framework for natural gas has been successful in creating well-functioning markets, the production, transport, trading and sales of hydrogen should be organised in a similar way. Third party access and network access rules are part of this. • Need for uniform European certificate market: The climate characteristics of all climate-neutral gases should be certified, i.e. regardless of whether it is chemically H2 or CH4 or a gas mixture. This will create a much larger market, which can thus be more liquid and have a greater impact. • Level playing field between power and gas: As analysed in the Commissions Impact Assess-ments on the “2050 long-term strategy” as well as for the higher2030 targets, the power and gas systems should work together symbiotically towards decarbonisation. • H2 for flexible and climate neutral power generation: The goal to reach climate neutrality in power generation by 2040 requires an H2 pipeline connection to gas-fired power plants by 2035 at the latest. • Open approach for the heat sector: While further electrification of heat may provide a suitable solution for some European member states, others rely more on the existing gas grids. Depending on the region or local conditions, the otherwise needed strong extension and reinforcement of the electricity grid and renovation of buildings, urban infrastructure and industrial patterns can make the use and adaptation of the existing gas grid more suitable as a quicker, more cost-efficient de-carbonisation option. • Technological neutrality and market mechanisms concerning blending: Using gas-hydrogen blends in the short and medium term achieves a larger GHG reduction at a lower sys-temic cost than by using only new dedicated infrastructure to deliver hydrogen. • Development of European H2-Backbone and infrastructure for imports: Estimations for the German market point out, that in 2050 around 80% of H2 will need to be imported.
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Response to Europe’s digital decade: 2030 digital targets

9 Mar 2021

As Energie Baden-Württemberg AG and our subsidiaries, we welcome the initiative of defining European 2030 targets for the digital space. EnBW strongly supports the efforts to achieve the goals of the Gigabit Society as an important prerequisite of further digital transformation. Likewise, we want to become part of the ecosystem of excellence and trust for AI a well as a champion in the data economy. Highest standards in cybersecurity and security of critical infrastructures are part of our DNA. 1. digital infrastructure and connectivity Since digital infrastructure is the foundation of any other digital development – clear forthcomings in this area are of utmost importance. EnBW’s point of view, the goals of the Gigabit Society are adequate, important and should be the guideline until 2025. We welcome the initiatives and policies by the Institutions to accelerate on permits and projects. In the consultations on BCRD, we are offering thoughts on possible solutions concerning the timeline of projects. Having a glance at 2030, in terms of technology we do not see copper nor coaxial-cables as future-proof. Very high capacity networks and possible investments, which are supposed to last for decades should be directed into fibre networks. The basic approach of “open access” leads to competition which is good. Competition for customers is taking place, leading to better offers and more efficient solutions in service and technology. 2. digital education and skills We clearly support the Commissions agenda concerning education and skills. Added value of the European workforce in 2030 will heavily rely on a digital skillset. With a view towards 2030 human machine collaboration will become increasingly important, whereas the machine becomes a central partner of human workers. As a company ourselves, we embrace what technology has to offer and we invest accordingly in the competences of our staff. An essential point concerning skills data literacy. While not everybody needs to become a data scientist, it is important to have a common language on a working level in companies. 3. digital transformation of business In the realm of data and artificial intelligence, we strive to create solutions in energy, mobility, and infrastructures. From our point of view, digitalisation will increasingly become a driver for sustainability. As part of the European AI Alliance, we are happy to share our knowledge and experiences with policy makers to contribute to the ecosystem of trust and excellence. A balanced AI regulation with a scope that encourages innovation is very important.
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Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

Summary of main elements (cf.detailed recommendations attached): • EnBW Energie Baden-Württemberg AG is fully committed to the 2050 climate neutrality target and has set itself the objective of becoming carbon neutral by 2035. • EnBW also fully supports the envisaged objective and general set-up of the Taxonomy regulation as well as the principal structure and overarching goal of the draft delegated act on the technical screening criteria. • However, concerning the criteria set for the energy sector, it would be necessary to readjust the proposed ambitions with technically feasible and economically sound criteria and thresholds, to drive the transition in a broad and speedy way. All activities leading to significant emission reduction which helps on the pathway to decarbonisation should be eligible while ensuring that their further necessary decarbonisation or their replacement by other solutions will take place as soon as possible. • For Germany, we see gas fired power plants as indispensable not only for the transition phase to stabilise a system driven by predominantly intermittent renewables. While in the upcoming years natural gas with a certain amount of blending of renewable or low carbon gases will be necessary, this gas mix will have to be decarbonised as quick as possible. • Including a broader mix of technical solutions, being able to make a substantial contribution to reduce CO2 emissions quickly and with a clear obligation to fullfill the climate neutrality threshold over time would help to unlock the necessary immediate abatement potential and force operators of this activity to push for the decarbonisation of the fuel input. • Therefore, EnBW recommends the following most important changes : 1. General adjustments : • Clarification that the threshold designates an average value over the life-time of the project • Clarification that reviewed thresholds will only be applicable for new activities • Clarification that where reference values for LCA exists (e.g. German Environment Agency, UBA) it should be possible to make use of them. • Replace the obligation of LCA-verification by third parties by the option of a reference to a science-based approach 2. For Annex I - Climate Mitigation: o Activity 4.7 - Electricity generation from gaseous and liquid fuels : -> Adjustment of the classification to allow for a qualification as substantial contribution as well as the threshold for transitional activity to 250 gCO2e/kwh. o Activity 4.19 - Cogeneration of heat/cool and power using gaseous and liquid fuels: -> The same adjustments on the classification and thresholds should be done for cogeneration, with 250gCO2e/kwh measured at output level, and the production of heat/cool o Activity 4.14 - Transmission and distribution networks for gaseous fuels, including renewable and low-carbon gases: -> Removal of restriction limiting the criteria only to retrofit or dedicated hydrogen grids; hydrogen-readiness should suffice o Activity 4.5 - Electricity generation from hydropower: -> Adjustment of the DNSH criteria to the existing requirements of EU water and biodiversity legislation as well as the possibility to use standard values for the application of the LCA to reduce the burden of the evaluation o Activities 4.8, 4.9, 5.6, 5.7 - Electricity/ heat generation from bioenergy, sewage sludge and biowaste: -> Alignment with the requirements of RED II o Activity 3.9 - Manufacturing of hydrogen: -> Adjustment of the criteria according to the TEG recommendations. o Activity 4.13 Manufacturing of biogas and biofuels in transport: -> Application of the same requirements as for use in electricity and heat production via reference to RED II. 3. For Annex II - Climate Adaptation - activity 4.7, 4.19 and 4.23: -> Alignment of the threshold for the DNSH criteria for power generation from gas to BAT standards
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Response to Revision of the CO2 emission standards for cars and vans

25 Nov 2020

For input: CO2 standards for cars and vans - revision (Roadmap) EnBW Energie Baden-Württemberg AG fully supports the 2050 decarbonization target of the European Union and the European Commission’s amendment of the Regulation setting CO2 emission standards for cars and vans. Decarbonizing the EU economy is a pivotal and time-critical challenge that all sectors and market actors need to respond to - especially in the transport sector, significant emission reductions are necessary. Concerning the policy options outlined in the inception impact assessment, we would like to comment on the overall level of ambition regarding the levels of stringency and targets, the assessment basis for emissions and the type of vehicles to be targeted. In light of the European Green Deal and the increased climate ambition of the European Union, we believe that the current emission standards are not ambitious enough and need to be tightened. Current standards do not sufficiently contribute to significant decrease in emissions emerging from the transport sector and are not a genuine move towards zero-emission mobility. Further, we strongly endorse that emission standards should ensure that vehicles on EU roads are clean not only during the initial assessment but over their entire lifetime at any typical usage. Moreover, the emission standards should be based on the real driving emissions of the vehicles and not the WLTP cycle. Real driving emissions have shown to be 10 to 30% above the WLTP cycle emissions, especially concerning powerful large cars and vans, which are in reality driven completely differently compared to the laboratory test environments. Therefore, the European Commission should ensure that real driving emissions are consistently assessed and compared to the WLTP cycle test values. Deviations need to be addressed and reflected in the respective development of the emission standard/ WLTP cycle test values. Lastly, the issue of plug-in hybrid electric vehicles (PHEV) needs to be addressed in the current amendment to the emission standards. To sustainably and effectively transition to zero-emission mobility in the European Union, PHEV need to be addressed with their actual contribution to emission reductions. Research has shown that PHEV are usually driven electrically for approx. 20% of the total distance driven. Therefore, PHEV should only contribute to fleet emissions to a limited degree, reflecting their real-life usage and should only be credited in a minor way to the overall fleet emission target.
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Response to Requirements for Artificial Intelligence

9 Sept 2020

As EnBW Energie Baden-Württemberg AG we welcome the approach of European Commission to conduct an Impact Assessment concerning ethical and legal requirements for AI. For several years already we have developed AI solutions in the energy sector. As operator and service provider in the field of critical infrastructures, we at EnBW operate multiple self-developed AI services already productively. These include AI-assisted overhead power line inspection by using drones, predictive maintenance of offshore wind turbines, securing public places by means of AI-assisted barrier systems, automatic detection of road damage and detection of damage to gas and water pipes. Lately we have been awarded “AI-Champion of Baden-Württemberg” - as EnBW we would like to share our expertise in an ecosystem of excellence in the EU. Our view on the outlined alternative options to the baseline scenario: Option 3c would most probably be an overall inhibitor as from the start. 3b puts up heavy hurdles for some selected sectors. As outlined in the white book on AI, the energy sector would suffer under this form of general suspicion of being a “high-risk” sector (white paper on AI, page 17). The first criterion already gives rise to fears of bureaucracy, while being too broad at the same time. In the coming years we need room for innovation instead of discrimination of individual sectors. For a risk-assessment of particular applications, a clear definition of “high-risk” would be very much needed from an industrial perspective. Rather soft measures (e.g. guidelines or other approaches which leave room for innovation) should be preferred before introducing bureaucratic certification processes. Concerning the outlined alternative options to the baseline scenario, we would advocate option 2. A voluntary labelling scheme would complement the existing EU legislation, which already sets high standards for example concerning liability (e.g. the product safety directive for products) or personal data (GDPR). A good example to operationalise AI ethics using labels can be found under: https://www.ai-ethics-impact.org/en Similarly, page 19 of the German report on the data ethics commission lines this out. (https://www.bmjv.de/SharedDocs/Downloads/DE/Themen/Fokusthemen/Gutachten_DEK_Kurzfassung.html;jsessionid=6202CA13F73BDB281E78F2F374F783E8.1_cid334?nn=11678504) Because of the diversity of products, services, customers and processes, it would be best to have individual labels and industry-inspired processes to qualify. Common guidelines might be helpful. For customers and employees it is important to understand the path of getting to a label – transparency is important, explainability creates trust.
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Response to Evaluation of State Aid rules for broadband infrastructure deployment

10 Aug 2020

As EnBW Energie Baden-Württemberg AG and our subsidiary NetCom BW, we welcome the initiative of the roadmap on the evaluation of EU state aid rules concerning the deployment of broadband. EnBW supports the efforts to achieve the goals of the Gigabit Society. As a company, we are active in fibre optic broadband expansion and offer both FTTC as well as FTTB/H-accesses. On efficiency: Municipalities and local communities today are in fact favoured to be connected to broadband networks. Progress, concerning more equal living conditions in the city and on the countryside, has been made. From EnBW's point of view, the goals of the Gigabit Society are adequate and important – still somewhat far from being achieved and unfortunately slow in the process of being delivered. In the feedback towards BCRD Roadmap, we offered our thoughts on possible solutions concerning the timeline of projects. On efficiency and competition, we would like to emphasize a major problem: In the context of the expansion of fiber optic infrastructure, we consider the network superposition of commercial over previously subsidized fiber optic networks to be a major problem. This is economically inefficient for the society, since the expansion of fiber optic networks is originally subsidized because telecommunications network operator did not see a self-supporting commercial expansion via the market investigation procedure. A subsequent additional commercial expansion therefore devalues the subsidized expansion/network: Mayors and municipal councils often complain that large telecommunications companies (TCs) are not interested in commercial expansion in the first step, but after expensive, subsidized expansion by others, they build their network over the existing subidised network. The large TCs then offer more favourable contracts and thus devalue the subsidised network, paid essentially by taxpayers. A ban on super positioning / building over subsidised networks would promote broadband expansion. In the questionnaire of the upcoming public consultation, it would be conceivable to ask other stakeholders on their view on this problem. On competition: The basic approach of “open access” leads to more competition. Competition for customers is taking place, leading to better offers and more efficient solutions in service and technology. On technology and funding: In terms of technology we do not see copper nor coaxial-cables as future-proofed. Solely fiber netwoks are the Very high capacity networks, which are supposed to last for decades. Therefore, possible publicily funded investments should be directed only into fibre networks. Moreover, we want to shed a light on business strategies that aim at the conservation of monopolies based in copper technologies. Those efforts to block or delay State Aid investments should be confronted, if possible – the market of new solutions and citizens would largely profit. In the long run, in some cases funding of the demand-side could be needed. This can happen if the population does not consider further bandwidth to be necessary. Future applications will most probability not be based on currently perceived needs. A review of bandwidth limits of the 2013 legislation would be helpful to achieve the Gigabit Society level, same as a clear definition of “grey areas”.
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Response to EU Methane Strategy

31 Jul 2020

EnBW Energie Baden-Württemberg AG shares the vision of a climate-neutral energy system and supports the goal of EU climate-neutrality by 2050. While methane emissions occur internationally along the entire value chain, EnBW and its subsidiaries operate in gas mid- and downstream in Germany. EnBW complies with all technical standards and regulations for methane emissions (ME) and works to undercut them. In view of renewable and decarbonized gases, EnBW considers gas as an important energy carrier of the future. General observations: • EnBW supports EU-wide MRV standards: The gas industry has reduced ME to the extent, that in 2017 only about 6,2% of ME in Europe were coming from the oil and gas industry (Estimation of DVGW; close to estimations of EEA/UBA). In order to further reduce ME, the Methane Guiding Principles have been developed. Further optimization and standardisation of MRV are welcome. • Comparability of data via uniform standards in and outside the EU: The EnBW gas network operators are recording and about to further improve to record the emission quantities as accurately as possible in order to develop a complete and transparent register of all ME in the network area. To ensure comparability, it is necessary that the recording of ME is carried out according to uniform (EU) standards. EnBW therefore supports such a reliable database. This database should as well include upstream emissions from outside the EU. Business activities in gas trading do not lead to direct ME – however, gas trading volumes could be linked to upstream ME. Biogas production: • Biogas production can contribute significantly to reducing methane emissions: On the precondition of using manure and waste as feedstock, biogas production can contribute significantly to reducing ME in agriculture and waste treatment. The technical potential for manure (solid and liquid) and waste lies in 2030 at 900 PJ/a (EU28). If the negative CO2 emissions for the fermentation of manure according to RED II are taken as a basis, 44,3 Mio. tCO2eq/a can be avoided in agriculture by the fermentation of manure. • Effective voluntary emission monitoring system to further reduce leakages: Due to leakages in safety devices, ME can occur in biogas plants and biomethane treatment plants. An effective voluntary emission monitoring system must be developed together with the biogas sector (e.g. EvEmBi-project). Gas distribution networks and gas storage: • Further reduction needs regulatory incentive: In addition to the successes achieved so far (reduction in distribution of about 60% in ME since 1990, while increasing volumes of transport by 25%) further possibilities of ME reduction lie in the areas of monitoring to identify the major emitters, (optimized) inspection methods, handling in the event of damage, use of innovative technology in operational needed evacuation procedures and a predictive maintenance. Common to all these possibilities is the need for a regulatory incentive to cover costs that are currently not economically viable. • Likewise, in gas storage the detection of unplanned and unavoidable emissions of very small quantities is difficult to achieve or even technically impossible. Gas-fired power stations: • Combustion technology of modern boilers and gas turbines is highly advanced: According to findings of different sources, ME are essentially not produced during the combustion of natural gas, but up-front. Despite further development, the engines themselves cannot significantly be improved. The lever of reducing ME is the fuel employed (renew. and decarb. gases). • Gas engines are an indispensable technology for future energy system, especially for use in CHP-plants and small generation plants. Further requirements for ME reductions would lead to a significant increase in costs without a mentionable gain in overall emission reductions. Gas power plants will be needed as flexible capacity for electricity generation from renewable and decarbonized gases.
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Response to Sustainable and Smart Mobility Strategy

28 Jul 2020

EnBW Energie Baden-Württemberg AG fully supports the 2050 decarbonization target of the EU as well as the target to reduce transport-related GHG emissions by 90% until 2050. EnBW strongly endorses the initiative to adopt a comprehensive EU Strategy for a Sustainable and Smart Mobility as part of the European Green Deal that advances European mobility for a green and digital future and modern economy. Individual road transport is a significant contributor to transport-related GHG emissions in the EU. In 2017, road transport made up 72% of total transport GHG emissions. Of these road transport emissions, 44% were due to passenger cars. The figure reveals the substantial negative contribution of passenger car road transport to GHG emissions but also the substantial possibility and scope to reduce emissions. At the same time, the 2019 Eurobarometer survey on mobility provides important findings to consider regarding citizens’ usage patterns. Cars remain the main mode of transport on a typical day for European citizens (52%) in all Member States whereby these vehicles are almost entirely powered by conventional fuel (91%) – leading to the above-mentioned emissions. Only 1% of vehicles used for daily mobility are zero-emission cars. At the same time, citizens are aware of the detrimental impact of road transport on the environment as a major challenge for daily mobility (29%) and willing to switch to more environmentally friendly forms of transport (59%). Based on the composition of transport emissions and the reality of citizens mobility patters, the EU strategy first and foremost needs to address the emissions of individual mobility in terms of passenger car road transport. Hereby, accelerating the uptake of zero-emission passenger cars and the corresponding necessary infrastructure is of upmost importance (i, ii and iii). At the same time, emission standards for conventionally powered vehicles need to genuinely reflect the EU’s goal to move to zero-emission mobility and thus significantly decrease transport sector emissions (ii and vi). Such an approach provides definitive clarity of purpose and will give a clear direction in the European Union’s policies. Freedom of choice for customers as well as rules for a level playing field to ensure fair competition for all market players are the main cornerstones that truly facilitate the uptake of electric mobility and the transition to zero-emission transport. Only on this basis can the desired connectivity for citizens, seamless charging all over Europe and innovation in the market be enabled. Whilst mandatory targets for charging infrastructure lead to an inaccurate allocation of capital, intelligent bundled European-wide, national and regional funding schemes based on the dissemination target for vehicles and accelerated administrative processes advance the build-up of charging infrastructure. Current emissions standards for conventionally powered vehicles do not sufficiently contribute to any significant decrease in emissions emerging from the transport sector. In view of the impacts of previous manipulative efforts on emissions standards and given the persistent shortcomings of fuel consumption testing, there is an urgent need to adopt a comprehensive and stringent approach ensuring compliance, robustness, and enforcement, e.g. real driving emissions tests. As identified, the EU strategy needs to centre holistically and with the highest priority on reaping the benefits of clean mobility for European citizens. Individual mobility and passenger car road transport is the most important lever for reducing emissions and should therefore be the focal element of the strategy. Incentivising the uptake of zero-emission vehicles, advancing the corresponding infrastructure, intelligent linking of transport systems based on digital platforms as well as sector coupling and implementing stringent emission standards that truly reflect the EU’s ambitions should be the main pillars of the str
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Response to Review of the Broadband Cost Reduction Directive (Directive 2014/61/EU)

17 Jul 2020

As EnBW Energie Baden-Württemberg AG and our subsidiary NetCom BW, we welcome the initiative of the roadmap for the revision of the Broadband Cost Reduction Directive (BCRD) and the efforts to ensure that the revision will serve to achieve the goals of the Gigabit Society. As a company, we are active in fiber optic broadband expansion and offer both FTTC and FTTB/H connections. In the context of the expansion of fiber optic infrastructure, we consider the network superposition of commercial over previously subsidized fiber optic networks to be a major problem. This is economically inefficient for the society, since the expansion of fiber optic networks is originally subsidized because telecommunications network operator did not see a self-supporting commercial expansion via the market investigation procedure. A subsequent additional commercial expansion therefore devalues the subsidized expansion/network: Mayors and municipal councils often complain that large telecommunications companies (TCs) are not interested in commercial expansion in the first step, but after expensive, subsidized expansion by others, they build their network over the existing network. The large TCs then offer more favourable contracts and thus devalue the subsidised network, paid essentially by taxpayers. A ban on super positioning / building over subsidised networks would promote broadband expansion. In the following we would like to try to outline solutions to the problem of "burdensome and long-lasting permit granting procedures", which has already been identified by the EU and addressed in the roadmap: Larger time losses are caused by times spent waiting and communicating during the permit granting process. This is often due to ambiguities regarding the eligibility of (passive and active) technology. Individual consideration, examination and communication have the effect of delaying the projects. It would therefore be helpful to draw up a catalogue of eligible measures, in which market prices, e.g. for the one meter of civil engineering (excavation), are stored. If a project remains within a corridor of normal market prices, individual considerations could be dispensed with and thus considerable time could be saved. A federal specification with a clear description of the eligibility of all technical components (also with regard to the dimension of the final construction) by the federal funding agency would be of great advantage. In order to reduce the duration and possibly also the costs of environmental/nature conservation tests, it would be conceivable to work with (digital) maps, which, similar to maps of landscape conservation areas, would facilitate planning. A quick view of "obstacles to expansion" would be useful. The same applies to obtaining information on existing (underground) infrastructure. Unfortunately, there is no uniform, let alone digital, instrument for obtaining this information. A uniform and in the best-case digitized system would greatly simplify and accelerate this situation (e.g. an Infrastructure Atlas on gas, water, communication, street lighting, etc.). The existence of preliminary confirmations towards applications helps to start a project. However, there is often considerable time spent waiting, when it comes to receiving a response to a final application for funding. Here it would be advantageous to significantly reduce the processing time, e.g. by using the catalogue approach. In most cases, TCs do not answer all the questions that local authorities pose, in the course of market exploration, but often use standardised reply letters. However, the local authorities have to ask questions twice in order to establish with legal certainty that the questions are considered unanswered. Time is also lost at this point, which leads to the extended project-timelines.
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Response to A EU hydrogen strategy

8 Jun 2020

General observation: EnBW Energie Baden Württemberg AG shares the vision of a climate neutral energy system and supports the objective of EU-climate neutrality by 2050. Electrification of other sectors and H2 will have to play a key role to reach this objective. Today the high costs of the technology are the main barrier and must be reduced as quickly as possible by achieving economies of scale. Therefore, EnBW welcomes an EU H2 strategy. The consultation document addresses the essential issues. However, it is necessary to keep an open approach on possible use cases of H2 and gas infrastructure applications in different sectors. This can also help to create the needed economies of scale which again help to bring down the costs. It would be useful to develop a sector-specific roadmap for the use of H2 with the associated intermediate steps. Recommendations: A sector open approach to a H2 economy: Hydrogen will have to play a role in decarbonizing the power and heat sector. In countries where intermittent renewables dominate, the power sector would also need hydrogen to balance the system with green and decarbonised gas power plants. Also, in the heat sector we see a significant potential of GHG-reduction via green gases grounded on existing infrastructures - not at least due to the low renovation rates of buildings or restrictions on installation capacities hampering a stronger up-take of heat-pumps. GHG oriented approach to H2 quality definitions: EnBW is advocating for a rapid decarbonisation of the gas sector via biomethane and H2. Blue H2 will be necessary for a while as the most cost-efficient solution, while green H2 production could be competitive latest by 2050. The decisive factor for the regulatory framework should be the GHG-emissions that are linked to the different gases in full life-cycle analyses. Imports despite domestic long-term competitiveness of green H2: Although the establishment of domestic European production of clean H2 will be in place in 2050, imports will be necessary due to naturally given limitations of production capacity and short- to mid-term stronger competitiveness. Close integration into existing EU gas market regulation: An adequate regulatory framework is of utmost importance. To avoid market distortion, EnBW advocates for including H2 in existing regulation, especially the EU Gas Directive and regulation. A functioning market for H2 can be reinforced via strengthening of the ETS and a price for CO2. Since this will not be enough, it is important to not only focus on incentivising production but rather the demand side, e.g. a GHG-oriented quota on the demand side, with a sub-quota for green H2 and a proper Guarantees of Origin system. Conversion of gas grid to become 100% hydrogen-ready by 2040: Due to the lead-time of long-lasting infrastructures, it is important to consider the final capacity needed in 2050 already when constructing it in the upcoming years. We recommend anchoring the target-year 2040 in the EU H2 roadmap for the completion of the gas infrastructure transformation. Thereby, existing gas pipelines must be taken into consideration as they can be converted to H2 pipelines over time. Joint network development plans at EU-level and cross-border coordination would enable synergies. Temporarily underutilized infrastructure must be tolerated while the transportation volume increases step by step. Distribution grid as lever to scale up and decarbonize the heating sector: Since power and heat generation, in contrast to large-scale pure H2 consumers, are mainly connected to the distribution grid, a future gas grid should reflect this. Via blending of H2 in the distribution grid, larger quantities of demand are generated delivering also additional economies of scale and foster a functioning H2 market. Where certain users, connected to the distribution grid, would need certain gas qualities or pure H2, technical solution would allow to filter the blended gas mix if needed.
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Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis)

4 Jun 2020 · Taxonomy

Meeting with Aliénor Margerit (Cabinet of Commissioner Paolo Gentiloni)

4 Jun 2020 · Sustainable Finance

Response to Union renewable Financing mechanism

3 Jun 2020

General observations : Energie Baden Württemberg EnBW AG welcomes the proposal for the financing mechanism in general as a supplementary tool to foster the deployment of renewables across Europe and especially to contribute to secure the achievement of the EU 2030 target for renewables. In general, it has to be avoided that the mechanism serves as an option for financing Member States not to do the utmost for fullfilling their targets in their own country as well as for the hosting Member State to replace its own project line. Recommendations: In our view, the following elements should be clarified or adjusted : • Lacking clarity on permitting procedures : One of the main challenges in the renewables deployment is the length and uncertainty of permitting procedures ; the draft regulation Art. 22 (1) does not clarify what elements would be considered mandatory for the project developers for their application or to which degree the hosting Member State would have to undergo certain approval procedures upfront (e.g. environmental impact assessments for offshore projects). These elements should be further specified. • Technology neutrality vs. technology specific auctions: EnBW very much welcomes the option of technology specific tenders as the impact of different renewables technologies on the system can vary significantly and therefore a need to foster one technology more than the other might be necessary. An adequate mixture in the renewables portfolio can bring system costs down. Therefore, it should be necessary that the hosting Member State have to give its consent to this elementof the auction design instead of a decision by the Commission only. • Assuring sufficient competition: The basis for sufficient competition should be created by making sure that a variety of actors can participate and a level playing field for all actors is guaranteed. However, appropriate minimum requirements should be set for the financial and technical capacity of the developer. Otherwise, there is a significant risk of non-realisation. Also sanctions in case of non-realisation of projects should be considered (see Article 13). It is essential that the selection of projects/developers takes place in a transparent and objective procedure. It is not only necessary that the selection criteria must be clarified up-front in the call for proposals, but that there is sufficient time for the competitors to prepare their application ; local developers should not have an industrial policy advantage.
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Response to Revision of Alternative Fuels Infrastructure Directive

4 May 2020

EnBW Energie Baden-Württemberg AG supports the revision of Directive 2014/94/EU on the Deployment of Alternative Fuel Infrastructure to encourage the use of low- and zero-emission vehicles. To successfully contribute to the European Green Deal, we suggest the revision to highlight the following aspects: 1. Free choice of customers regarding the authorization and payment method used at the recharging station to enable seamless charging all over Europe Ad hoc charging shall be possible at every charging station in Europe whilst there shall be no obligation for credit/debit card terminals. Added security measures for RFID cards may be achieved using coupling of charging cards to EMP apps. 2. We believe in a competitive market for e-mobility and a market-based price formation mechanism. Prices are set in a competitive market environment so that there is no need for any retail price regulation. Yet, price transparency and information are essential for the customer and shall be displayed through digital means to the customer (mobility app, charging station display). 3. Standardisation must be accompanied by rules for a level playing field that guarantee the free choice of customers and prevent anti-competitive behaviour Customers shall not be restricted in the use/non-use of ISO 15118 or the choice of their EMP. As ISO 15118-2 Ed.1 only allows one charging contract for Plug&Charge per vehicle, it is potentially highly damaging to market competition. The application of this version shall therefore not become mandatory. The installation and regular update of charging contracts must be possible for all EMPs without delay at transparent and fair conditions in all vehicles. The PKI should be operated by a neutral entity and ensure cross-border interoperability. 4. CPOs shall grant EMPs fair access to their recharging infrastructure based on fair tariff negotiations/mutual agreements EMPs must have fair access to charging stations of CPOs. Access should be organised within competition rules based on bilateral negotiations and permitting differentiated pricing models of CPOs for EMPs. Roaming platforms provide a good opportunity to connect EMPs and CPOs Europe-wide. 5. Static and basic dynamic data of charging stations and vehicle batteries shall be easily available for customers. Customers shall freely decide on the use and transmission of the vehicle data. With the consent of the user, charging related and other relevant data from the electric vehicle must be shared and made available to other market participants (battery state of charge etc.). CPOs own the data of their charging stations. Static data and basic dynamic data (vacant, occupied etc.) shall be freely accessible to customers and other market players. Premium dynamic data (charging history etc.) and basic dynamic data related to individual charging sessions shall be marketable by CPOs/EMPs. There shall be no state-run platforms for data transmission as private platforms will develop in a competitive environment. 6. Intelligent bundled funding schemes based on long term targets and accelerated administrative processes advance the dissemination of recharging infrastructure – rather than mandatory targets Mandatory national targets for charging infrastructure and a fixed electric vehicle to charging station ratio lead to inaccurate allocation of capital. Rather, targets for charging infrastructure shall be reasonably linked with dissemination targets of BEV/PHEV and non-public charging infrastructure. 7. Customer-friendly charging provides a competitive advantage for CPOs Customers need to be able to locate charging stations easily and have transparency of the status of charging stations before choosing a charging station. Minimum requirements for technical standards (socket location on car, recommended cable length) are needed, yet minimum requirements for quality of charging (SLA, availability ratio) are not feasible since, in competition, CPOs will aim for excellent quality.
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Response to Development of Euro 7 emission standards for cars, vans, lorries and buses

28 Apr 2020

We strongly endorse this initiative that supports the Green Deal and helps to ensure that vehicles on EU roads are clean not only during the initial assessment but over their entire lifetime at any typical usage. We encourage to stress that current standards do not sufficiently contribute to any significant decrease in emissions emerging from the transport sector and are not a genuine move towards zero-emission mobility. We would like to emphasize that current vehicle emission standards, such as Euro6, are not flawed due to complexity, which was added intentionally into its design, but rather by a lack of real-world applicability during lifetime and typical usage, not to speak of manipulations such as in the case of Dieselgate. Furthermore, we remind that the main purpose of the OBD functionality was not to limit the tampering of the emissions caused by a vehicle. Regarding the objectives and policy options of the regulation, we urge to focus on a two-step approach that is introducing option 2 in the short term and option 3 as soon as possible. We appreciate the objective to improve air quality especially in urban areas. It is of utmost importance to include testing procedures related to typical emissions in urban and residential areas, such as cold start emissions. We are aware that noise limits of vehicles are part of Reg. EU No 540/2014. However, we stress that health protection includes not only emissions in terms of pollutants and particles but also noise emissions. Geo-fencing enabling zero-emission modes may be combined with low-noise modes as an option. Although we welcome the idea of OBM, we fail to comprehend the fundamental difference between OBM and current OBD. We would like to add that statistical data over the vehicle’s lifetime from OBM, such as the actual average fuel consumption of individual models and of an vehicle manufacturer’s entire fleet, may be used to improve consumer protection and to encourage vehicle manufacturers to develop features nudging drivers to a more fuel-saving behavior. Regarding the preliminary assessment of expected economic impacts, we question that a simplification of the emission standards might result in an increase in consumer trust (see option 1). In our opinion, only a strict application of comprehensive and accurate standards will result in an increase in consumer trust. Again, in the preliminary assessment of option 3, we would like to point out that simplifying or replacing OBD carries risks and shall be done carefully, e.g. stripping only emission-related functionalities. Any intentional or unintentional manipulation of vehicle data must be prevented effectively. Additionally, we express our curiosity concerning geo-fencing not being mentioned again in the preliminary assessment. Regarding the preliminary assessment of social impacts, we question the conclusion that option 1 is expected to result in a moderate improvement in public health. Furthermore, we would like to highlight that positive social impacts are not limited to mortality & morbidity and include other effects of positive environmental impacts. Although we acknowledge counter-intuitive negative effects may happen, we question the prospect of higher consumer prices in options 2&3 affecting the affordability of Euro7 vehicles for low-income households. We are highly interested in any statistical data that back this assumption, e.g. data on households’ purchases of new and used vehicles, and the effect of stronger regulation on prices. Moreover, we were not able to follow the reasoning of why keeping older vehicles has a negative impact on social inclusion or why the use of alternative modes of transport is a negative impact at all. Lastly, in view of the impacts of Dieselgate and given the persistent shortcomings of fuel consumption testing, we call on the EC to adopt a comprehensive and stringent approach towards Euro7 ensuring compliance, robustness against tampering, and enforcement over the entire lifetime of
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Response to Climate change mitigation and adaptation taxonomy

27 Apr 2020

EnBW Energie Baden-Württemberg AG fully supports the 2050 decarbonization target. We have to considerably strengthen our efforts to trigger the intensive transition movement. Therefore, we very much welcome the envisaged objective and general set-up of the Taxonomy regulation and the principal structure and overarching goal of the TEG Report. However, we see an urgent need in the energy sector to readjust the proposed ambitions with technically feasible and economically sound solutions. We specifically need a broader approach for the transition phase, in order to cope with the great transformational challenges. While in the current situation the Taxonomy framework is even more necessary to keep the compass of the Green Deal transition and support the direction of the reduced financial means into future proved investments, a cost-efficient pathway is more important than ever. In general: • All activities leading to significant emission reduction which help on the pathway to decarbonisation should be eligible, • a smooth implementation of the taxonomy rules, especially the analyses of the activities, should be as simple and user-friendly but also as robust as possible, • a flexible approach, so that the restriction of the screening criteria to only a certain set of activities should not have the effect of penalising other activities not (yet) covered. Specifically: • Thresholds for power generation and CHP from gas have to be revised to realistic milestones: The current threshold of 100 g CO2/kwh de facto excludes natural gas as an eligible abatement option. The threshold cannot be achieved at least until the 2030s if CCS is excluded due to the lack of public acceptance and a very high feed-in of renewable/ decarbonised gases is technically or economically not possible in this time frame. However, climate-neutral gas can constitute an important contribution to a decarbonised energy system in the future, at least for countries where nuclear is not accepted, the geographical situation provides mainly intermittent renewable electricity generation and a high industrialisation rate causes further challenges. The Commission should define an ambitious but realistic starting point which is possible without lock-in risk. Therefore, a threshold of 390 g CO2e/kwh for CCGT and 500 g CO2e/kwh for OCGT should be the starting point. To secure ambitions and to avoid lock-in we suggest as supplementary criteria: o substantial contribution to the overall emission reduction by performing at least 10% better than the average of direct CO2 emissions/kwh of non-intermittent electricity produced; o substantial contribution to the security of supply; o avoidance of lock-in effects due to the capability to blend in renewable and decarbonized gases in the lifetime of the asset. The thresholds should be progressively reduced after 2030 when an increasing amount of low carbon and renewable gases will be produced with an ambitious pathway towards the 2050 objective. The same arguments hold true for highly-efficient cogeneration. • Revision and extension of the criteria for gas grids As long as investments in gas grids allow for hydrogen readiness, the grids should be treated as neutral if the gas feed-in is on a pathway towards carbon neutrality. Therefore, also extension/new build of gas infrastructure should be eligible. This holds specifically true for some regions in transition, which have relied historically on nuclear and/or coal generation and where the necessary grid infrastructure also on DSO level is so far not in place. Also, for hydrogen networks new build must be eligible. • Simplifying and clarifying the methodological requirements A uniform LCE/A methodology to ensure comparability and reliability should be provided by the Commission before the application of the taxonomy becomes mandatory. The proposed measurements are not yet sufficiently tested and comprehensive enough. In the absence, only direct CO2 emissions should be measured.
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Meeting with Miguel Arias Cañete (Commissioner) and BDEW Bundesverband der Energie- und Wasserwirtschaft e. V. and

20 Nov 2017 · clean energy package

Meeting with Maroš Šefčovič (Vice-President) and

9 Oct 2017 · Electric Mobility

Meeting with Maria Cristina Lobillo Borrero (Cabinet of Vice-President Miguel Arias Cañete)

19 Apr 2017 · Clean Energy Package- state of play in the European Parliament and the Council

Response to Commission Regulation establishing a guideline on electricity balancing

2 Jan 2017

The Electricity Balancing Guideline (EBGL) is a cornerstone for the development of a fully integrated European energy market. In order to achieve a reliable balancing mechanism and to ensure that the balancing system provides the necessary incentives for market parties to become active in all markets across all timeframes, we would like to address the following key messages that still need to be reflected in the EBGL. Clear market roles are essential for well-functioning markets: Each BRP is responsible for its individual balance of generation and load and thus needs to be given the maximum possibilities to balance their position up to real-time. TSOs should only be responsible to cover the residual imbalance. Thus the open formulations in the EBGL as regards to activation purposes are critical as it may lead to an “optimisation” process of TSOs (e.g. mixing-up of balancing and congestion management activities). This must be ruled out as it will bring a lack in transparency and inexplicable interplays for market participants. No predetermination of an obligatory balancing energy market: With extending the submission of balancing energy bids up to real time, a similar and most likely overlapping market to the existing intraday market would be established. This will have adverse consequences on intraday liquidity and prices. We are of the strong opinion that the balancing market design should limit the overlap with intraday markets and should actually foster liquid intraday markets close to real-time for selb-balancing of BRPs. In fact, all of the short-term flexibility should become available in intraday markets. Already today a large contribution to the short-term correction of the system imbalance comes from intraday trading taking place shortly before GTC, reducing the resulting TSO balancing needs. Therefore, we do not support a balancing energy market and strongly believe that the negative side-effects on intraday markets are to be taken seriously. Balancing energy markets will reduce incentives to be active on intraday markets and lead to a reduction of liquidity. We strongly recommend that the introduction of a balancing energy market should only be designed as an option, not as an obligation. A short term market for balancing energy can only be an intermediate step towards a liquid intraday market. No predetermination of pricing method for balancing energy / results of pilot studies must be incooperated: The obligatory prescription of the introduction of a marginal-pricing scheme for the settlement of balancing energy will lead to an optimal result per se. Any expected benefit of the introduction of a marginal-pricing on the resulting BRP incentives depends on unpredictable adjustments of market participants’ bidding behaviour. In our view an established market design with pay-as-bid pricing can deliver equivalent incentives for BSPs and BRPs. In fact, with regard to the general applicability for all balancing products and across TSOs, marginal-pricing causes a lot more difficulties and unwanted side-effects than pay-as-bid. This has recently been demonstrated by the EXPLORE project which also investigated the problems of applying a marginal price in practice. Especially the discussion on the preconditions (homogenous good) that would be required to actually utilize the theoretical results on efficiency of marginal pricing and the conclusions on the actual complexity for creating bids clearly demonstrates the need for further analysis. Thus, we strongly support the proposal of the EXPLORE project to also include the pay-as-bid approach into the decision alternatives.In our view, the EBGL should not predetermine the pricing method for balancing energy products without taking the outcome of the pilot studies into account, including a clear definition of the decision criteria for the final proposal for a pricing method. In fact, Recital 6 of the EBGL foresees exactly such a process.
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Meeting with Günther Oettinger (Commissioner)

8 Nov 2016 · Energy Economy in Germany

Meeting with Miguel Arias Cañete (Commissioner)

8 Nov 2016 · Market design

Meeting with Joachim Balke (Cabinet of Vice-President Miguel Arias Cañete)

15 Jun 2016 · Market Design

Meeting with Christian Linder (Cabinet of Vice-President Maroš Šefčovič)

1 Mar 2016 · Energy Union - State of play

Meeting with Soren Schonberg (Cabinet of Commissioner Margrethe Vestager)

16 Apr 2015 · EU energy and State aid policy

Meeting with Joachim Balke (Cabinet of Vice-President Miguel Arias Cañete), Maria Cristina Lobillo Borrero (Cabinet of Vice-President Miguel Arias Cañete)

12 Mar 2015 · Exchange on the current EU energy and climate policy topics

Meeting with Christian Linder (Cabinet of Vice-President Maroš Šefčovič)

12 Mar 2015 · Presentation of the compnay, Energy Union