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ENEL SpA

Enel is a multinational power company and a leading integrated player in the global power and renewables markets, with operations in 28 countries worldwide.

Lobbying Activity

Meeting with Benedetta Scuderi (Member of the European Parliament)

15 Jan 2026 · Industry and Energy

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

16 Dec 2025 · Energy prices for energy intensive industries

Meeting with Felicia Stanescu (Cabinet of Executive Vice-President Raffaele Fitto), Gabriele Giudice (Cabinet of Executive Vice-President Raffaele Fitto) and Endesa

11 Dec 2025 · Energy policy topics

Meeting with Miguel Gil Tertre (Cabinet of Executive Vice-President Teresa Ribera Rodríguez), Thomas Auger (Cabinet of Executive Vice-President Teresa Ribera Rodríguez) and Endesa

11 Dec 2025 · Perspectives on Italian and Spanish markets, climate resilience, security of supply and level playing field.

Meeting with Michele Piergiovanni (Cabinet of President Ursula von der Leyen)

11 Dec 2025 · Presentation of the group and views on energy policies

Meeting with Bernardus Zuijdendorp (Head of Unit Taxation and Customs Union) and IBERDROLA and

9 Dec 2025 · Meeting with representatives of 9 European multinationals on Pillar Two, "Side-by-Side" approach & a level playing field

Enel urges inclusion of renewable energy sales in EU Taxonomy

5 Dec 2025
Topic — A review of the technical screening criteria within the EU taxonomy environmental delegated act.
Message — Enel requests including the sale of certified renewable electricity as an eligible activity to complete the energy value chain. They argue this change would more accurately reflect contributions to climate change mitigation.12
Why — This would increase Enel's reported sustainable turnover and improve its access to green finance.34
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Meeting with Felix Fernandez-Shaw (Director Directorate-General for International Partnerships) and ELECTRICITE DE FRANCE and

1 Dec 2025 · 4th meeting of the Working Group on Regional Electricity Integration in Latin America and the Caribbean

Enel calls for nuclear inclusion in EU climate policies

27 Nov 2025
Topic — The consultation explores the development and deployment of Small Modular Reactors in Europe.
Message — Enel requests nuclear energy's integration into EU energy policies and climate funding tools. They advocate for increased research funding and updated regulations for modular reactors. They seek equal access to investment programs alongside other clean technologies.123
Why — Equal access to EU budgets would reduce financial risks and attract private capital.4
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Meeting with Martin Hojsík (Member of the European Parliament) and Clean Air Task Force, Inc. and

26 Nov 2025 · Geothermal energy breakfast

Meeting with Pietro Fiocchi (Member of the European Parliament) and EPIA SolarPower Europe and

26 Nov 2025 · Tematiche ambientali

Meeting with Elisabetta Gualmini (Member of the European Parliament) and Association des Constructeurs Européens d'Automobiles and Hydrogen Europe

26 Nov 2025 · ITRE Committee

Meeting with Elena Donazzan (Member of the European Parliament)

26 Nov 2025 · Incontro di aggiornamento su temi energetici, focus sul pacchetto "energy grids"

Meeting with Bruno Tobback (Member of the European Parliament) and Edison Spa

13 Nov 2025 · EU Energy Policy

Enel calls for harmonized EU circularity standards and recycling incentives

6 Nov 2025
Topic — New EU regulation on circular economy and secondary raw materials for clean technologies.
Message — Enel requests harmonized EU standards for waste and secondary materials, financial rewards for companies investing in recovery research, and flexible repowering rules that avoid full site restitution requirements. They argue current fragmented regulations hinder recognizing waste as secondary raw materials.123
Why — This would reduce compliance costs and administrative burdens for their waste management operations across borders.45
Impact — Environmental groups lose stronger waste disposal restrictions and mandatory site restoration during wind farm repowering.67
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Meeting with Monika Zsigri (Head of Unit Energy)

6 Nov 2025 · Exchange on climate adaptation for electricity grids

Enel urges EU to prioritize electricity grid funding in 2028-2034 budget

28 Oct 2025
Topic — EU's next long-term budget (MFF 2028-2034) covering various funding programmes and priorities.
Message — Enel requests dedicated minimum funding for electricity distribution grids separate from transmission infrastructure, streamlined funding processes under CEF, and stronger commitment to electrification in the European Competitiveness Fund. They advocate for maintaining current grant levels for large enterprises and support the EU Preference principle with adequate backing mechanisms.123
Why — This would secure predictable investments in their core distribution grid business and maintain favorable grant conditions.45
Impact — Transmission grid operators may face reduced relative priority if distribution receives dedicated separate funding.6
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Energy Giant Enel Calls for Priority Funding for Electricity Distribution Grids

28 Oct 2025
Topic — EU's next long-term budget framework for research, innovation, and infrastructure funding 2028-2034.
Message — Enel requests dedicated minimum funding for electricity distribution grids to boost renewable energy hosting capacity and climate resilience. They advocate for streamlined funding processes, stronger commitment to electrification in industrial decarbonization, and support for nuclear SMR technologies.123
Why — This would accelerate investments in their electricity distribution infrastructure and support their nuclear technology ventures.45
Impact — Other sectors competing for decarbonization funds lose priority as distribution grids receive dedicated allocations.67
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Enel urges dedicated EU funding for electricity distribution grids

28 Oct 2025
Topic — EU's next long-term budget (Multiannual Financial Framework) for 2028-2034 and competitiveness funding.
Message — Enel requests dedicated minimum funding for electricity distribution grids, streamlined access to funds through simplified single-stage processes, and stronger commitment to electrification in industrial decarbonization. They advocate for sector-specific reform objectives not tied to unrelated disbursements and harmonized implementation rules across Member States.123
Why — This would secure consistent funding for their core distribution grid infrastructure and enable deployment of smart grid innovations.45
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Enel urges EU to prioritize electricity distribution grid funding

28 Oct 2025
Topic — EU's next long-term budget for cohesion, agriculture, fisheries and networks 2028-2034.
Message — Enel requests dedicated minimum funding for electricity distribution grids, independence from transmission grid financing, and support for nuclear technologies. They advocate for streamlined funding processes and a multi-project approach for global investments.123
Why — This would secure consistent investment flows for their distribution grid modernization and electrification projects.45
Impact — Regions with weaker grids could fall behind if national plans don't adequately prioritize local infrastructure needs.67
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Enel urges dedicated EU funding for electricity distribution grids

28 Oct 2025
Topic — EU's long-term budget framework 2028-2034 and infrastructure funding mechanisms.
Message — Enel requests a minimum dedicated amount of funding for electricity distribution grids within the National and Regional Partnership Plans to ensure consistent investment flow. They emphasize that distribution grid funding should not be tied to transmission infrastructure and advocate for sector-specific reform objectives under the money-for-reform mechanism.123
Why — This would secure funding for their distribution grid modernization and avoid delays from transmission-linked requirements.45
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Meeting with Carlo Fidanza (Member of the European Parliament) and Eni S.p.A. and Association Internationale de la Savonnerie, de la Détergence et des Produits d'Entretien

21 Oct 2025 · legislative updates

Power giant Enel urges EU-made product incentives in green procurement

14 Oct 2025
Topic — EU rules on environmental standards for public procurement of solar and wind technologies.
Message — Enel requests incentives for EU-made products and a harmonized methodology for carbon footprint assessment before setting thresholds. They propose additional technical requirements for solar panels including recycling certification and resistance standards.123
Why — This would help Enel compete by rewarding EU manufacturing and clarifying compliance requirements.45
Impact — Non-EU manufacturers face competitive disadvantages from Made in EU preferences and stricter standards.6
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Enel calls for delayed AI Act enforcement and simplified data rules

14 Oct 2025
Topic — EU digital simplification covering data protection, AI, cybersecurity, and data-sharing rules.
Message — Enel requests delayed AI Act enforcement until guidance and authorities are operational, exemptions for technical data from cookie requirements, postponement of Data Act chapters until 2026, and streamlined cybersecurity reporting through a single entry point.1234
Why — This would reduce compliance costs and give time to prepare systems while protecting commercially sensitive infrastructure data.567
Impact — Public authorities lose access to company data that could inform policy and emergency response.89
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Enel urges EU to prioritise flexibility and storage in energy security

13 Oct 2025
Topic — Revising EU energy security framework for decarbonised, electrified, and crisis-resilient systems.
Message — Enel supports targeted reinforcement of the EU energy security framework, emphasising demand-side flexibility, distribution grid upgrades, storage deployment targets, and accelerated electrification. They call for binding roadmaps, clearer governance, and comprehensive cybersecurity measures including coverage of distributed energy technologies.1234
Why — This would accelerate deployment of Enel's renewable generation, storage assets, and flexibility services across European markets.56
Impact — Fossil fuel producers lose market share as electrification and renewables reduce import dependency.78
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ENEL urges EU to ease state aid rules for clean tech manufacturing

6 Oct 2025
Topic — Revision of EU regulation exempting certain state aid categories from prior Commission approval.
Message — ENEL requests higher exemption thresholds to enable strategic investments in technology and innovation. They want simplified procedures with standardized documentation to reduce administrative burden. They advocate extending GBER coverage to clean tech manufacturing with investment support and operational aid.123
Why — This would allow ENEL to access larger subsidies for manufacturing facilities and reduce compliance costs.456
Impact — Non-EU manufacturers face stronger European competition subsidized by operational state aid beyond investment support.78
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Meeting with Susanna Ceccardi (Member of the European Parliament)

23 Sept 2025 · ENEL Back to School

ENEL SpA Urges Greater Flexibility for Energy Market Reporting

15 Sept 2025
Topic — Rules for the supervision of inside information platforms and reporting mechanisms under REMIT.
Message — ENEL requests precise deadlines for reporting platforms to provide updated technical specifications to clients. They advocate for validation before publication and seek flexibility to use alternative disclosure channels.123
Why — This would reduce compliance burdens by allowing the use of multiple channels for disclosures.4
Impact — Other market participants lose efficient access to data if publication is fragmented across various channels.5
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Enel urges Commission to limit reporting burdens in REMIT revision

15 Sept 2025
Topic — The consultation updates rules for data reporting to ensure wholesale energy market transparency.
Message — Enel wants to remove production and consumption forecasts from reporting requirements. They suggest shortening reporting horizons to eighteen months to align with industry practice. The company proposes replacing complex algorithm IDs with a simple reporting flag.123
Why — This would reduce compliance costs and simplify operational requirements for the company.45
Impact — Regulators lose granular oversight of trading strategies and internal production forecasts.67
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ENEL Backs Global Carbon Markets and Resilient Energy Infrastructure

11 Sept 2025
Topic — The initiative outlines the EU's global climate and energy strategy for 2025-2029.
Message — The company calls for all nations to align targets with the 1.5°C goal using concrete timelines. They advocate for setting up international carbon markets and investing in resilient infrastructure.123
Why — Consistent governance would lower investment uncertainty and help markets operate more efficiently.45
Impact — Providers of low-quality carbon offsets would be excluded by stricter verification standards.6
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Enel urges EU-wide mandates for large corporate vehicle fleets

8 Sept 2025
Topic — EU initiative setting minimum requirements for zero-emission vehicle uptake in corporate fleets.
Message — Enel proposes a uniform regulation mandating zero-emission targets for fleets exceeding 100 vehicles. They also recommend including charging infrastructure costs in financial support schemes.12
Why — Mandated electrification increases electricity demand and provides grid flexibility via smart charging.34
Impact — Large fleet operators will face significant expenses for vehicle procurement and private charging infrastructure.5
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Enel demands unified ETS aid caps and clean-tech eligibility

5 Sept 2025
Topic — The consultation reviews rules for compensating industries for indirect carbon emission costs.
Message — Enel recommends including solar panel manufacturing in the aid scheme to support industrial decarbonization. They also propose a strict 75% cap to prevent market distortions between countries.12
Why — Including solar manufacturing would help their green energy production business stay globally competitive.3
Impact — German energy-intensive companies could lose the advantage of exceeding the standard compensation cap.4
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Meeting with Rosalinde Van Der Vlies (Director Energy)

3 Sept 2025 · Exchange of views on retail market issues

Meeting with Paula Rey Garcia (Head of Unit Energy)

9 Jul 2025 · Permitting and CfDs schemes

Enel urges linking carbon markets and integrating removal credits

7 Jul 2025
Topic — A review of the EU's emissions trading system and market stability reserve.
Message — Enel suggests linking industrial and transport carbon markets to improve market activity. They want carbon removal credits included to help companies meet targets. Finally, they seek EU-wide rules to compensate industries for high electricity costs.123
Why — Centralized compensation rules would lower their operational costs and ensure fair competition.4
Impact — Environmental advocates may lose if carbon credits substitute for direct industrial emission cuts.5
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Enel Urges EU To Prioritise Industrial Electrification and Resilience

7 Jul 2025
Topic — A proposal to accelerate the decarbonisation of energy-intensive industries while maintaining competitiveness.
Message — Enel recommends streamlining permitting for renewable energy and grid infrastructure. They advocate for non-price criteria like EU content in public procurement. They also request financial supports including grants and tax incentives.1234
Why — Faster permitting and network upgrades would help Enel deploy more renewable energy and electrification projects.5
Impact — Foreign manufacturers, especially Chinese solar companies, would lose market share to "made in Europe" products.67
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Enel pushes for 'Made in EU' criteria in Innovation Fund

2 Jul 2025
Topic — Evaluation of the EU Innovation Fund's operations and performance between 2020 and 2024.
Message — Enel proposes prioritizing projects with "Made in EU" production and sourcing to support local economies. They also advocate for funding distribution networks and simplifying the application process for project developers.123
Why — Streamlined procedures and expanded eligibility would lower administrative costs for Enel's energy projects.45
Impact — International technology providers may face exclusion due to new local sourcing and production requirements.6
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Response to EU Fusion Strategy

24 Jun 2025

Dear Members of the European Commission, Enel SpA, an international power company, highly appreciates the possibility to provide feedback on EU Fusion Strategy Consultation. For further details on our position, please refer to the document attached to this feedback.
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Enel urges simplified and harmonized EU cybersecurity rules

20 Jun 2025
Topic — The initiative revises the Cybersecurity Act to update ENISA’s role and certification frameworks.
Message — Enel requests simplification and harmonization among the many cybersecurity laws to address overlapping requirements. They propose a mapping matrix so that specific technical controls automatically satisfy multiple legal obligations. The company also insists on maintaining the voluntary adoption of certification schemes.1234
Why — Unified rules would reduce administrative burdens and compliance costs for the energy giant.56
Impact — National authorities may see their specific regulatory competences diminished by a centralized framework.7
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Meeting with Felix Fernandez-Shaw (Director Directorate-General for International Partnerships) and Airbus and

12 Jun 2025 · High-level Roundtable on Colombian energy sector with exchange of views between Minister of Mines and Energy, IFIs and EU companies.

Meeting with Katarina Koszeghy (Cabinet of Commissioner Wopke Hoekstra) and IBERDROLA and

26 May 2025 · Exchange of views on the need and prospects for simplification in Pillar 2, in particular in light of the current situation with the US

Meeting with Felix Fernandez-Shaw (Director Directorate-General for International Partnerships) and ELECTRICITE DE FRANCE and

20 May 2025 · 3rd meeting of the Working Group on Regional Electricity Integration in Latin America and the Caribbean.

Meeting with Stéphane Séjourné (Executive Vice-President) and

15 May 2025 · European solar industry

Meeting with Aleksandra Kordecka (Cabinet of Executive Vice-President Stéphane Séjourné) and European Chemical Industry Council and

14 May 2025 · Implementation of Clean Industrial Deal

Enel urges EU to grant nuclear equal climate funding

12 May 2025
Topic — The Commission's program provides an overview of investment needs for the nuclear ecosystem.
Message — Enel wants nuclear energy integrated into EU climate financing and policy frameworks. They advocate for equal access to investment instruments and funding for new technologies.12
Why — This would lower financial risks for Enel and help attract private capital.3
Impact — Public services lose funding if non-energy levies are removed from electricity bills.4
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Response to Technical description of important and critical products with digital elements

18 Apr 2025

Dear Members of the European Commission, The Enel Group, a multinational company and a leading operator in the power and renewables markets of Europe, welcome the public consultation on the possibilities to build up a holistic European Cyber Resilience Act. Please find attached the complete response to the consultation. Best regards, Almudena Diaz
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Meeting with Felice Zaccheo (Head of Unit Directorate-General for International Partnerships)

16 Apr 2025 · Exchange of views on the Regional Electricity Market (MER) in Central America and other Global Gateway energy initiatives in Latin America and the Caribbean, focusing on the synergies with the investments from ENEL in the region.

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

15 Apr 2025 · Clean Industrial Deal

Response to Interim evaluation of the Strategic Technologies for Europe Platform (2024-2025)

2 Apr 2025

ENEL's positioning is contained in the document attached.
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Meeting with Felix Fernandez-Shaw (Director Directorate-General for International Partnerships) and

1 Apr 2025 · Plenary Feedback round on previously held GGIA Working Group sessions of 9 different thematical groups regarding Latin America and the Caribbean (LAC).

Meeting with Felix Fernandez-Shaw (Director Directorate-General for International Partnerships) and ENGIE and

31 Mar 2025 · Workshop on: “Powering Integration: Strategic Partnerships for Regional Electricity Integration in Latin America and the Caribbean”

Meeting with Jozef Síkela (Commissioner) and ELECTRICITE DE FRANCE and

28 Mar 2025 · H2 Financing Facility

Meeting with Susanna Ceccardi (Member of the European Parliament)

26 Mar 2025 · Priorities in the field of Industry, Research and Energy

Meeting with Carlo Fidanza (Member of the European Parliament)

26 Mar 2025 · Introductory meeting

Meeting with Isabella Tovaglieri (Member of the European Parliament, Committee chair)

25 Mar 2025 · Politiche energetiche europee

Meeting with Silvia Sardone (Member of the European Parliament, Committee chair)

25 Mar 2025 · ENVI COMMITTEE

Meeting with Jozef Síkela (Commissioner) and

24 Mar 2025 · Global Gateway

Meeting with Dario Nardella (Member of the European Parliament)

20 Mar 2025 · Priorities in the field of Industry, Research and Energy

Response to EU Start-up and Scale-up Strategy

17 Mar 2025

The position of ENEL is expressed in the attached document
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Meeting with Jutta Paulus (Member of the European Parliament, Shadow rapporteur) and Climate Action Network Europe and

14 Mar 2025 · Security of Energy Supply

Meeting with Aldo Patriciello (Member of the European Parliament)

11 Mar 2025 · transizione energetica

Meeting with Giorgio Gori (Member of the European Parliament)

6 Mar 2025 · Electricity grids and the role of distribution system operators

Enel Urges Water Strategy to Prioritize and Protect Hydropower

4 Mar 2025
Topic — The initiative seeks a multi-annual plan to ensure European water resilience.
Message — Enel demands the strategy preserves hydropower capacity and harmonizes water rights across Member States. They suggest aligning water taxation with actual benefits and pollution contributions.12
Why — The proposal would provide regulatory stability and better remuneration for Enel's flexible hydropower assets.34
Impact — Environmental groups lose as the strategy may favor energy production over strict ecosystem protection.5
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Meeting with Bruno Tobback (Member of the European Parliament, Shadow rapporteur)

4 Mar 2025 · Europe’s energy infrastructure and enhancing regional cooperation

Meeting with Dario Tamburrano (Member of the European Parliament, Shadow rapporteur) and Huawei Technologies and

4 Mar 2025 · Reti elettriche

Meeting with Stefano Soro (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

11 Feb 2025 · Scaling up solar PV manufacturing in Europe

Meeting with Giorgio Gori (Member of the European Parliament, Rapporteur)

4 Feb 2025 · Exchange of views on upcoming Resolution on Energy Intensive Industries

Meeting with Anna Stürgkh (Member of the European Parliament, Rapporteur)

3 Feb 2025 · INI Report on grids

Response to Standards for wireless recharging, electric road system and vehicle-to grid-communication of recharging infrastructure

21 Dec 2024

Enel Group is pleased to engage in the public consultations regarding the draft delegated and implementing acts supplementing Regulation (EU) 2023/1804 (AFIR Regulation) on alternative fuel infrastructures data sharing. We consider these consultations a vital opportunity to finalize and elucidate the regulatory framework, thereby promoting the harmonized development of recharging infrastructure across Europe. Nonetheless, certain provisions within the draft regulations under review may impose substantial burdens on charging point operators, potentially escalating the costs of recharging infrastructure and services and impacting end users. Regarding the ISO 15118-20 standard, applicable to all charging points starting in 2027, we need to ascertain which use cases are mandatory (for example: bidirectional, plug and charge etc). If bidirectionality is needed, the 2027 deadline might be particularly challenging, as this feature is not widely used yet. Please find in the document attached Enel Group's main observations on the all 4 draft regulations under consultation.
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Response to Common technical requirements for a common application interface for alternative fuels infrastructure data

21 Dec 2024

Enel Group is pleased to engage in the public consultations regarding the draft delegated and implementing acts supplementing Regulation (EU) 2023/1804 (AFIR Regulation) on alternative fuel infrastructures data sharing. We consider these consultations a vital opportunity to finalize and elucidate the regulatory framework, thereby promoting the harmonized development of recharging infrastructure across Europe. Nonetheless, certain provisions within the draft regulations under review may impose substantial burdens on charging point operators, potentially escalating the costs of recharging infrastructure and services and impacting end users. We support the implementation of the OCPI (Open Charge Point Interface) for API integration standard, as it is more commonly used in EV charging infrastructures compared to DATEX II. OCPI is specifically designed for the EV charging sector, facilitating interoperability and communication between different charging networks. DATEX II, on the other hand, is primarily used for traffic management and the exchange of travel-related information, rather than for managing EV charging infrastructures. Please find in the document attached Enel Group's main observations on the all 4 draft regulations under consultation.
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Response to Technical specifications related to the format, frequency and quality of data on alternative fuels infrastructure

21 Dec 2024

Enel Group is pleased to engage in the public consultations regarding the draft delegated and implementing acts supplementing Regulation (EU) 2023/1804 (AFIR Regulation) on alternative fuel infrastructures data sharing. We consider these consultations a vital opportunity to finalize and elucidate the regulatory framework, thereby promoting the harmonized development of recharging infrastructure across Europe. Nonetheless, certain provisions within the draft regulations under review may impose substantial burdens on charging point operators, potentially escalating the costs of recharging infrastructure and services and impacting end users. Here are the primary observations of the Enel Group regarding the format and the data flow to the National Access Points (NAPs): In 2024, in Italy, the Piattaforma Unica Nazionale National Single Platform (PUN, https://www.piattaformaunicanazionale.it/), managed by Gestore dei Servizi Energetici Spa (GSE), was implemented, which allows citizens, businesses and public administrations to access a map of all charging points present on the Italian territory. The PUN also provides a detailed set of information and data on charging stations and tariffs, which already partly includes most of the data required by the AFIR and the draft regulations under consultation. We note that the AFIR now necessitates that we also submit this data to the NAP (CCISS in Italy), an additional entity distinct from GSE (who manages the PUN). Furthermore, we note that the format mandated by the PUN for the operators is OCPI (Open Charge Point Interface) rather than DATEX II. We note that the format the PUN is requiring to the operators is OCPI (Open Charge Point Interface) and not DATEX II. A similar platform is also present in Spain (RIPREE) which collect Static data and Red Electrica de Espana (REE) is developing a platform to collect dynamic data both through OCPI. As is widely known, OCPI is more prevalently utilized in EV charging infrastructures compared to DATEX II. OCPI is specifically designed for the EV charging sector, facilitating interoperability and communication between different charging networks. DATEX II, on the other hand, is primarily used for traffic management and the exchange of travel-related information, rather than for managing EV charging infrastructures. To create synergies and avoid unnecessary and costly duplications of data flows, it would be best to allow the OCPI format alongside DATEX II and establish a direct flow between any given similar already existing national platform (as the PUN in Italy) and the NAP. Please find in the document attached Enel Group's main observations on the all 4 draft regulations under consultation.
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Response to Data types for alternative fuels infrastructure

21 Dec 2024

Enel Group is pleased to engage in the public consultations regarding the draft delegated and implementing acts supplementing Regulation (EU) 2023/1804 (AFIR Regulation) on alternative fuel infrastructures data sharing. We consider these consultations a vital opportunity to finalize and elucidate the regulatory framework, thereby promoting the harmonized development of recharging infrastructure across Europe. Nonetheless, certain provisions within the draft regulations under review may impose substantial burdens on charging point operators, potentially escalating the costs of recharging infrastructure and services and impacting end users. Here below the primary observations of the Enel Group we would like to bring to your attention related to some data in the list: Service support, and facilities offering associated services to the user: This data is not available in our systems and is very problematic to be provided in terms of availability. We would like to emphasize that CPOs can only submit data on services belonging to their charging hubs (services operated by the CPO or business partners). It is not feasible to submit data on services in the surroundings of the charging hubs (e.g., nearby restaurants) due to the high effort and frequent changes to nearby services. Unless this requirement is essential, we recommend making it optional to avoid additional costs for operators to provide and update this information. Vehicle-type compatibility: This data is not available in our systems. We already provide the type of connector data. Knowing the connectors they need, EV drivers have sufficient information to filter the stations they can use. Mandating this information is not necessary by our point of view. Vehicle specifications permitted: This data is not available in our systems and there are issues in providing it. We suggest making this information optional rather than mandatory. Number of parking spaces dedicated for people with disabilities: this data is not available in our systems and there are issues in providing it. A CPO can only provide information about the charging stations, not the parking spaces, and we do not yet know if they are suitable for people with disabilities. We suggest making this information optional. Mobility service providers offering contract-based recharging: Clarification is needed from the EC regarding which MSPs are meant for contract-based recharging. In Italy, we have more than 100 MSPs connected to our charging stations and over 40 in Spain. Is it necessary to have about 100 additional fields for each charging station? If this requirement is indeed necessary and must remain mandatory, it could be considered to expand the information to include the full list of all MSPs integrated with the CPO, not just those offering contract-based recharging. Electricity supplied is 100 % renewable: there are issues with providing this information. We can only provide information about electricity covered by Guarantee of Origin for each Points of Delivery (PODs) owned by Enel, not for those managed by Enel but owned by third parties. We suggest making this information optional. Please find in the document attached Enel Group's main observations on the all 4 draft regulations under consultation.
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Meeting with Stefano Bonaccini (Member of the European Parliament)

10 Dec 2024 · Meeting with ENEL

Meeting with Antonio Decaro (Member of the European Parliament)

10 Dec 2024 · Energy charge supply

Meeting with Raffaele Fitto (Executive Vice-President)

10 Dec 2024 · General introductory discussion on ongoing energy-related issues

Meeting with Massimiliano Salini (Member of the European Parliament)

10 Dec 2024 · EU Industrial strategy

Meeting with Miguel Gil Tertre (Cabinet of Executive Vice-President Teresa Ribera Rodríguez) and WindEurope and

5 Dec 2024 · To discuss European wind industry

Meeting with Elena Donazzan (Member of the European Parliament)

3 Dec 2024 · Aggiornamento sui temi energetici della Commissione ITRE

Meeting with Isabella Tovaglieri (Member of the European Parliament)

26 Nov 2024 · Discussione su politiche energetiche europee

Meeting with Magda Kopczynska (Director-General Mobility and Transport) and European Chemical Industry Council and

7 Nov 2024 · Ambrosetti Club Europe - Transport and mobility priorities

Enel backs strict emission rules for low-carbon hydrogen

25 Oct 2024
Topic — The EU is establishing a methodology to measure emissions from low-carbon fuels.
Message — Enel requests a full life cycle assessment for hydrogen including leaks and methane emissions. They advocate for technology-based sub-classifications and including electrolysis among low-carbon fuel types.123
Why — This allows Enel to increase the operating hours of its hydrogen production facilities.45
Impact — Fossil-based hydrogen producers face stricter scrutiny regarding methane leaks and carbon capture effectiveness.6
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Meeting with Pasquale Tridico (Member of the European Parliament)

23 Oct 2024 · Meeting with Michele BOLOGNA- ENEL

Meeting with Dario Tamburrano (Member of the European Parliament)

22 Oct 2024 · Priorità per la legislatura

Meeting with Pietro Fiocchi (Member of the European Parliament)

22 Oct 2024 · Temi ambiente

Meeting with Antonella Sberna (Member of the European Parliament)

22 Oct 2024 · Energy market challenges and competitiveness

Meeting with Dan Nica (Member of the European Parliament) and NOVE and

22 Oct 2024 · Debate on challenges and opportunities for the energy sector with focus on Romania and CEE Countries

Meeting with Mariateresa Vivaldini (Member of the European Parliament)

22 Oct 2024 · Meeting conoscitivo

Meeting with Paolo Borchia (Member of the European Parliament)

22 Oct 2024 · EXCHANGE OF VIEWS

Meeting with Pasquale Tridico (Member of the European Parliament)

14 Oct 2024 · Meeting with ENEL

Meeting with Benedetta Scuderi (Member of the European Parliament) and European Association for Storage of Energy and Energy Storage Coalition

3 Oct 2024 · Energy

Response to Revision of the electricity guideline on forward capacity allocation.

30 Sept 2024

(For more details please refer to the attached document) Both consumers and suppliers need effective forward markets to manage long-term price exposure and reduce short-term market price risks. While day-ahead, intraday, and balancing markets have seen significant harmonization and integration over the past fifteen years, the forward market has received less attention. While fully supporting the objectives of the European Commission proposals, the Enel Group suggests not to force the introduction of regulated Regional Virtual Trading Hubs (RVTH), since it would represent a significant paradigm shift that could disrupt the well-functioning of forward markets, unless strong benefits are clearly demonstrated by a comprehensive qualitative and quantitative impact assessment. We do not see the establishment of RVTH as a tool to solve current forward market fragmentation and poor liquidity in several bidding zones, to avoid possible detrimental effects on market functioning. Our main concerns are: - Lack of evidence for liquidity: No proof that Zone-To-Hub (Z2H) Long Term Transmission Rights (LTTRs) will enhance liquidity in Virtual Hubs. Phasing out current Bidding Zone Border (BZB) LTTRs in favor of Z2H products would be detrimental for the market removing, or lowering the effectiveness of cross border hedging opportunities; - Unaddressed liquidity issues: the proposal does not tackle the real issues behind the current lack of liquidity, such as high cash collateral requirements, regulatory interventions, and lack of incentives for retailers to participate in the forward market for deliveries over 1-2 years; - Possible ostracization of some regions: predefining hubs based on Coordinated Capacity Regions (CCRs) could isolate some bidding zones, such as the Iberian peninsula from continental Europe if defined at the CORE level; - Implementation time: as an untested concept, implementation could take 5-10 years, conflicting with the proposed ambitious timeline; - Risk of Financial Transmission Rights (FTR) obligations: defining FTRs as obligations rather than options could expose market participants to unlimited price spread risks, reducing liquidity; - Hedging efficiency: Virtual Trading Hubs (VTHs) may not improve and could worsen hedging efficiency, increasing basis risk due to price volatility between zones and the hub; - An artificial introduction of VTHs may reduce the range of trading instruments. Instead, we recommend maintaining the current allocation mechanism, improving it with more practical solutions (listed below): - using Virtual Location Capacity Option (VLCO) that simulates the FTR Option product through a swap contract: for a specific notional amount, the buyer pays a fixed price to the seller, who pays a variable price. With exchange support, VLCO could help build a secondary market for the FTR Option, enhancing market liquidity and providing longer-term product references without eliminating the current LTTR market; - Organizing more frequent auctions; - Allocating LTTR products with maturities matching forward market product maturities, at least 3-year tenor LTTRs; - Developing secondary markets to boost liquidity; - Providing regulatory certainty and avoiding market interventions; - Improving collateral regulations by accepting non-cash collateral like non-collateralized bank guarantees or underlying electricity production/customer contracts/ETS permits; - Considering voluntary market makers to drive liquidity in forward markets; - Facilitating cross-border hedging opportunities through improved long-term transmission right products and allocation. TSOs should increase long-term cross-border capacity volumes through efficient capacity calculation and adequate investment. These solutions can be implemented sooner and allow suppliers and consumers to protect against volatile prices over longer periods without increasing the complexity of the forward hedging framework and associated liquidity risks.
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Meeting with Josep Borrell Fontelles (High Representative) and Banco Santander, S.A. and

30 Sept 2024 · The objective of the lunch is to gather the views of key representatives from the EU private sector regarding the present situation in Mexico and prospects under the new administration, notably from an economic perspective, in an open dialogue.

Meeting with Elena Donazzan (Member of the European Parliament)

24 Sept 2024 · Incontro conoscitivo e scambio di vedute sul mandato del Parlamento Europeo

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

23 Sept 2024 · EU Energy and Industry Policy

Response to Interim evaluation of the Fusion for Energy Joint Undertaking

5 Sept 2024

ENEL Group appreciates the opportunity to provide feedback to the European Commission's call for evidence regarding the interim evaluation of the Fusion for Energy (F4E) Joint Undertaking. As a group closely monitoring advancements in nuclear technology, including Small and Advanced Modular Reactors (SMRs and AMRs) as well as nuclear fusion, ENEL Group firmly believes in the importance of continued research and development (R&D) in fusion energy.
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Response to Ecodesign requirements for air heating and cooling products (review)

30 Aug 2024

Enel supports the EU Ecodesign and energy labelling policies and agrees with the need to keep the legislation up-to-date and in line with the latest technological developments, with cost-effectiveness and proportionality criteria in mind. Enel would like to suggest that also aspects related to energy system integration of reversible heat pumps could be addressed by the Commissions proposal and its accompanying impact assessment, including Demand Response capabilities and features, so future Heat Pumps become smart and flexible assets for the energy system. The European heat pump stock to be installed in the upcoming years and decades has a vast potential to become a large pool for flexibility and demand response services to the energy system. If properly designed with the right features, heat pumps could increasingly contribute to balance increasing supply and demand peaks and imbalances in the energy system and its grids on a daily basis, phenomena that will be gradually aggravated by the expected increase of intermittent renewables share in the system. Taking advantage of such potential would reduce costs for the EUs energy system and for consumers. We believe that Heat Pump flexibility/demand response services should remain market driven and that ecodesign is the right place to decide on the design features that Heat Pumps should have to adequately react to market driven signals in the near future, facilitate interoperability and communication with other devices, adequately interact with smart meters and allow for aggregation of Demand Response services. More specifically, we suggest that the following elements could be approached with a dedicated cost-benefit analysis, particularly on the impacts of heat pumps deployment and on the benefits for the overall energy system: Making new heat pumps placed in the EU market smart, easily interoperable and demand response ready. Assess the convenience to mandate the inclusion of metering functionality that could be used as a Dedicated Measurement Device (i.e. a sub-meter) as defined in the revised Electricity Market Design directive. Assess the convenience to include more sophisticated requirements on control functionality. s More details can be found in the paper attached.
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Response to Recommendation to promote the development of innovative forms of solar energy deployment

2 Apr 2024

Dear Members of the European Commission, Enel SpA, an international power company, highly appreciates the possibility to provide feedback on the Innovative forms of solar energy deployment Consultation. Regulatory barriers, particularly those concerning the multifaceted use of land and water, alongside non-regulatory obstacles such as financial gaps inherent in technology implementation, must be carefully addressed to facilitate the deployment of solar energy initiatives. In this context, Enel welcomes the European Commission's initiative which will accompany a Commission Recommendation. In this sense, we would like to contribute to this discussion by providing some important actions that, in our opinion, would help the solar energy sector, especially for the implementation of innovative forms of photovoltaic projects. For further details on our position, please refer to the document attached to this feedback.
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Meeting with Nicolas Schmit (Commissioner) and

6 Mar 2024 · Labour and skills shortages, the EU's social targets, the European Pillar of Social Rights Action Plan

Enel urges technology-specific rules for renewable energy auctions

1 Mar 2024
Topic — The Commission is proposing new recommendations for the design of renewable energy auctions.
Message — Enel demands technology-specific pre-qualification criteria to ensure clarity and transparency. The company suggests using bid bonds to guarantee project completion. Non-price criteria must avoid duplicating existing permitting requirements and national policy instruments.123
Why — Enel would gain lower administrative burdens through clearer and technology-specific auction rules.4
Impact — Industrial consumers risk higher costs if negative bidding distorts the power market.5
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Response to Assessment of the energy efficiency public funding support at Union and national level

26 Feb 2024

Enel welcomes the agreement reached on the EU Energy Efficiency Directives Fit for 55 recast. Enel believes that an increasing electrification of the economy should play a major role in reaching a highly efficient energy use in the UE and in contributing to the 2030 energy and climate targets. The formula to calculate Member States national contributions should continue to guide the Commission assessment of Energy Efficiency contributions from Member States. Enel supports a dedicated guidance from the Commission to Member States in the following topics: - The implementation at national level of Article 8 with an increased ambition on Energy Savings Obligation should strike a trade-off between Energy Savings Obligation Schemes towards energy operators and Alternative Measures. - Encourage Member States to disseminate information on available energy efficiency improvement measures and to create access to legal and financial advice to all market actors. - Promote the role of Energy Services Companies and new contracting modalities as a pillar for Energy Efficiency savings. - Promote direct incentives and financial support to overcome the economic and non-economic barriers of energy efficiency interventions, particularly in the buildings sector and including fuel switching interventions. - Ensure that transmission and distribution system operators do not invest in stranded assets. - Finally, the availability of qualification, accreditation, and certification schemes to ensure the appropriate level of competences for energy efficiency professionals is crucial to overcome the lack of expertise and qualification. Please find further details in the document attached.
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Response to Guidance to Member States and market actors to unlock private investments in energy efficiency (EED recast)

26 Feb 2024

Enel welcomes the agreement reached on the EU Energy Efficiency Directives Fit for 55 recast. Enel believes that an increasing electrification of the economy should play a major role in reaching a highly efficient energy use in the UE and in contributing to the 2030 energy and climate targets. The formula to calculate Member States national contributions should continue to guide the Commission assessment of Energy Efficiency contributions from Member States. Enel supports a dedicated guidance from the Commission to Member States in the following topics: - The implementation at national level of Article 8 with an increased ambition on Energy Savings Obligation should strike a trade-off between Energy Savings Obligation Schemes towards energy operators and Alternative Measures. - Encourage Member States to disseminate information on available energy efficiency improvement measures and to create access to legal and financial advice to all market actors. - Promote the role of Energy Services Companies and new contracting modalities as a pillar for Energy Efficiency savings. - Promote direct incentives and financial support to overcome the economic and non-economic barriers of energy efficiency interventions, particularly in the buildings sector and including fuel switching interventions. - Ensure that transmission and distribution system operators do not invest in stranded assets. - Finally, the availability of qualification, accreditation, and certification schemes to ensure the appropriate level of competences for energy efficiency professionals is crucial to overcome the lack of expertise and qualification. Please find further details in the document attached.
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Response to Guidance to facilitate the designation of renewables acceleration areas

23 Feb 2024

Dear Members of the European Commission, Enel SpA, an international power company, highly appreciates the possibility to provide feedback on the Guidance on designating renewables acceleration areas. Enel believes that this initiative can be an important tool to help unblock the obstacles preventing the advance of renewable sources, enabling the achievement of the objectives of the EU Green Deal and REPowerEU. Considering that many renewable energy projects are currently facing various difficulties regarding licensing procedures, especially with regards to the wind power plants which can take up to 9 years to obtain all the necessary permitting to get the project up and running. In Italy, for example, the success rate of proceedings (calculated as the ratio of the volumes of projects authorized (and not yet built) to the volumes of projects to date in the authorization process) is about 16%. So, in this context, it is of utmost importance to implement the provisions legislated in the REDIII about the proper mapping of areas dedicated to the development of renewable energy projects, especially regarding to facilitating and speeding up permitting processes. It is also relevant to foster a smooth renewable energy (RE) integration in the power system, establishing streamlined permitting also for grid and storage infrastructure together with RE acceleration areas. For further details on our position, please refer to the document attached to this feedback.
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Meeting with Ditte Juul-Joergensen (Director-General Energy) and BUSINESSEUROPE and

22 Feb 2024 · Energy market

Meeting with Maroš Šefčovič (Executive Vice-President) and

22 Feb 2024 · Clean Transition Dialogue on Clean Technologies

Meeting with Stefano Grassi (Cabinet of Commissioner Kadri Simson)

23 Jan 2024 · Courtesy meeting, change of role

Meeting with Kadri Simson (Commissioner) and

17 Jan 2024 · Importance of networks in energy transition.

Enel Backs Equal Emission Rules for Renewable Hydrogen

20 Dec 2023
Topic — This consultation updates rules for distributing free carbon emission allowances.
Message — Enel supports removing factors that make free allowance calculations dependent on electricity or fuel. They also request applying these new rules starting from January 2024.12
Why — Renewable hydrogen projects will receive the same financial benefits as fossil-based production.3
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Meeting with Thierry Breton (Commissioner) and KIC InnoEnergy SE and

1 Dec 2023 · Réunion ministérielle de l’Alliance Solaire

Enel urges risk-based approach to EU soil monitoring rules

30 Oct 2023
Topic — The consultation concerns a new EU law for monitoring and restoring soil health.
Message — Enel requests more clarity on soil districts and who is responsible for measurements. They advocate for a risk-based assessment frequency and evidence-based contamination identification.123
Why — This would prevent duplicative regulations and reduce the frequency of costly soil inspections.45
Impact — Public interest groups might receive less information if fewer sites are investigated and registered.6
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Meeting with Nicola Danti (Member of the European Parliament) and Edison Spa

17 Oct 2023 · Scambio di vedute dossier in corso + NZIA

Meeting with Ditte Juul-Joergensen (Director-General Energy)

11 Oct 2023 · Energy Transition

Meeting with Dan Nica (Member of the European Parliament)

4 Oct 2023 · Energy Issues

Meeting with Kadri Simson (Commissioner) and

6 Sept 2023 · High level dinner before the ENSTO-E grids event – discussion on the challenges for European networks and electrification.

Enel demands better funding rules for European Hydrogen Valleys

4 Sept 2023
Topic — Strategic roadmap to double Hydrogen Valleys and reach renewable production targets.
Message — The organization requests a change to allow combining state aid with new funding initiatives. They also want immediate certification schemes and updated network rules to support industrial demand.123
Why — This would reduce financial risks for projects facing significant inflation and supply constraints.4
Impact — Some European regions may fall behind if funding is not distributed more equally.5
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Enel SpA urges longer transition for biomass reporting rules

22 Aug 2023
Topic — Updating rules for monitoring and reporting greenhouse gas emissions within the EU ETS.
Message — Enel requests new rules not apply to biomass purchased before the amendment. They argue the current transition period is too short for early adopters.12
Why — This avoids penalizing companies that used biomass early to reduce their carbon emissions.3
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Enel Backs Carbon Border Rules but Demands Higher Non-Compliance Fines

11 Jul 2023
Topic — New reporting obligations for the transitional period of the carbon border adjustment mechanism.
Message — Enel supports the proposed flexibility for reporting direct emissions during the initial transitional phase. They suggest increasing fines for missing or incorrect reports to two-thirds of the carbon price. They also propose a grace period for minor, unintentional errors to avoid unfair penalties.123
Why — Robust enforcement prevents market distortions and ensures the carbon mechanism protects EU industry.45
Impact — Non-compliant importers face significantly higher financial risks from the proposed increase in fines.67
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Meeting with Maria-Manuel Leitão-Marques (Member of the European Parliament, Rapporteur)

5 Jun 2023 · Forced Labour

Enel urges EU to make clean heating the standard

26 May 2023
Topic — This consultation addresses a new EU plan to accelerate heat pump deployment.
Message — Enel recommends removing tax exemptions for fossil fuels to encourage cleaner heating. They also call for streamlined permitting processes and financial incentives like reduced VAT.123
Why — Increased heat pump adoption would boost electricity demand and provide grid flexibility services.45
Impact — Fossil fuel industries lose market share as the EU moves away from boilers.67
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Meeting with Riccardo Maggi (Cabinet of Executive Vice-President Frans Timmermans) and ELECTRICITE DE FRANCE and

4 May 2023 · Presentation of new business group

Meeting with Kadri Simson (Commissioner) and

4 May 2023 · Importance of hydropower in ensuring electricity system flexibility; The application of the electricity market reform to hydropower; How to strengthen the visibility of hydropower as one of the key sources of renewable energy.

Meeting with Kurt Vandenberghe (Director-General Climate Action)

27 Apr 2023 · solar PV panels

Enel urges electrification to improve European air quality standards

14 Mar 2023
Topic — This consultation concerns the revision of EU standards for ambient air quality.
Message — Enel recommends accelerating the penetration of decarbonized electricity for transport and heating sectors. They also suggest reviewing monitoring station locations to reflect real population exposure more closely.12
Why — This shift would increase demand for Enel's renewable energy and charging infrastructure.3
Impact — Manufacturers of internal combustion engines and fossil fuel boilers would see reduced demand.4
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Response to Key performance indicators for the Digital Decade policy programme 2030

13 Mar 2023

The Enel Group, a multinational company and a leading operator in the power and renewables markets of Europe and worldwide, highly appreciates the opportunity to provide feedback on the proposed Key performance indicators (KPIs) to monitor the progress of the Union against the digital targets set out in the Digital Decade policy program. The Enel Group welcomes the Digital Decade Policy Program as a positive step towards a Europe fit for the digital age and sees some possibilities to complement the proposed KPIs summarised below: 1. One of the more relevant objectives mentioned in the Decision (EU) 2022/2481 related to Article 3 (c) on ensuring the Unions digital sovereignty by digital and data infrastructures capable of efficiently storing, transmitting, and processing vast volumes of data that enable other technological developments. The Enel Group calls on the EU Commission to introduce KPIs to realize this crucial objective for Europe to achieve digital sovereignty. It is already recognized in the EUs Data Strategy the occurrence of Imbalances in market power, and market imbalances in relation to access to and use of data, for example when it comes to access to data by smaller players. Even though the Commission put in place two excellent regulations to solve these imbalances (the Digital Services Package), the EU needs to reduce its technological dependencies in these strategic infrastructures, at the center of the data economy. Hence, further monitoring of EU efforts for creating an ecosystem that allows the scalability of smart services is needed. 2. Europes Digital Compass considered creating targets on sustainable city planning, and data centers/cloud infrastructures to become climate-neutral and energy efficient by 2030. The current environmental footprint of the ICT sector is estimated to be between 5 to 9% of the worlds total electricity use and more than 2% of all emissions, a large part of which is due to data centers, cloud services, and connectivity. The EU must consider establishing KPIs to ensure minimal energy waste and to promote green data storage techniques in data centers and cloud services to become climate-neutral and energy efficient by 2030.
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Meeting with Dan Nica (Member of the European Parliament)

7 Mar 2023 · energy issues

Meeting with Kadri Simson (Commissioner) and

7 Mar 2023 · Exchange on the needed regulatory support to promote the deployment and manufacturing of the solar power in the EU and the EU’s support for the solar energy so far.

Meeting with Maroš Šefčovič (Executive Vice-President) and

3 Mar 2023 · Energy supply

Meeting with Margrethe Vestager (Executive Vice-President) and

3 Mar 2023 · Green Deal Industrial Plan, State Aid Reform of the electricity market design

Meeting with Kadri Simson (Commissioner) and

3 Mar 2023 · Donation of solar panels to Ukraine.

Meeting with Barbara Glowacka (Cabinet of Commissioner Kadri Simson), Stefano Grassi (Cabinet of Commissioner Kadri Simson)

2 Mar 2023 · Prep call for announcement on solar PVs for Ukraine of 03/03/2023

Meeting with Nicola Danti (Member of the European Parliament)

15 Feb 2023 · Revisione del mercato elettrico dell'UE

Meeting with Patrizia Toia (Member of the European Parliament)

14 Feb 2023 · Energy Market Reform

Meeting with Stefano Grassi (Cabinet of Commissioner Kadri Simson)

13 Feb 2023 · Emergency delivery of energy supplies to Ukraine

Meeting with Ditte Juul-Joergensen (Director-General Energy) and Eni S.p.A.

7 Feb 2023 · Site visit to Biorefinery, Green Stream docks, IPCEI electrolyzer

Meeting with Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans) and WindEurope and

1 Feb 2023 · Renewable energy

Meeting with Filip Alexandru Negreanu Arboreanu (Cabinet of Commissioner Adina Vălean)

23 Jan 2023 · Presentation of the status of Enel electric charging infrastructure deployment among the highways in Italy and how the plans are going ahead.

Response to Creation of the Common European Mobility Data Space

7 Dec 2022

Unlocking the potential of mobility and transport data is essential to transition towards more sustainable and smarter transport system. Building a common European data space for mobility could enable better access to transport and mobility data, making use of existing and future data initiatives.(i.e. Gaia-X) Simplicity, trustworthiness, promoting EU standards, and the principles of interoperability and data portability are key elements. Moreover, Enel considers paramount underlining the need to establish a clear legal framework to boost data sharing and make data widely available. The lack of proper and coherent framework could cause confusion about responsibilities. Delineation and interplay between related pieces of legislation is crucial both for legal certainty as well as to build trust in more effective use of data. More clarity is needed on the interplay between the new initiatives and the existing horizontal legislation such as General Data Protection Regulation, vertical legislation for transport sector such as vehicle type-approval with regard to access to in-vehicle generated data or Intelligent transport system directive related to transport infrastructure. Furthermore Avoid possible overlaps and loopholes is paramount also in the light of new digital initiatives currently under development like the Data Act, cybersecurity legislation and to other European data space under development in particular but not limited to energy and public administration ones. Streamline data sharing and access. The new framework shall ensure fair and non-discriminatory access by all interested stakeholders (e.g. vehicle manufacturers, service providers and public authorities etc.) to data and the envisaged procedures and fee structures should be fair. For instance, the real-time access by charge point operators (CPOs), mobility service providers (EMSPs) to some specific in-vehicle-data as, for example, the Electric vehicle batterys state of health, state of charge, capacity, temperature, and power set point or the planned departure time of the consumer, is essential to enable smart charging and V2x services. It must be ensured that OEMs provide full transparency on technically available in-vehicle data, publishing or made available a catalogue/list of vehicle data, functions and resources accessible at request. At the same time, it is important also that the data's owner and all the relevant players in the value chain do not suffer economic disadvantages so fair remuneration/incentive schemes for data shared should be provided. Cybersecurity is paramount, furthermore the access to particular sets of data should only be granted where it is appropriate and relevant, subject to a test of a balance of interests of the relevant market players. It is fundamental to identify which are the highly sensitive data (even if non-personal) that shall be attached to the highest data protection rules, appropriately adapting the data before transferring it or avoiding the sharing of the most sensitive ones. Legislation needs also to recognize that access to data is not sufficient, but a successful exchange of data in a seamless, coordinated and timely manner based on existing and open standards is required in addition to adequate investment, skills, education and trust.
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Meeting with Gerassimos Thomas (Director-General Taxation and Customs Union)

5 Dec 2022 · General discussion about the tax environment of the energy sector in Europe

Meeting with Peter Van Kemseke (Cabinet of President Ursula von der Leyen), Valeria Miceli (Cabinet of President Ursula von der Leyen)

29 Nov 2022 · Upcoming revision of the Electricity Market Design

Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans), Riccardo Maggi (Cabinet of Executive Vice-President Frans Timmermans)

7 Nov 2022 · Energy crisis response, permitting electricity market reform

Meeting with Kadri Simson (Commissioner) and

26 Oct 2022 · Joint purchasing options.

Meeting with Sirpa Pietikäinen (Member of the European Parliament)

18 Oct 2022 · Sustainability-linked bonds, sustainable finance initiatives

Meeting with Pascal Canfin (Member of the European Parliament)

17 Oct 2022 · Green Deal

Meeting with Stefano Grassi (Cabinet of Commissioner Kadri Simson), Tatiana Marquez Uriarte (Cabinet of Commissioner Kadri Simson)

7 Oct 2022 · Funding Instruments to Speed Up Investments in the PV Supply Chain

Meeting with Gilles Boyer (Member of the European Parliament, Shadow rapporteur)

26 Sept 2022 · EUGB (staff)

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness) and ELECTRICITE DE FRANCE and

21 Sept 2022 · EMIR review, clearing threshold

Meeting with Antoine Colombani (Cabinet of Executive Vice-President Frans Timmermans) and ELECTRICITE DE FRANCE and

21 Sept 2022 · Energy derivatives markets

Meeting with Stefano Grassi (Cabinet of Commissioner Kadri Simson)

16 Sept 2022 · PV supply chain - winter outlook for electricity & gas markets

Meeting with Ditte Juul-Joergensen (Director-General Energy)

16 Sept 2022 · Emergency interventions in the electricity and gas markets; solar power supply chains.

Meeting with Frans Timmermans (Executive Vice-President) and WindEurope and

15 Sept 2022 · State of the wind energy industry and supply chain

Response to Requirements for access to electricity metering and consumption data

5 Sept 2022

Dear Members of the EU Commission, The Enel Group welcomes the draft Implementing Regulation and is grateful to have the possibility to provide comments through public consultation. Please, find enclosed the list of our proposals for amendments. At your disposal for any clarification, you may need. Almudena Diaz (on behalf of the Enel Group)
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Response to Review of EU rules on payment services

27 Jul 2022

How consumers pay for charging EVs is an essential element in their charging experience and ensuring availability of widely used payment methods will increase acceptability and accessibility of EVs. The proposal for an Alternative Fuel Infrastructure Regulation (AFIR) would require that all new publicly accessible recharging stations with power output equal or above 50 kW to accept electronic payments through terminals and devices used for payment services which should at a minimum include payment card readers. It also asks for all existing stations to be retrofitted with such card readers by 2025. The current draft report of the European Parliament TRAN Committee is even more ambitious, extending the obligations above to all publicly accessible recharging stations, regardless of their power output. However, it is our concern that these requirements are overestimating the positive impact for customers and underestimating the negative consequences on overall EV infrastructure and availability of charging, forcing a significant investment in new hardware and operational costs (which include additional acquiring costs due to the introduction of a new payment and collection channel, the management of a new billing process parallel to the traditional ones and financial management and reconciliation costs). This heavy burden would be done only to facilitate “ad-hoc charging” which accounts only about 5% of the charging sessions whilst the majority is done with mobility service provider contracts using an app, a charging card or automatic authentication. In addition, the use of debit and credit cards is steadily decreasing and most of these transactions are covered by other solutions such as web-based ones and QR codes. Moreover, the current PSD II requires the use of a card terminal with PIN authentication every fifth payment transaction or every time an amount over €50. If, according to the Strong Customer Authentication (SCA) requirement laid down in the PSD2, a secure PIN-pad is required to be installed on the charging station, this will have considerable cost consequences and effect the available installation space of this type of equipment in the field. The combination of the AFIR and PSDII requirements would make the entire installation of charging infrastructure considerably more expensive and leading inevitably to higher consumer prices for the EV driver, reducing the uptake of EVs and discouraging the roll out of publicly charging infrastructures. Therefore, we request an EU-wide solution to remove the PIN-pad obligation for the EV charging industry by exempting EV charging sessions from the Strong Customer Authentication (SCA) requirement in PSD II, putting into the same category as parking or riding public transport. Given that almost all the EV charging transaction amounts are small and quite nowhere near the €50-€150 thresholds and the importance for consumers to be able to complete these transactions, charging of EVs is comparable to those categories. This could be achieved through a clarification via the revision of PSD II that SCA for EV charging can be provided via several secure means of payment, excluding the use of a PIN-pad. In fact, new payment technologies, as smartphones/mobile payments with embedded SCA, implemented, for example, via fingerprint / Face-ID or similar, are spreading among the consumers. PIN entry is no longer required, neither for the amount limit, nor if the user exceeds the limit of five payment transactions. We believe that this option would benefit the consumer, by making payments convenient, safe, and accessible. In parallel, it would enable the accelerated roll-out of EV infrastructure as resources can be dedicated to creating more charging locations instead of retrofitting well-functioning hardware. Both the AFIR and the revised PSDII should be future proof, following the trends of the market and the future payment options which are rapidly becoming popular.
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Meeting with Ditte Juul-Joergensen (Director-General Energy)

8 Jul 2022 · Discussion about preparedness and electricity market design.

Enel Group urges flexible F-gas rules for energy transition

28 Jun 2022
Topic — The European Commission is revising rules to reduce greenhouse emissions from fluorinated gases.
Message — Enel requests raising climate-impact limits for electrical equipment and guaranteeing spare parts for existing machinery. They also suggest slowing gas phase-outs to support the massive deployment of heat pumps.123
Why — Enel would lower compliance costs and avoid relying on a limited number of technology suppliers.45
Impact — Environmental groups lose because the proposal allows gases with higher global warming potential.6
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Meeting with Koen Doens (Director-General Directorate-General for International Partnerships)

28 Jun 2022 · Energy transition, Latin America

Enel urges protection for business secrets in public data

21 Jun 2022
Topic — European Commission initiative regarding the availability of high-value datasets held by the public sector.
Message — Enel requests removing non-financial statements and management reports from shared datasets to protect business secrets. They propose uniform specifications for data publishing and suggest adding area emission saturation levels to environmental categories. The framework should align with the EU's common dataspaces.123
Why — Excluding certain reports protects proprietary business strategies from being accessed by competitors.4
Impact — Transparency groups lose the ability to easily access and compare corporate sustainability performance.5
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Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

16 Jun 2022 · ENEL would like to discuss their proposal for the reshoring of the solar photovoltaic sector in Europe

Meeting with Pilar Del Castillo Vera (Member of the European Parliament, Rapporteur) and Apple Inc. and

24 May 2022 · Data Act

Meeting with Ditte Juul-Joergensen (Director-General Energy)

20 May 2022 · Discussion on security of supply and electricity market design.

Response to A New European Innovation Agenda

10 May 2022

A whole spectrum of technology innovations and solutions will be needed in the next decade in order to grant a successful transition towards decarbonized energy system and to reach the European green deal goals. Against this background as Enel we welcome the initiative of European Commission for a new overarching innovation agenda that articulates all aspects in a way that allows efficient implementation and maximum impact on strategic objectives. In Enel Group Innovation is a key pillar to allow company to grow in a rapidly changing context while ensuring high safety standards, business continuity and operational efficiency, and thus enabling new uses of energy and new ways of managing it, making it accessible to an ever-larger number of people. Innovation is the bedrock and creates the conditions to be more sustainable, these two concepts that go hand in hand, and according to Enel view merge in the word “Innovability” to describe the degree to which one deeply permeates the other. Indeed sustainability will not develop without continuous innovation and for Enel innovation is meaningless unless it is oriented towards sustainability. Enel operates and strongly believes that an Open Innovability model is the key to support and empower the innovation development. A consensus-based ecosystem that makes it possible to connect companies with startups, industrial partners, small and medium-sized enterprises, research centers and universities through a variety of system, such as crowdsourcing platforms and Innovation Hub networks. Indeed Enel’s innovation strategy leverages the online crowdsourcing platform (openinnovability.com), a global network of 9 Innovation Hubs and 22 Labs which consolidates the new model of collaboration with startups and SMEs. The latter offer innovative solutions and new business models, and Enel makes its skills, testing facilities and a global network of partners available to support their development and possible scale-up. The Hubs manage relationships with all the players involved in innovation activities and are the main source of scouting for innovative startups and SMEs while the Labs allow startups to develop and test their solutions together with the company’s Business Lines. It is paramount to scale up innovation funding and that such funding programmes will be designed in a complementary, mutually reinforcing perspective exploiting synergies. Coordinating implementation timeframes, access rules, selection criteria would be essential to maximize participation and access to the different instruments and to first bridge the so-called valley of the death (the phase between research and successful innovation) and second to support full scale implementation. Furthermore provided that grants remain the most important form of support for high-risk investments such as innovation projects, other existing financial products can prove useful risk-sharing instruments.
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Meeting with Martin Hojsík (Member of the European Parliament)

3 May 2022 · Gas Market design

Meeting with Mauro Raffaele Petriccione (Director-General Climate Action)

28 Apr 2022 · EU Solar PV supply chain, renewable energy permitting and RePowerEU

Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans), Riccardo Maggi (Cabinet of Executive Vice-President Frans Timmermans)

25 Apr 2022 · Current situation on the electricity markets

Enel urges binding EU methane reduction targets

14 Apr 2022
Topic — The Commission is proposing a regulation to reduce methane emissions in the energy sector.
Message — Enel proposes setting an ad-hoc European target for methane emissions to ensure global compliance. They support immediate action on all components emitting 500 parts per million or more.12
Why — Efficiency-based tariffs and reduced leakages would increase operational efficiency and provide economic returns.34
Impact — Non-EU energy exporters will face higher costs to meet strict European technical standards.5
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Response to Revision of EU rules on Gas

12 Apr 2022

Enel welcomes the European Commission proposal on a Regulation and Directive on the internal markets for renewable and natural gases and hydrogen, as a necessary step to align the regulatory and policy framework of the gas sector to the 2030 and 2050 EU climate ambition. In Enel we believe that energy efficiency and further direct electrification of the demand - backed by investments in additional renewable power and in reinforced, resilient and digitalized electricity networks – are at the core of the decarbonization objectives and of a secure and affordable energy system, also due to the greater efficiency and maturity of the electricity technologies. Where this isn’t feasible or efficient, the use of other energy carriers such as renewable and decarbonized gases, in particular hydrogen, should be explored. These gases and derived fuels will be needed in the so called “harder to abate” sectors, i.e. certain industrial sectors or processes (chemicals, steel, cement, high temperature heat) and selected transport segments (long-range maritime and aviation, fossil fueled railways which cannot be economically electrified). With an Energy System Integration perspective, the focus of the Package should then be on addressing the changing role of gases in a decarbonized system rather than only on decarbonizing gases: the promotion of renewable gases should then be targeted to decarbonize selected current gas uses, not generally gas itself and this will require the design of competitive markets and the efficient use of infrastructures allowing the integration of renewable gases and renewable hydrogen. The gas regulatory framework should foremost: - be in line with the EU’s energy and climate objectives - enable a level-playing field between all different gases and between gases and other energy carriers (i.e. take full stock of the possibilities for substitutability as the basis for both the energy efficiency first principle and the energy system integration) In attachment, we provide detailed comments on the European Commission proposal, following the five main dimensions in which the package is organized.
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Meeting with Daniel Mes (Cabinet of Executive Vice-President Frans Timmermans) and Volkswagen Aktiengesellschaft and

7 Apr 2022 · Meeting with CEO Alliance on Digitising Energy Action Plan

Response to VAT in the Digital Age

1 Apr 2022

A paramount issue to Electric Vehicles charging pertains to the classification of the charging transaction for VAT purposes especially, but not limited to, public recharging point. The recharging activity entails a large number of services far beyond the mere supply of electricity (e.g. real-time communication of characteristics and availability of the charging station, possibility to reserve a recharging slot, occupancy of the associated parking space). Charging an electric vehicle is a unique and comprehensive service and the share of the cost of energy is only a part of the cost of the overall service. The charging of electric vehicles should be ideally defined as a service also for VAT directive purpose and European legislation on electric vehicles charging shall avoid leading to varying national implementation or interpretation. However, in some Member States, EV charging is considered a good, whereas in others it is considered a service and in others there is no clear official guideline at all. According to the guideline issued by VAT committee the emerging approach is to consider such activities as a supply of electricity (goods) from VAT point of view. A classification as goods implies a heavy administrative burden and considerable compliance costs for businesses when doing trade within the EU, such a duty for industry to register for VAT in all 27 Member States leading to a potential fragmentation of the European Single Market for EV charging and causing additional barriers slowing down the deployment of affordable electromobility services and potentially hampering the recharging experience of EV users in different Member States. In addition to the measures already foreseen in the “action plan for fair and simple taxation supporting the recovery strategy to amend the VAT Directive, the scope of the VAT One Stop Shop (OSS) should be widened to include the EV charging processes, regardless the qualification of these transactions as supply of goods or services, in order to partially lower some of these barriers in the longer term. However, the expected long timeframe required to revise the VAT directive and put in place such system poses serious threat and potentially can slow down the deployment of a full accessible and interoperable pan European recharging infrastructure. Against this background ready and directly applicable solutions should be envisaged to avoid lower the barriers such multi-registration and reporting duties in different Member States.
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Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

30 Mar 2022

Enel welcomes the EU Energy Performance of Buildings recast proposal, as part of the Fit for 55 package. Energy efficiency is one of the most cost-effective ways of addressing the EU’s strategic policy objectives of carbon neutrality by 2050, ensuring security of energy supply and enhancing competitiveness. Energy efficiency acquires even more importance within the context of the current energy crisis and the REPowerEU communication, as it is one of the key tools to reach independency from foreign gas importation. Decarbonization of the building sector is crucial to reach the EU climate ambition. The building sector also plays a key role in the reduction of emissions in the transport sector by providing the necessary charging infrastructure for e-vehicles and fostering e-mobility.The actual renovation rate and depth of the EU buildings stock is not sufficient to meet the energy consumption and GHG emissions reductions that are required to achieve the EU climate goals. The annual renovation rate of the building stock should more than double and go paired with an increased use of renewable energy and the smartening of buildings, which ultimately contribute to the efficient production and consumption of renewable energy, and the decarbonization of the transport sector.To scale up energy renovations in the EU building stock, it is crucial to remove the barriers that withhold building owners to invest and implement measures that trigger deep renovation. Energy renovations bring multiple social, environmental, and economic benefits, beyond energy performance improvement. Renovating the EU building stock at a 3,5% weighted energy renovation rate could yearly cost over 300 billion euros from 2035 onwards, but it would create significant short- term impacts on GDP growth and employment, resulting in a net beneficial outcome for the EU economy. Enel therefore welcomes the proposed recast of the EPBD, and particularly: • The shift from Long Term Renovation Strategies towards operational National Building Renovation Plans (NBRPs), which will ensure concrete targets, measurement and integration with other EU regulation, aiming at the decarbonization of building stocks. • The requirement for Member States to implement a national common scheme for building renovation passports which will be an effective tool to incentivize and monitor staged deep renovation, by providing the required information on the renovation roadmap of a building. • The increase in required EV charging structure as well as the withdrawal of existing barriers to the installation of private charging points which will be critical to respond to the projected EV charging demand by 2030. Nevertheless, a clear definition of pre-cabling is needed to effectively guaranty the possibility to install a charging point when needed. Furthermore, the Directive should include provisions for the charging of heavy-duty vehicles and cover new or renovated private truck depots, as well as logistic hubs and distribution centers, requiring them to be ready for battery electric truck charging. Finally, the definition of “zero-emission buildings” should explicitly allow for these buildings to cover their low residual energy requirements from distributed sources of flexibility such as electric vehicles.• The mandatory implementation of smart readiness indicators for large non-residential buildings with a high energy demand as an initial step towards the smartening of all buildings. • Mandatory Minimum Energy Performance Standards (MEPSs) which are considered essential to step up the energy renovation rate of national building stocks- especially for the worst performing buildings- and to reach the decarbonization of the EU building stock. • New provisions regarding the content, quality and issuance of energy performance certificates (EPCs) and the creation of national databases that will improve monitoring and stock taking of the buildings’ energy performance and decarbonization.
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Meeting with Mauro Raffaele Petriccione (Director-General Climate Action)

30 Mar 2022 · Energy prices and RePowerEU

Meeting with Caroline Boeshertz (Cabinet of Executive Vice-President Valdis Dombrovskis)

22 Mar 2022 · EU energy markets - gas price regulation; gas price cap

Meeting with Stefano Grassi (Cabinet of Commissioner Kadri Simson), Tatiana Marquez Uriarte (Cabinet of Commissioner Kadri Simson)

22 Mar 2022 · Discussion on energy prices

Meeting with Pascal Canfin (Member of the European Parliament)

17 Mar 2022 · Energy

Response to Soil Health Law – protecting, sustainably managing and restoring EU soils

16 Mar 2022

Land take and soil degradation are a serious problem in Europe and require urgent action. A harmonized regulatory framework at EU level for soil protection is therefore paramount to reach no net land take by 2050 and land degradation neutrality by 2030, as stated in the EU Biodiversity Strategy for 2030. Enel sees with perplexity that the EU 2030 Soil Strategy mainly focuses on soil protection and management related to agricultural activities and urbanization, without a more holistic approach to land use by other sectors, such as industry. A new Soil Health Law should instead provide for a broader scope, including all type of land uses that might impact soil quality as well as its ecosystem services and interactions with other environmental aspects such as water and air. The Law should explicitly address all anthropogenic activities and clearly define the sectors covered by its provisions. To be effective and ensure a coherent regulatory framework, Enel believes that the new Soil Health Law should consider the following recommendations: - Land degradation neutrality should be clearly defined upon soil threatening factors, in function of the desired land use. Beyond chemical, biological and physical conditions, soil quality needs to be defined with respect to the desired use of land. It is important to establish conceptual linkages between soil quality indicators and soil threats, taking in consideration the potential for remediation and desired use of land. - Regarding the definition of soil health indicators and the characterization, risk assessment and remediation of soil pollution, homogenous criteria should be set up at EU level, including thresholds for certain pollutants. EU standardized criteria and a uniform methodological approach towards characterization and remediation of soils would enable the implementation of a EU soil quality certification, which beyond transactional purposes could facilitate fast track permitting for circular uses of land, such as the repurposing and re-use of brownfields. A EU soil quality certificate could foster investments in brownfields, by addressing critical issues such as the risk and liability for soil contamination, defining the corresponding liabilities and remediation requirements for both the seller as the buyer. - In the same line, the creation of a soil quality passport for excavated soil, based upon the established soil health indicators, might bring a valuable tool to stimulate the re-use of soil and avoid the application of the waste directive. Overall, such a passport would enable the implementation of circular economy principles, by creating a tracking system that at the time would simplify the management of excavated soil. - A definition of sustainable and circular land management is desirable, considering the different potential uses of land. Sustainable land management envisages a broader and more holistic scope than soil use and would open the possibility for new, optimized land uses and new business models that incentivize the coexistence of different activities that create mutual synergies and benefits. - To effectively implement the land take hierarchy, the definition of land take should consider suitable criteria and metrics, including the quality of land, the level of possible remediation and the desired land use. The land take hierarchy should: •Prioritize practices that avoid additional land take such as multipurpose land use •Foster the re-use of land, through the repurposing of decommissioned industrial sites, creating the adequate economic incentives, and simplifying permitting procedures for land recovery and re-purposing;.•Ensure minimization of additional land take through simplified permitting procedures and financial support for the use of degraded land. - To achieve the desired outcomes on land take, remediation and sustainable land use, it is crucial to provide for the right incentives and simplified permitting procedures.
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Response to Waste Framework review to reduce waste and the environmental impact of waste management

22 Feb 2022

A circular approach to waste is crucial to reach an absolute decoupling of waste generation and resource depletion from EU economic growth. Overall waste generation has increased the last decade and only limited decoupling has been achieved. Member States seem not to be on track to meet their 2025 EU targets on the preparation for re-use and recycling, especially for municipal waste. The Zero Pollution Action Plan sets an ambitious target for 2030 to reduce significantly total waste generation and by 50% municipal waste. With the current levels of waste prevention and recovery, those targets risk not to be achieved. Waste prevention and circular waste management offer multiple environmental, social and economic benefits. Besides safeguarding human health and the environment, waste recovery, re-use and recycling reduce the need for primary raw materials, avoiding the environmental impacts of extraction and the economic dependency from non - EU raw material supply chains. Such activities also might bring a positive effect on job creation, provided that the necessary skills are being build. Nevertheless, to be successful, the right framework must be set to develop an EU market for secondary raw materials and/or end – of -life products. Upcoming waste streams from industries such as renewables might pose significant challenges and opportunities. The lack of specific provisions on the end-of-life treatment for renewable energy assets in the existing EU waste regulation not only poses a challenge, but moreover hampers the opportunity to develop a secondary market which could bring significant economic value creation, secure raw material supply within a circular economy framework and yield employment opportunities. Evidence shows that the existing waste regulation is not delivering the desired outcome and targeted actions need to be taken. Such actions include: • Waste should be redefined with a view to ensuring greater consistency with a circular economy approach. The definition of waste should be updated within the current context, considering evolving technologies and processes that enable a circular management of end-of-life products and materials. Under certain conditions, materials with the potential to be reused or recycled should be given the possibility to be directly and explicitly excluded from the definition of waste. Such conditions have to be laid out within the regulatory framework and could include for instance the issuance of a certificate for recyclable/ re-usable materials. Furthermore, there is a need to improve both the regulatory aspects as well as the implementation at operational level. • The WFD should consider upcoming streams of waste and accordingly lay out more specific end-of-waste criteria. This is the case for end-of-life renewable assets which pose a significant challenge in the coming years. Re-use and recycling of end-of-life renewables can offer significant opportunities to create new markets for secondary raw material and second-life products. • The WFD should ensure a more harmonized implementation at EU level by providing additional guidance on waste management activities and the responsibilities of the different actors within the process. This would create a level playing field for Member States and the development of a proper EU market for secondary raw materials and/or the re-use of end-of-life products.
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Meeting with Kadri Simson (Commissioner) and

27 Jan 2022 · The CEOs of the leading wind energy companies presented the key barriers to renewable energy project permitting they had experienced, and suggest some possible good practices for the upcoming Commission guidance on this topic.

Meeting with Nicolas Schmit (Commissioner) and

27 Jan 2022 · Green transition and changes in the labour market, in particular reskilling and upskilling.

Meeting with Helena Dalli (Commissioner) and

26 Jan 2022 · Discussion on ENEL's work towards fostering an inclusive and diverse work place. ENEL was included in the three main indices that monitor company performance on gender diversity.

Response to Revision of the Energy Tax Directive

18 Nov 2021

The Enel Group strongly welcomes the proposed review of the Energy Taxation Directive. Such review has been long due. There is an increasingly urgent need to align EU energy taxation with enhanced climate and environmental objectives and take into account current and projected energy technologies’ development. Energy Taxation is a key element in providing price signals able to effectively complement energy and climate policies, thereby supporting the clean energy transition and contributing to a prosperous and carbon-neutral economy The ETD review’s emphasis on correcting the misalignments with EU climate and energy objectives is particularly appreciated. The proposed new basis and structure for minimum tax rates promises to be effective. The principle of harmonizing application across Member States through ensuring that relative ranking is maintained appears pragmatic although the environmental performance clause calls for clarification. Enel strongly welcomes the proposal’s effort to review and rationalise product specific exemptions, although proposed measures need further enhancement. It is indeed critical to align the incentive system set out by the EU tax framework with the evolving energy mix of a European Union on a net-zero decarbonisation path. The proposed measures go in the right direction, but in some case the need strengthening: • The special treatment and exemptions foreseen for green hydrogen are indeed welcomed as effective measures to promote decarbonization in hard to abate sectors. • The proposed measures to remove both direct and indirect tax exemptions to fossil fuels should be strengthened. The proposed special treatment of certain aspects of transport lagging behind on the path to full decarbonisation goes in the right direction but in some cases also requires strengthening. While the power sector is well on track to net-zero before 2050, transport is clearly lagging behind and offers important opportunities for rapid emission reductions. The proposal set forth within the Review of the Energy Taxation Directive is seen positively, but more should be done, more specifically: • The special treatment and exemptions foreseen for use of shore-side electricity are indeed welcomed as effectives measures to promote decarbonization of a very hard to abate sector. However, they should be further strengthened. • Despite acknowledging the need for specific treatment for electricity used for EV charging, the proposed measures appear be weak. Enel particularly appreciates the proposal’s efforts to rationalize the use of tax revenues while ensuring a sustainable tax income regime for governments. Within the European Green Deal context, it is also crucial for tax revenues to promote the development and penetration of technologies that are key for Europe’s Energy transition.
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Response to Carbon Border Adjustment Mechanism

18 Nov 2021

The Enel Group fully welcomes the Proposed Carbon Border Adjustment Mechanism (CBAM) as a mean to strengthen the EU’s carbon leakage management system and therefore safeguard the competitiveness of EU’s industry. The form of a ‘Notional ETS’ without a cap, whereby importers of covered products have to surrender CBAM certificates equal to the embedded emissions in their imports, appears pragmatic and an effective way forward. We furthermore strongly welcome the inclusion of the power sector in the scope of the CBAM. Although carbon leakage impacts in the power sector compared to other sectors may be less significant on an EU wide basis, on a regional basis they could severely undermine decarbonization of some of the EU border areas. Furthermore, given its characteristics, the European Power Sector is very well positioned to promptly become part of a CBA. To ensure a smooth CBAM implementation, it is vital for the EU to engage in a full and transparent dialogue with its trading partners in the run-up to the adoption of the regulation. Enel assesses positively the proposed ten-year transition for the carbon leakage management regime with the CBAM gradually replacing existing free allocation of EU ETS allowances. Enel assesses also positively and as very pragmatic the absence of export rebates in the CBAM Regulation, but complementary measures will need to be mobilized to address the issue of exports. The CBAM’s proposed pragmatic approach to calculating the carbon content of imported goods is particularly appreciated. Enel strongly believes a reasonable approach has been adopted vis-à-vis the level of embedded product emissions declaration, especially in terms of the foreseen verification activities by accredited entities and the differentiated approach between electricity and other products. Taking into account the existence of a carbon price in the country of origin by discounting the compliance obligation, the proposal appears to take an effective approach to recognizing but also encouraging climate action among the EU’s trading partners. CBAM revenues should be earmarked for supporting the decarbonization of the activities falling within the scope of the regulation. Enel calls for the inclusion of hydrogen in the EU Carbon Border Adjustment Mechanism to avoid fossil based and highly emitting hydrogen imports
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Response to Review of Directive 2012/27/EU on energy efficiency

18 Nov 2021

Enel welcomes the EU Energy Efficiency Directive’s “Fit for 55” recast proposal. The proposed increase of the EU target to reduce energy consumption by at least 9% by 2030 compared to the projections of the 2020 Reference Scenario baseline seems appropriate to reach the 55% GHG emissions reduction target by 2030. The proposal of a harmonized formula to calculate Member States’ national contributions, as well as the additional delivery gap mechanism are seen positively. We see with perplexity a raise in the energy savings obligations under article 8, as the existing set up may lead to the amplification of market distortions in the EU. Such distortions already exist since the Directive doesn’t foresee any mechanism to ensure that Member States implement a balanced mix of measures to fulfill their energy savings obligations under Article 8. Some countries exclusively implement Energy Savings Obligation Schemes, others a mix of ESO schemes and alternative measures or only alternative measures. This leads to a disproportional burden on obligated parties in those countries where only ESO schemes have been set in place. A raise of the ESO would further distort the market, increasing even more the costs for energy operators and eventually for end consumers. A 1,5% annual energy savings obligation, from 2024 onwards, implies that only energy savings obligations would account for approximately 80% versus a former 50% of the additional savings contributing to the achievement of the increased EU 2030 target. New and more stringent mandatory requirements in other pieces of legislation will limit the accountability of new “additional” measures under article 8, and thus hamper significantly the achievement of a more ambitious energy savings obligation target. On the other hand, the eventual inclusion of the building and road transport sector under the ETS should provide for additional resources for energy efficiency projects. Therefore, we propose an increase of the article 8 ambition of 1,3% instead of 1,5%. Further, to avoid market distortions in those Member States that implement Energy Savings Obligation schemes, a cap should be introduced to ensure that no disproportioned burden is being put on obligated parties. On the other hand, the requirement to target part of the energy savings to people affected by energy poverty, vulnerable customers and, where applicable, people living in social housing is highly welcomed as it might play an important part in countering energy poverty and in ensuring a just transition. Finally, Enel supports the proposal to exclude the crediting of energy savings from policy measures regarding the use of direct fossil fuel combustion technologies from 2024 and even earlier on. Such exclusion is fully aligned with the gradual phase out of fossil fuels and the overall decarbonization target as set in the Green Deal. Enel welcomes the reinforcement of the role of public entities in achieving higher energy efficiency targets, as not only they set an example for the general public and other sectors, moreover they are a significant energy consumer. More specifically the requirement to renovate 3% of the total floor area of heated and/or cooled buildings owned by all public entities is crucial to reach the overall energy efficiency targets, The Member States’ obligation to ensure that transmission and distribution system operators do not invest in stranded assets to contribute to climate change mitigation is seen as positive. Enel supports the proposed requirement for Member States to provide and disseminate information on available energy efficiency improvement measures and to create access to legal and financial advice to all market actors through one stop shops. Finally, the availability of qualification, accreditation, and certification schemes to ensure the appropriate level of competences for energy efficiency professionals is crucial to overcome the lack of expertise and qualification.
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Response to Revision of Alternative Fuels Infrastructure Directive

17 Nov 2021

The ‘Fit for 55’ package paves the way for the implementation of the EU Green Deal, this set of legislative revisions represents a unique opportunity for Europe to take a step forward and win the climate race. That is why now it is the time to show steadfast commitment and prioritize the most efficient, sustainable and cost-effective pathways to decarbonize the economy. In this scenario, the EU Green Deal success story can only be achieved by enacting a clear commitment towards truly sustainable solutions. Through the ‘Fit for 55’ package, the EU has a tremendous opportunity to have a prominent role in the energy transition for truly green solutions perfectly fits with the engineering skillsets embedded in the great corporate successes of Europe in industries such as manufacturing, automotive, power generation and construction. Enel recognizes and welcomes the ‘Fit for 55’ package and the fact that an ambitious proposal for concrete steps forward to foster a further shift toward zero emission electric vehicles and thus decarbonize the transport sector, have been made by the European Commission in the proposal of Alternative fuel infrastructure revision. Enel welcomes and supports the introduction of Member states mandatory targets for recharging infrastructure for electric vehicles and revision the scope to include binding target for shore-side electricity supply (OPS) and airport supply of electricity infrastructure deployment However, some adjustments to the proposal are deemed necessary to reinforce the regulation and enable the EU to meet its long-term GHG emission reduction targets, effectively promote the transition towards a clean and zero emission transport sector: -The revision of AFI should mandate infrastructure targets only for zero emission transport modes to reach the 2050 climate neutrality goal. In particular, zero emission electric mobility is key to achieve the European decarbonization goals. -Due to the incipient phase of hydrogen-based solutions the deployment of any widespread hydrogen refueling infrastructure should be carefully further assessed to avoid investment in infrastructure for solutions with a large risk to fail to deliver. Hence, the revision of Alternative fuel infrastructure should avoid imposing binding targets on such solution or at very least adjust the ambition of the hydrogen infrastructure deployment targets. -Ensure the deployment of sufficient publicly accessible charger capacity to cope with the electric vehicles recharging needs by revising upward the power output from 1 KW per BEV to 1,5-1,9 KW per BEV until the end of 2025 and bring forward the minimum publicly accessible recharging points deployment target for TEN-T Comprehensive network. -Support the deployment of electric Heavy-duty vehicles and extend the applicability of the target sat for HDV “safe and secure parking area” to all lorry parking sites and revise upward the target ambition for 2025 (each overnight parking area shall offer a power output of at least 200 kW) and 2030 (each overnight parking area shall offer a power output of at least 400 kW) to cope the needs of public night charging of HDV. -Reinforce the principle of charging activity as provision of services and for all the charging points publicly accessible and not and for shore-side electricity supply (OPS) as well -Ensure openness to all methods and technologies in respect to payment systems for ad hoc charging without limiting the use of widely supported digital means and imposing retroactively requirements on existing charging infrastructure. -Ensure that smart recharging ready charger become be the minimum requirement for all the newly installed charging points, independently from the charging point output power, but avoiding retroactively requirements on existing charging infrastructure
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Response to Updating the EU Emissions Trading System

8 Nov 2021

Please, find below a synthesis of Enel’s view on EU ETS revision proposal. For further details, please see the attached document. Enel welcomes the EU ETS Directive’s “Fit for 55” proposal of reform as it fits with the increased EU climate ambition and will help provide stable and predictable carbon price signals. The scope expansion of the existing EU ETS to the maritime sector will positively increase the system’s overall ambition. The inclusion of maritime in the EU ETS will strengthen the system and contribute to decarbonizing the shipping sector. Particularly welcomed is the scope expansion in the area of hydrogen production activities as it will support market penetration of hydrogen produced via electrolyzers and increasingly zero emission electricity. However, the proposed 25 tons/day threshold should be changed to 1000-1500 tons/year. Producing 25 tons of hydrogen per day requires electrolyzers with at least 100 MW capacity, while current state-of-the-art facilities have a capacity of 20 MW. Moreover, a daily threshold seems not appropriate for green hydrogen produced through V-RES such as wind and sun. All that being considered, Enel proposes an annual threshold of 1000-1500 tons/year. The effort required from EU ETS sectors is seen positively, but a greater emphasis should be placed on just transition measures and greater support of the ETS sectors’ decarbonization through EU ETS auction revenues. Enel believes the amended Article 10 should be even further reinforced with measures steering investments towards ensuring a just transition and supporting decarbonization of EU ETS sectors. The proposed combination of adopting as soon as possible a higher LRF and rebasing promises to be an effective way of increasing EU ETS ambition while guaranteeing regulatory transparency. This provision will remove the risk of arbitrariness over the one-off reduction amount, guaranteeing the regulatory predictability needed to achieve a strong carbon price signal. The revision of the MSR parameters is assessed positively, guaranteeing that the system remains “fit for purpose” and able to react against external market shocks. The new absorption rules will allow the containment of the surplus of allowances while contributing to maintain price stability and predictability. The new buffer intake range will contribute to reduce price volatility by stabilizing the surplus and avoiding potential threshold effects. Maintaining the MSR activation thresholds of 400 and 833 MtCO2e appears to be consistent with the MSR's revised absorption rules, the expected hedging trend and the scope extension of the EU ETS. The inclusion of both maritime and aviation sectors into the allowances’ surplus (TNAC) computation is also welcome. Enel welcomes the creation of a separate system for road transport and buildings, but the decarbonization of these sectors should be supported with complementary measures which could also help address the potential social impacts associated with high carbon prices. Moreover, measures such as the DAFI directive, the CO2 standards for cars and the EPBD should continue to be essential tools to drive the decarbonization of these specific sectors. The safeguard mechanism of the transport and building MSR is welcome and will prevent socially unacceptable price spikes, but the Social Climate Fund should be the main policy tool to guarantee a just transition. The potential social impact of high carbon price applied on road transport and building sectors requires adequate funding and a proper implementation by MSs of the new Social Climate Fund, especially considering that the safeguard mechanism of the new dedicated MSR will be triggered by rapid price spikes but not by gradual increase of prices above socially acceptable levels.
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Response to Updating Member State emissions reduction targets (Effort Sharing Regulation) in line with the 2030 climate target plan

8 Nov 2021

Enel warmly welcomes the Commission’s proposal amending the EU Effort Sharing Regulation included in the “Fit for 55” Package. The Effort Sharing Regulation (ESR) is a key piece of legislation within the EU energy and climate framework, given that it addresses GHG emissions reduction in sectors that are not covered by any other overarching instrument at EU level. Such sectors -including transport, buildings and many industrial processes- are currently lagging behind in the decarbonization process if compared to sectors covered by the EU Emissions Trading Scheme. The proposed increase of the EU target to reduce GHG emissions in ESR sectors by at least 40% by 2030 compared to 2005 levels seems adequate to reach the 55% GHG emissions reduction target by 2030, although a higher reduction in non-ETS sectors could better reflect environmental benefits not accounted in GHG-related costs and provide a fairer effort sharing among ETS and ESR. Without such additional significant ambition increase, the European Union would simply not reach its 2030 binding GHG reduction target. The target increase to 40% (vs previous 30%) will accelerate the energy transition in ESR sectors such as transport and buildings that are struggling to unlock their decarbonization potential. Nevertheless, Enel advocates for a deviation from the cost-efficiency criteria acknowledged in the Commission’s related impact assessment, as decarbonization of ESR sectors brings about environmental benefits not accounted in GHG-related costs. The burden sharing should balance cost efficiency and at the same time favor a fair allocation of efforts, hence limiting the burden for the sectors present in the current ETS. The contribution of non-ETS sectors could be increased to 43% as evidenced in the ‘Sustainable Paths for EU Increased Energy and Climate Ambition’ study by Compass Lexecon – Enerdata – Enel Foundation. Enel fully endorses the proposal to maintain the same basic sectoral coverage in the Effort Sharing regulation as before, therefore making the scope of the ESR entirely compatible with the creation of a separate ETS for road transport and buildings without undermining the governance of EU GHG targets and underestimating non-economic barriers. In fragmented sectors like transport and building, price signals are not sufficient to overcome non-economic barriers, which often hamper the adoption of non-emitting technologies. The proposal correctly recognizes that a carbon price on its own would not deliver the required transformation in the sectors concerned in an efficient manner. Therefore, it would be premature to leave the aimed decrease in emissions from buildings and road transport exclusively to emission trading. Maintaining road transport and buildings in the ESR obligation reinforces the policy framework for accelerating decarbonization and electrification of end uses. The risk of weakening national policies due to excluding those sectors of the ESR binding union’s and national targets is by these means avoided. Enel supports the proposal to upgrade Member States’ 2030 binding reduction targets in sectors covered by the ESR based on the current per-capita GDP methodology, so as to necessarily align them with the EU-wide reduction of 40%, with any eventual further adjustment needed. The introduction of new flexibilities - such as access to LULUCF credits and voluntary additional reserve formed by unused LULUCF credits - is not of particular concern as long they have a clear limiting cap and they do not endanger the overall GHG ambition. The Commission’s proposal is a missed opportunity to explore how EU-level and MS-level ESR targets could be properly cascaded into sub-sectorial targets. Sectoral targets would provide for a stronger policy driver to sectors like transport and buildings, which are lagging behind in the decarbonization process. Please find additional details in the paper attached.
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Meeting with Adina-Ioana Vălean (Commissioner) and

27 Oct 2021 · Automobiles

Response to Action plan on the digitalisation of the energy sector

10 Sept 2021

Dear Members of the European Commission, Enel SpA, an international power company, highly appreciates the possibility to provide feedback on the EC roadmap consultation for the Digitalisation of Energy Action Plan, and recognises the enabling role of digital technologies for the green transition. Please find the response of the Enel Group as a document enclosed. I remain available for any clarification or further contribution you may require.
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Response to Data Act (including the review of the Directive 96/9/EC on the legal protection of databases)

25 Jun 2021

Dear Members of DG CNECT G.1, Enel SpA, a multinational company in the energy sector, highly appreciates the EC proposal for a regulation aimed to create fairness in the data economy by addressing the difficulties of access to and use of data. Enel especially welcomes the willingness to establish more competitive markets for cloud computing services. Fair and harmonized conditions, will encourage consumers to make greater use of cloud computing services, enhancing portability, and will allow SMEs to develop new content and services. In Enel's views, declarations of adherence to a SWIPO Code of Conduct for IaaS and/or SaaS services encompassing Article 6 of the Free Flow of Non-Personal Data Regulation, such as eight cloud services providers already performed, successfully encourages transparency when switching provider and porting data. Concerning data management and reuse for research data, Enel advices to build on the FAIR data principles, which stipulate that such data should in principle be findable, accessible, interoperable, and re-usable. Moreover, public-sector data is not usually findable in machine-readable formats; hence Enel encourages the Commission to coordinate the facilitation of sharing non-sensitive public sector-generated datasets, in machine-readable formats, providing guidance on common schemes for voluntary sharing data in accordance with EU legislation requirements; Related to the energy sector, specific legislation on data access is in place (e.g. unbundling) and specifically in preparation, as mandated by the recast Electricity D., which required countries to adopt “Implementing Acts on interoperability and data access” in fields such as consumption and production, demand response, switching and other services. Therefore, we recall the Commission to take into consideration that for the energy sector, the sectorial legislation on data access and use, is already developed and sufficient. In addition to sectoral legislation, the Enel Group also considers relevant to highlight that in the Commission proposal for a Data Governance Act, data sharing remained a choice and Enel considers that sharing privately-held data should remain voluntary. To incentivize data sharing among companies, fair compensation guidelines, best practices, and tax incentives could be built to also enhance predictability and trustworthiness. To avoid unfair competition, compulsory data sharing schemes shall be avoided and specified case by case, and based on clear rules. In this regard, studies commissioned by the EU institutions in which the macroeconomic benefits of data sharing are disclosed might further increase knowledge and trust in data sharing. Moreover, the development of national governance structures for data-sharing applicable both to public and private organizations shall be based on general EU guidelines, ensuring a minimum harmonization degree for data sharing. In addition, national criteria and rules for data sharing shall consider criteria for data sharing at the sectoral level, homogenizing the legal framework.
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Meeting with Stefano Grassi (Cabinet of Commissioner Kadri Simson), Tatiana Marquez Uriarte (Cabinet of Commissioner Kadri Simson), Thor-Sten Vertmann (Cabinet of Commissioner Kadri Simson)

23 Jun 2021 · ENEL expectations regarding Commission proposals in the fit for 55 package, in particular as regards the revision of the Renewable and Energy Efficiency Directives.

Meeting with Mauro Raffaele Petriccione (Director-General Climate Action)

22 Jun 2021 · RES & ETS

Meeting with Aliénor Margerit (Cabinet of Commissioner Paolo Gentiloni)

27 May 2021 · CBAM + ETD

Meeting with Nicolas Schmit (Commissioner) and

11 May 2021 · Pact for Skills roundtable with the renewable energies ecosystem sector.

Meeting with Thierry Breton (Commissioner) and Eurelectric aisbl and

11 May 2021 · Pact for Skills roundtable with the renewable energies ecosystem sector

Meeting with Henrik Hololei (Director-General Mobility and Transport)

15 Apr 2021 · European Green Deal

Response to Enhancement of European policy on critical infrastructure protection

7 Apr 2021

Dear Members of European Commission - DG Home affairs, Please find attached Enel Group answer (2 pages document). Kind regards.
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Response to Modification of the General Block Exemption Regulation for the Green Deal and the Industrial and Digital Strategies

2 Apr 2021

We, as Enel Group, would like to highlight the following improvements on GBER: Increasing aid exemption notification thresholds and avoiding geographical limits - increasing the general exemption notification threshold related to State aid for environmental protection, currently set at € 15 million per undertaking per investment project - increasing the specific threshold (Article 4) applied to the different types of investment and operating aid related to Section 7 of the GBER - setting higher notification thresholds for assessing large aid schemes (i.e. operating and investment aid for RES also coupled with storage) granted on competitive bidding process basis, currently up to €150 million per year and increasing the limit of the combined budget of all schemes falling under the related provision (i.e. Art. 42 GBER) in the MS concerned - removing unnecessary geographic limitations to the financing measures i.e. electricity grids or EV re-charging infrastructures, currently possible only in assisted areas. -Broadening the aid categories covered by the block exemptions. Overcoming the current rather rigid structure based on technologies which makes rather difficult to introduce new and broader aid measures, opening to new technologies or designing incentive schemes towards a broader objectives approach -Investment aid vs operating aid – Renewables energy sources. As to renewables, although MS tend to use operating aid, in particular price support schemes (eg. Feed in tariffs and feed-in premiums) for RES development, as operating aid is linked to the funding gap of the project and covers investment costs, it shares features of investment aid and is therefore comparable to it. Thus, concepts of investment aid and operating aid including cost structure (CAPEX, variable OPEX, fixed OPEX) should be further clarified and aligned with EEAG definitions. -The framework for hybrid plants, namely new and existing plants coupled with storage, should be improved and should be clarified that it fits under the GBER, particularly to ensure an efficient and sustainable implementation of the Recovery and Resilience Facility. -Green hydrogen produced by electrolysis through renewable electricity could be the potential missing link in the transition to the decarbonization. Its potential is not negligible despite the economics still represents a huge limitation for large scale production and use. It is paramount to streamline only aid for the development of green hydrogen production to make its costs competitive to buyers in comparison with other types (blue and gray) of hydrogen. -Electricity distribution grids. The upgrading and digitalization of the electricity system to make it ready to include distributed flexibility services, to connect new massive RES generation, to improve the resilience of the grid and in general to boost the electrification of the economy are crucial. Public funding coupled with regulatory solutions to support and boost deploying effective DSOs plans for construction, replacement or upgrade the electricity grids are required. The new GBER should clearly state its inapplicability to electricity grid under legal or natural monopoly, since they do not involve state aid. -Storage. Support solutions for storage should be improved under the GBER and EEAG. The new framework shall be consistent with the Electricity Directive (n. 2019/944) provisions aimed at ensuring that ownership and operation of energy storage is awarded through tender procedures to market players and not to TSOs (unbundling principle). Wherever investment in storage is made by system operators as a last resort, this should be closely monitored in order not to foreclose opportunities for market players. -E-Mobility.Electric vehicles and electric recharging infrastructures. An appropriate public supporting framework under GBER to develop the electro-mobility and related re-charging infrastructures across Europe is crucial. -Aid intensities vs. Funding gap
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Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

22 Mar 2021

Enel warmly welcomes the Commission Inception Impact Assessment to review the Directive 2010/31/EU and amending Directive 2018/844/EU on Energy Performance of Buildings, as the “Energy Efficiency First” principle constitutes one of the main pillars of the EU’s fight against climate change and a successful and sustainable energy transition. Enel supports the Commission’s proposal of an increased EU decarbonization ambition by 2030 to reduce GHG emissions at least 50% and towards 55% compared to 1990 levels in a responsible way, and to reach climate neutrality in the EU by 2050. The EU should more than double the renovation rate of buildings by 2030 and foster deep renovation to achieve the EU higher climate ambition, which could bring at the time significant social, environmental and economic benefits. EU policies should target at reaching a deep energy renovation rate of at least 3% by 2025 to achieve the decarbonization of the buildings sector[1], exceeding thus by far the actual renovation rate of 1%, and avoid delayed action due to the current COVID-19. Deep renovations should go along with the phase-out of fossil fuel energy sourcing and lean on clean, electrified renewable technologies. In order to aggressively decarbonize the building sector, by 2050 its electrification must more than double to approximately 72%[2]. This can be done through efficient electric technologies in heating, where heat pumps are 4 to 5 times more efficient than their gas boiler equivalent. Energy efficiency measures can be implemented in ways to benefit low-income households by financing them via revenues coming from different sources. Shifting to electricity as the most efficient energy carrier plays an important role in reaching the energy efficiency targets thanks to the multiple benefits it brings, by means of technologies spanning across sectors. The Commission has to align the EPBD revision with the increased climate ambition for transport, considering the increasing EV stock, by providing the necessary deployment of charging infrastructure, both in residential as in non-residential buildings. The minimum charging infrastructure requirements set in the Article 8 of the directive should be reviewed and any barrier that could hamper its adoption, such as the limiting provisions in Article 8.6 should be removed. The Commission should explicitly ensure the “right to plug” principle and introduce specific requirements for charging points. Enel supports the phased introduction of mandatory minimum energy performance standards (MEPS) for different types and particularly for worst performing buildings. Enel supports the reinforcement of the smart readiness indicator for buildings in the EPBD revision, as it should foster the deployment of smart technologies, enabling the increase of the charging infrastructure for electric vehicles, on-site renewables and demand response. Policy enablers in driving building electrification are needed to ease efficient renovation of buildings and promote fuel switching, by pointing at: (1) targeted renovation objectives for the building stock, (2) updated building codes requiring electrification technologies and energy management systems to be present in new and renovated buildings, (3) simplification of administrative procedures for building renovation, (4) mandatory energy efficiency audits and inspection schemes linked to energy performance certificates and building renovation passports, (5) promotion of interoperability among assets, (6) tax reductions and deductions for building renovation, (7) funding schemes and innovative financing models for paying back the upfront investment, (8) training and enhancing skills to lower costs and increase quality work and, (9) removing undue taxes and levies from electricity tariffs and transfer them to general taxation, where necessary. Please find attached a paper with further details.
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Meeting with Hannah O'Kane (Cabinet of Commissioner Mairead Mcguinness)

22 Mar 2021 · sustainable finance

Response to Revision of the NIS Directive

18 Mar 2021

Dear Members of European Commission, DG CNECT Unit H.2; Enel SpA, a multinational company in the energy sector highly appreciates the EC prompt revision of the Directive on the security of network and information systems (EU) 2016/1148. Please find the Enel Group feedback in the attachment.
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Meeting with Frans Timmermans (Executive Vice-President) and Volkswagen Aktiengesellschaft and

18 Mar 2021 · European Green Deal as a growth strategy

Response to Revision of EU rules on Gas

9 Mar 2021

Enel strongly believes that the completion of the decarbonization of the power sector and the electrification of final uses, such as transport, heating and cooling and industry, along with energy efficiency, are the key levers to trigger for a clean and cost-efficient transition. These measures have the lowest CO2 abatement cost to tackle the largest part of emitting activities. Green electricity and electrification can deliver in many sectors, thanks to the readiness and cost competitiveness of technologies such as electric-vehicles for the road transport and heat pumps for buildings. Going further towards deep decarbonization, for the remaining final energy uses, the so-called “harder to abate” sectors such as certain industrial sectors or selected transport segments (maritime, aviation), the “new gases” and in particular green hydrogen will have a key role to play in their decarbonization. In the light of such goals, Enel welcomes the Commission proposal to review the gas legislative framework to design competitive decarbonized gas markets. Against this background, Enel suggests the following main recommendations. Please refer to the document attached for a more detailed response. -Classification of “new gases”. There is no common agreed definition for the different type of gases at EU‐level. As a fundamental step, a regulatory framework requires consistent and clear definitions and criteria to determine unambiguously the different type of decarbonized gases. As principle, gas classification should allow to evaluate the different categories of gas against the sustainability criteria and GHG reduction emissions criteria -Hydrogen infrastructure. In defining dedicated rules for a potential hydrogen infrastructure, the upcoming legislative proposal should take into specific consideration the current status and foreseeable developments of hydrogen production and demand patterns, taking into account the level of incertitude strictly linked to the incipient status of such technologies. -Blending of new gases into existing natural gas grid. When discussing options such as the blending of hydrogen into the existing natural gas grid, Enel believes that such option should be discarded in favor of other more efficient solutions, in view of using hydrogen in those sectors that can truly benefit most from its use (the harder to abate sectors). Blending should also be discarded as a way to kick-start a hydrogen market, that should instead rely on dedicated support measures for the production and use of green hydrogen in specific end-uses (the harder to abate sectors). -Classification of Power to gas facilities and hydrogen markets. Power-to-gas equipment converts electricity to gas which may be used for different purposes. In this context and as already recognized by regulators, the ownership and use of such installations are already and should be considered as market-based activities, which are open to competition among market players. -Tariffs for Power to gas. Power‐to‐gas assets could be subject to both electricity and gas regulation and network codes with different requirements. This could eventually lead to issues concerning differences between physical characteristics of the power and gas systems and respective applicable legislation. A harmonized network tariff system including such technologies should be developed to assure a common approach at EU level. Network tariffs should not be used to subsidize technologies, activities or users; any subsidization should be done with dedicated instruments outside the regulation of network access. -Network planning. Ensure that gas regulation schemes do not incentivize building more gas infrastructure if not necessary. Gas regulation should prevent unnecessary investments in gas infrastructures where possible if they do not comply with the goals towards a decarbonized system. A stronger oversight by ACER and NRAs will be necessary
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Meeting with Marco Piantini (Cabinet of Commissioner Paolo Gentiloni)

3 Mar 2021 · State of play and exchange of views on Recovery and Resilience Facility (RRF).

Response to Modernising the EU’s batteries legislation

1 Mar 2021

Dear Members of DG ENV. Unit B3 – Waste Management & Secondary Materials, Please find enclosed the response of Enel SpA.
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Meeting with Celine Gauer (Head of Task Force Secretariat-General) and Airbus and

18 Feb 2021 · RRF - cross border projects

Meeting with Diana Montero Melis (Cabinet of Commissioner Jutta Urpilainen)

12 Feb 2021 · Africa Europe Green Energy initiative. Ms Montero joined the meeting organized by CAB VdL - Valeria Miceli

Meeting with Valeria Miceli (Cabinet of President Ursula von der Leyen)

12 Feb 2021 · Africa Europe Green Energy Initiative

Meeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness)

8 Feb 2021 · Sustainability Linked Bonds

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis)

8 Feb 2021 · Sustainable finance

Meeting with Kadri Simson (Commissioner) and

27 Jan 2021 · Solar PV manufacturing in the EU. Revision of the Renewable Directive, Energy Efficiency, role of renewable and solar in the Climate Target Plan.

Meeting with Thierry Breton (Commissioner) and

27 Jan 2021 · Solar PV manufacturing in the EU

Response to Proposal for a legislative act on methane leakage in the energy sector

26 Jan 2021

Enel welcomes the Commission communication on an EU Methane Strategy and the further proceedings on a legislative proposal to reduce EU-related methane emissions from fossil fuels, as both acknowledge methane as a relevant contributor to GHG emissions. Methane emissions contribute with a relevant share (approx. 15%) to global GHG emissions. Methane losses in natural gas and oil upstream and midstream operations are a significant part of it, representing about a half of the methane anthropogenic emissions. Furthermore, methane has a notable impact on air quality issues, as precursor for tropospheric ozone. Structurally addressing EU direct and indirect methane emissions is a long awaited issue. Tackling methane emissions should become an ever increasing priority for the EU climate strategy. Methane losses along the gas value chain represent extra-GHG emissions of up to 30% according to most estimates. According to the Fifth Assessment Report 5 (AR5) of the Intergovernmental Panel on Climate Change, average methane losses in the gas value chain are 2-3% of the natural gas consumed. This represents up to additional 30% GHG emissions to the emissions derived from combustion. In 2015, the European Commission conducted a study on the field , concluding that average methane losses in the EU are 1.1%, being more than half of them related to the transport and distribution of the gas. Enel would like to emphasize that the new legislative proposal to reduce methane emissions in the oil, gas and coal sectors should tackle energy-related methane emissions from a structural point of view, taking into account the impact of direct and indirect methane emissions when planning new investments and assessing new energy and climate policies. The achievement of Member States and EU GHG reduction obligations can benefit from effective sectoral policies that reduce methane emissions in sectors involving gas and oil activities. New investments on infrastructures related to fossil fuels should be gradually replaced with investments with higher potential on GHG emission reduction, as well in terms of methane reduction. Related direct and indirect methane emissions shall become an additional criteria for EU taxonomy on climate and sustainable finance and awarding of EU funds. The likely underestimation of methane losses along the EU gas and oil value chains should be addressed, deepening in the root causes and updating the knowledge on the issue through reliable data and empiric experiences, so as to become a better guide for policy making. Estimates of methane emissions from losses in gas and oil operations are exposed to a high degree of uncertainty. Recent studies point out that methane losses along the gas value chain may be underestimated. The impact of methane emissions on climate change is highly sensitive to any variation. In this context, we welcome the Commission’s announcement to develop legislation on compulsory measurement, reporting, and verification (MRV) for all energy-related methane emissions. However, we would like to express concern over still insufficient reliable data at EU level. We consider necessary that in parallel the Commission carries independent comprehensive studies at EU level to determine the actual contribution of abnormal leakages and discharges to methane emissions. The upcoming legislative proposal should promote policies and best practices to prevent methane emissions related to oil and gas operations. Cost-efficient obligations to improve detection and repair (LDAR) of leaks on all fossil gas infrastructure, to eliminate routine venting and flaring in the energy sector covering the full supply chain and to introduce performance-based requirements to gradually replace emitting gear. The upcoming legislative proposal should take specific attention to the management of methane emissions from new sources of methane such as biomethane and synthetic gases. Please find attached a paper in support.
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Response to Revision of EU Ambient Air Quality legislation

14 Jan 2021

Air quality in Europe is still far from complying with European or international standards. Especially in urban areas, air quality limits in Europe are widely exceeded for the three main pollutants (particulate matter or PM, ozone and nitrogen oxides or NOx). The European Energy Agency (EEA) reports that in 2018 15% of the EU urban population was exposed to concentrations of PM10 above the EU threshold, 4% in the case of PM2.5, and 4% in the case of NO2. Such percentages increase substantially if the World Health Organization thresholds are considered (48% for PM10 and 74% for PM2.5). Air pollution comes at the expense of reduced health for European citizens, a deteriorated environment as well as high directly and indirectly related monetary costs.. A study of the OECD concludes that the reduction in air pollution is directly related to the GDP growth in Europe over the last decades and that the direct economic benefits of pollution control largely outweigh abatement costs. Evidence shows that legislation is not delivering results and actions needs to be taken urgently: • A stronger governance of air quality policies and a broader engagement of all actors are needed to implement effective actions enabling compliance with pollutant concentration limits. The Commission should establish a reporting, reviewing and monitoring cycle, similar to the reinforced model set in the Regulation on the Governance of the Energy Union, including the provision on common templates. Integrated National Climate and Energy plans, Air Quality Action Plans and National Air Pollution Control Programs need to be coherent and their measures need to be better coordinated vertically and horizontally. Guidelines, benchmarks and best-practice should be provided to support Member States actions. Air quality co-benefits also in wider economic terms should be always taken into account when assessing any new policy with a direct or indirect impact on air quality. Citizens, cities, regional and local communities should be engaged in the definition of plans and programs. • Means for accelerating the penetration of the decarbonized electricity vector should be explored for sectors like transport and heating which are not delivering effective reductions in air pollution. Electrification is an energy efficient way of making those sectors sustainable in the long run. Switching from the direct use of fossil fuels to electricity enables an efficient pollution control of emissions: it eliminates distributed and highly fragmented emission sources in the building and transport sectors, transferring them to power generating plants that are generally easier to regulate and control and will rapidly become emission free. As a result, air quality impacts, especially in urban areas where most of the population lives, would be minimized by an increasing uptake of electricity-based technologies. Governments should develop ambitious plans to foster sustainable RES-based electrification business models across all sectors. Regulation should remove the remaining barriers hindering the adoption of electric technologies and should support network digitalization enabling sectorial coupling. • From a circular economy perspective, and with reference to cities, urban areas should be reorganized in a circular way, promoting the electrification of consumptions and transport and enabling the closing of loops at local level. • Location requirements for monitoring stations have to be reviewed so as to more closely reflect real population exposure. • Communication to the general public needs to be both increased and improved to enhance citizens’ engagement.
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Meeting with Valdis Dombrovskis (Executive Vice-President) and

12 Jan 2021 · Recovery and Resilience Facility; Financing the Green Recovery; Sustainable finance

Response to Revision of the Communication on important projects of common European interest

21 Dec 2020

Enel Group confirms its commitment for IPCEI and welcomes the future opportunities to improve the drafting of the new IPCEI Guidelines because we believe in the paramount role that those projects will play in the context of a decarbonized and competitive Europe. We support the European Commission scope for the application of the IPCEI. However, we believe that regarding Environmental, Energy and Transport projects (point 23) the Commission should provide more visibility and clarity about the role and the relevance that these sectors actually deserve, particularly in light of the European Green Deal ambitions, also in terms of objectives and eligibility criteria. We welcome the potential of the IPCEI, and we strongly believe in the role that those projects could play in the next future, for instance in transport sector, mainly E-mobility and in the green hydrogen production. However, we think that taking into account the evolution of new technologies and new sectors that can contribute to achieve the carbon neutrality, the IPCEI projects should not be selected and limited to these six industrial sectors. Attached a file with further details
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Response to Climate change mitigation and adaptation taxonomy

17 Dec 2020

Enel welcomes the opportunity to provide feedback on the Commission’s Inception Impact Assessment on the Delegated Regulation draft for stablishing 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. Concerning technical screening criteria for “Climate change mitigation”, Enel regrets the fact that the current draft of the EU Taxonomy Delegated Act does not include specific criteria for the segment of the electricity value chain referred to retail sales, that on the contrary constitutes a fundamental segment of the power value chain and that plays a critical role for the decarbonisation of end use energy consumption. Enel suggests to also consider the retail power activity among those with eligibility criteria by requesting retailers to apply either the criteria for the electricity generation activity or the criteria for the electricity distribution activities. Furthermore, Enel urges the Commission to reconsider the comprehensive eligibility of the Hydropower generation, that ranks amongst the best performing electricity generation technologies with respect to life-cycle emissions and that should therefore be treated equally to other renewable electricity generation technologies such as wind and solar. Concerning the “Do Not Significant Harm” criteria established for hydropower plants, we recommend to differentiate between the operation of existing hydropower plants and the construction of new hydropower plants when specifying the requirements to be applied for each of the five environmental objectives to which the DNSH principle has to be met. Speaking of electricity generation from Geothermal, we recommend the emission thresholds to be deleted for geothermal energy as it is a renewable energy source and because the CO2 emitted by a Geothermal Power plant has a natural origin, as there are no combustion of fossil fuels. Moreover, like for solar and other renewable energies, LCE should be uniformly applied in form of technology-specific standard values for the upstream LCE instead of project-specific calculation. Based on most recent UN’s IPCC data, several technologies on top of those already proposed for an exemption by the TEG fulfil this prerequisite and should thus be exempted from an obligatory LCE analysis: geothermal technology has sufficient evidence of being far below the threshold of the Emission Performance Standard of 100g CO2 / kWh. In the light of this, geothermal power plants should be exempted from conducting LCE analysis also for new projects. For what concerns transport, Enel invites the Commission to enlarge the list of eligible business activities related to electric mobility, including but not limited to: software solutions for electric mobility, e-mobility service provision or financing mechanisms. Finally, regarding the “Do no significant harm (‘DNSH’) criteria on Transition to a circular economy”, Enel believes that identifying a single criterion for mapping the transition to the circularity of the entire electricity sector, applicable along the whole value chain, would represent a very effective simplification. Enel’s position is further detailed in the document attached.
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Response to Revision of Regulation on Union guidelines for the development of the trans-European transport network (TEN-T)

15 Dec 2020

The need of a transport infrastructure policy at EU level is paramount, it allows closing gaps, removing bottlenecks and eliminating technical barriers that exist between the transport networks of EU Member States, strengthening the social, economic and territorial cohesion of the Union and contributing to the creation of a single European transport area. Europe cannot afford a patchwork of infrastructure solutions which risks leaving some regions and consumers behind. The TEN-T regulation was adopted in 2013 and the provisions adopted were aligned and coherent with that time. Meanwhile the EU ambition and goal in terms of climate policy, energy efficiency, and decarbonization policies have evolved so the current provision are no longer in line with the new EU goals (e.g. TEN-T still calls for “a significant reduction in CO2 emissions by 2050” only). Indeed, TEN-T regulation is clearly outdated on what concern the EU climate ambition: solutions that not allow to overcome the lock-in on fossil fuel and that can have only a moderate reduction effect on GHG emission are still supported and considered as clean fuels despite the availability of proven and cleaner solution. These options not aligned with the long-term decarbonization strategy shall be phase-out to allow the transition toward zero emission solution. In the light of the current EV market uptake and as underlined in the Green deal Communication, the EU must accelerate the deployment of charging points in the TEN-T core, comprehensive network and in urban and near urban areas also outside the TEN-T core network. If no additional action is taken infrastructure gaps for recharging points will remain in urban and suburban agglomerations and in the TEN-T core network corridors as well. To allow vehicles to travel easily throughout the EU ('continuity of service') and to provide the long-term market certainty infrastructure must be spread wider and the deployment of recharging infrastructure shall be made a general priority of TEN-T both in the comprehensive network and both in the core network. The comprehensive network should be expanded to cover urban and near-urban areas, minor urban areas, where recharging point customer experience shows the future market uptake potential for EVs is higher. Conveying financial support to projects, in particular for fast and ultra-fast charging infrastructures, also outside the main corridor of TEN-T network shall be made a priority because the comprehensive network is where most of main roads/highways lie (e.g. France, Spain and regions of Italy). Recharging infrastructure also need digital and smart infrastructures, both electricity and telecom, for the development of open and interoperable services for the benefit of the consumer. It is recommended that the design of the next TEN guidelines (transport, Energy and Communication) be reviewed to effectively foster the creation of the desired synergies. This is particularly important as the industry shows increased interest in investigating and experimenting with synergies, for instance between high power charging for EVs and medium-voltage level energy storage (EES) to reduce stress on certain strained local grids and in addition boost added-value services to the grid. On-shore power supply (OPS), should be included explicitly in the list of priorities for maritime and inland infrastructure development. As announced in the European green deal a substantial part of the 75% of inland freight carried today by road should shift onto rail and waterways. Waterway transport could offer an environment friendly alternative, however, it is crucial to assure that provisions to effectively support the deployment of on-shore power solutions in order to mitigate emissions of GHG, particulate and sulphur of ships at berth, as well as reducing noise and vibration in the harbour and surrounding areas.
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Meeting with Maroš Šefčovič (Executive Vice-President) and

15 Dec 2020 · The European Battery Alliance (EBA) and European Raw Materials Alliance (ERMA).

Response to New EU Soil Strategy - healthy soil for a healthy life

10 Dec 2020

The Enel Group strongly welcomes the Commission’s Roadmap for a “New Soil Strategy- healthy soil for a healthy life” as a pillar of the European Green Deal, considering that soil is a hugely important non-renewable resource, essential for human and economic health, biodiversity and food security. Land take and soil degradation are a serious problem in Europe and require urgent action. A harmonized policy framework at EU level for soil protection is paramount to reach no net land take by 2050 and land degradation neutrality by 2030, as stated in the Biodiversity Strategy for 2030. To be effective, the strategy should be aligned and integrated with other initiatives such as the Zero Pollution Action Plan, the Biodiversity strategy for 2030, the Circular Economy Plan and other, existing, EU legislation such as the Directive on Environmental Liability. Regarding the goal of no net land take by 2050, Enel considers that the New Soil Strategy should include the re-use and re-purposing of decommissioned industrial sites as a key lever to avoid further land occupation and soil pollution. This is particularly true for decommissioned power plants, within the context of the actual phase - out of fossil fueled power plants. Brownfield sites from decommissioned coal power plants can be reused for the development of renewable energy projects, taking advantage of already existing infrastructure and reconvert old “brown” jobs as well as create new ones. Enel is actively pursuing re-use of soil within its industrial strategy focusing on repurposing some of its industrial sites and extending the use of others. Enel’s global energy transition strategy foresees in this context a coal phase-out of almost 9 GW by 2027, with the decommissioning of the Group’s 10 remaining coal fueled plants, going hand in hand with an increase of renewable energy capacity of almost 100 GW by 2030. Site re-purposing, life extension and repowering of wind farms are considered as key options to be pursued. Based on its experience as major energy operator pro-actively engaging in the energy transition, Enel believes that the EU policy framework for soil should consider the following recommendations: 1. It should provide adequate incentives for sites re-purposing and brownfields re-use. Incentives should be granted to favor financing the reuse of brownfield sites against greenfield ones. Sites re-use contributes to a more circular economy and helps labor force relocation. It is a win-win solution for any power plant shutdown. 2. The policy framework should ensure stability and predictability for power plants shutdown and re-purposing of sites to new uses. Transparent long-term planning of units phase- out and a stable and predictable framework can significantly facilitate scouting opportunities for future second uses of brownfield sites as well as improve decommissioning process. 3. Fast track permitting procedures should be set up at Member State level for projects that entail additional environmental or social benefits, such as the re-use of fossil fuel power plants for the deployment of carbon neutral energy sources, such as renewables. 4. Regarding soil remediation, the new policy framework should set up homogenous criteria at EU level for the characterization and risk assessment of polluted land, including the definition of limits for certain pollutants. This should go along with expedite permitting procedures and financial incentives that lower the burden of remediation costs. 5. Finally, the new Soil Strategy should seek to maximize synergies with circular economy policy frameworks, for instance considering the significant impact of waste on land erosion, pollution and land take, especially coming from landfills. The recycling of waste of end of life assets from renewables should therefore be incentivized and included in the EU Product Policy of the new Circular Economy Action Plan as a key value chain.
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Meeting with Margaritis Schinas (Vice-President) and

10 Dec 2020 · Recovery plan

Response to Land use, land use change and forestry – review of EU rules

26 Nov 2020

• We welcome the proposed EU LULUCF Revision, alongside the ambitious package of enhanced policies and measures to accelerate the energy transition to a low-carbon economy. We support the European Commission’s approach to consider a emission reduction contribution from all sectors, providing the right policy mix, ensuring cost efficiency across all sectors, but also guaranteeing a clear transition pathway in all sectors. • MS need to improve LULUCF policies to avoid deterioration of sinks due to ageing and harvesting of forests. Carbon removals under current management are forecasted to gradually decline, whereas it is estimated that 2050 net zero target will require sinks to almost double compared to current levels. • Increased flexibility between ESR and LULUCF should be assessed and further flexibility should be explored while balancing the cost efficiency with the need of LULUCF enhancement. Increased flexibility could increase cost efficiency to achieve climate targets, while national targets and incentives guarantee LULUCF enhancement across MS. Enel believes that the flexibility mechanisms that the ESR regulation already foresees should be kept as a way to balance the complementarity between the role of the ESR and mechanisms in support addressing the LULUCF sector. • The EC should carefully avoid excessive flexibility between LULUCF and ESR and assess how it could be enhanced but also complemented with quantitative limitations to avoid the risk of loosened carbon markets. Increasing the LULUCF flexibility by allowing the use of sink credits for ESR/extended ETS compliance would allow the combined ESR and ETS to deliver fewer decarbonization in ESR sectors with risk of lock-in. Flexibility mechanisms may be limited through National and EU-level caps wherever convenient, to avoid non cost-effectiveness unbalances. • Distributional impacts of increased flexibility require further analysis, as increased actions in the LULUCF sector are not evenly distributed across MS due to their specific geography and consequent potential. More flexibility in LULUCF for ESR could compensate for unbalanced distribution. • The EC should address the lack of certification of enhanced levels of carbon stored in the LULUCF sink at the level of private land ownership. As the carbon sequestration costs and enhancement of biological diversity are not sufficiently rewarded and the environmental costs of land-related activities are not priced, farmers and foresters do not take sufficient climate action. • The EC should assess implications strengthened LULUCF designs may have on the sourcing of materials for the bio economy . Additional incentives for enhancing carbon absorption could reduce the supply of biomass. Therefore, the benefits of increasing forests/carbon stocks in terms of improved biological diversity and other ecological functions, should be measured vs. the counter-balancing negative effects on the bio-economy. • Enel believes that improving LULUCF sink requires additional policy levers to achieve sustainable enhancement of forest and carbon stocks. Current policies do not provide any direct incentives for farmers and foresters. Other policies such as the CAP strategic plans or the Biodiversity Strategy or forthcoming Forest Strategy could provide some additional incentives.
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Response to Updating the EU Emissions Trading System

26 Nov 2020

•Enel welcomes the approach of the legislative initiative, aimed at strengthening the EU ETS, and the ambitious package of policies and measures to accelerate the just transition to a low-carbon economy. It is critical for the EC to adopt a holistic approach enhancing carbon pricing alongside complementary policies and measures. Current ETS should be revamped while striking a careful balance between enhancing/extending the market instrument and streamlining the relevant policies, incentives and funding required to overcome non-economic barriers. •ETS target. The EC should consider a balanced distribution of reduction efforts among sectors based on cost-efficiency. The contribution of ETS sectors vs. other sectors should be based on techno-economical abatement potential. Thus cost efficiency of abatements in the different sectors should be evaluated in light of technology evolution, enhanced carbon prices and reinforced complementary EU and national policies and measures. •LRF Review. The abatement potential of power and energy emissions justify a substantial increase of LRF rate in the next 10 years to achieve keep a stable price signal. A more stringent reduction pathway could lay the foundation for acceleration in the most mature sectors in the light of the 2030 target. Moreover, sending a strong and predictable carbon price signal is of critical importance to guarantee the timely rollout of low-carbon technologies. •MSR Review. In light of an increased LRF, the EC should evaluate the following options for MSR review: - Increase of intake rate to keep the market balanced amidst overlapping national and EU policies. The intake rate could be kept at 24% after 2023 to cope with the EUA surplus. - Adjustment of MSR upper and lower ‘activation thresholds’ in view of a reduced cap in 2021-2030 to maintain the MSR effectiveness. - Effect of different MSR cancellation thresholds on market surplus/liquidity •Extension to RT. The EC should assess the enhancement of Road Transport policies and measures to foster electric infrastructure development, batteries innovation and electrified public transportation. Cars regulations and emissions standards are to be strengthened to reach zero emissions. A ‘Separate RT ETS’ may also be explored for the medium-long run to ensure the sector’s contribution to decarbonization, while supporting low-carbon technologies and infrastructure with enhanced measures and incentives. Longer-term linking with flagship ETS may be scrutinized as well. •Extension to Buildings. All low-carbon policies and measures in Buildings should be strengthened to ensure the swift decarbonisation of the sector. The EC should reinforce standards for buildings and assess electrification incentives at the EU and Member State levels while protecting low-income residents. Possible adoption of ETS in Buildings could be explored as residual tool since an extremely high carbon price level would be needed to reduce GHG emissions. •CBA Revenue Allocation. Enel believes a Carbon Border Adjustment (CBA) should be initially adopted in selected carbon-intensive sectors only: power, cement, steel and chemicals. The adoption of the CBA should be matched with a gradual phase-out of free allocation to avoid short-term distributional impacts. Initial pilot for Electricity sector could be rolled out as this sector is ready to become part of CBA rapidly since no transition is required from free-allocation to auctioning, allowing a smooth deployment. •Renewable Hydrogen. ETS innovation fund should increasingly support innovative and promising low carbon technologies including Renewable-based hydrogen. A renewable hydrogen support scheme should focus on demand-side scheme over quota-production scheme to mitigate the risk that renewable hydrogen would feed final uses whenever cleaner options exist. The policymakers should support the renewable hydrogen scale-up and foster energy end-use in hard-to-abate sectors via market-based tools.
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Response to Updating Member State emissions reduction targets (Effort Sharing Regulation) in line with the 2030 climate target plan

26 Nov 2020

Enel welcomes the revision of the Effort Sharing Regulation (ESR) and the related Impact Assessment, aimed at enhancing EU climate policies in light of the more ambitious climate targets. The current ESR target (30% reduction vs. 2005 in sectors not covered by the ETS such as transport and buildings) is not in line with the increased ambition under debate to reduce responsibly at least 50% to 55% the overall EU GHG emissions. The Impact Assessment should explore the different policy options in line with increased ambition choices. The revision of the ESR should seek a right balance between reductions in current ETS sectors and in ESR sectors on the basis of effectiveness and cost efficiency. 2030 ambition for ESR sectors needs to be strengthened without impacting negatively end users. Ambition needs to be aligned with 2050 climate neutrality avoiding locking-in emitting infrastructure while carefully managing price impacts on the most exposed segments of society. The interaction of market signals (EU ETS) and EU/National Policies & Measures needs to be carefully assessed. In fragmented sectors like transport and building, price signals are not sufficient to overcome non-economic barriers, which often hamper the adoption of low-carbon technologies. The inclusion of transport and building fuel emissions in ETS could support the GHG reduction goal, but strengthened policies at both EU and Member State level would still be needed. Member State policies are paramount to address non-economic barriers. The extension of the ETS to new sectors could potentially lead to unbalances among sectors and among Member States. The possible allocation of allowances may interfere with EU and National policies and markets. Currently ESR targets are implemented into national policies through 2021-30 National Energy and Climate Plans, which are already giving a strong policy signal to end-use sectors for this decade. It is crucial to explore the need to keep the existing Member State burden-sharing scheme in the ESR to have both national targets and related decarbonization measures in support for ESR sectors. The Impact Assessment should explore the effects of increased flexibility between Member States and with LULUCF. Flexibility decreases overall mitigation costs but increases the risk of locking-in carbon intensive technologies in some Member States. Based on the above elements, we would like to contribute to the process with our following initial recommendations: − The Commission should carefully consider how maintaining ESR coverage for any new ETS sectors could guarantee a right policy mix and at the same time avoid unbalanced distributional impacts through Member States and sectors. − The Impact Assessment should assess the risk of weakening national policies due to the extension of the ETS to new sectors. The role of ESR targets at national level should be maintained and reinforced to enhance national policy actions and measures through higher ESR targets. − The Impact Assessment should evaluate how to update upwards the ESR targets by Member States in line with the 2030 increased ambition. − The Commission should explore how EU-level and MS-level ESR targets could be properly cascaded into sub-sectorial targets to give a stronger policy driver to sectors like transport and buildings, which are lagging behind in the decarbonization process. − Flexibility between the ESR sectors and LULUCF sector is advisable, but the use of limiting caps should be assessed to avoid loosened pricing signals. The revision of the ESR should keep flexibility mechanisms to balance the complementarity between ETS extension, the ESR role and LULUCF sector. The flexibility mechanism may be limited through MS and EU-level caps to avoid unbalances.
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Response to Revision of the CO2 emission standards for cars and vans

25 Nov 2020

Since 1990, emissions from road transport have increased significantly and as of today account for almost a fifth of EU's GHG emissions. The next years are critical for curbing CO2 emission. If action is insufficient in the short-medium term, it will likely be impossible to make up for the deficit later, this requires a substantial decrease in CO2 emissions in the transport sector. Transport also affects heavily air quality, noise pollution and health. Despite improvements in fuel quality and vehicle efficiency, road transport remains the major cause of air pollution (in particular, totaling 39% of NOx emissions). Although emissions of the main air pollutants from transport have been declining over the last two decades, many of the EU’s urban dwellers remain exposed to air pollutants concentration levels that exceed the EU’s air quality standards. Against this background and as underlined in the European Green Deal Communication, transport should become drastically less emitting, especially in cities: “To achieve climate neutrality, a 90% reduction in transport emissions is needed by 2050”. Road transportation is the most emitting subsector, but also the most feasible to decarbonize thanks to proven and soon cost-efficient technologies. Electric mobility is key to reach both the EU’s climate and energy efficiency objectives. It represents the clear pathway towards zero-emission mobility goal of EU. Driven by the entry into force of 2020/21 CO2 emission limit targets for cars and vans, the growing sales of electric cars across Europe have already resulted in a significant drop in new car CO₂ emissions. In this context, Enel welcomes the European Commission proposal to review the Regulation (EU) 2019/631 on CO2 emission performance standards for cars and vans as a necessary policy action to foster a further shift toward zero emission electric vehicles and thus decarbonize the road transport sector. As underlined in the IIA, changes in the current regulation are deemed necessary to enable the EU to meet its long-term GHG emission reduction targets, effectively address the air quality issue and foster Europe’s industrial growth and its vehicle manufacturers’ leadership in the world. Against this background, the following main measures should be considered: • Strengthening of the stringency of the CO2 emission limit targets for both cars and vans: more ambitious targets should be set in order to put Europe on track to reach the long term target of reducing by 90% transport GHG emissions by 2050 compared to 1990 • Revision of the incentive mechanism for zero- and low-emission vehicles, in particular by: o Replacing the current crediting system with a one-way CO2 target adjustment with a more effective “ZLEV mandate” requiring vehicle manufacturers to sell a minimum proportion of ZLEV including non-compliance penalties o Revising the threshold to classify a vehicle as zero and low emission vehicles (ZLEV) and to be eligible to ZLEV incentive mechanism (e.g. the Clean Vehicles Directive set a 0g CO2 /km from 2026 threshold for clean vehicles) Moreover, we believe that metric based on WTW approach, the potential inclusion into CO2 emission performance standards of carbon correction factor (CCF) or similar credit based mechanisms should be discarded as this could undermine the environmental effectiveness of CO2 standards and lead to double regulation /counting, interfering with other policy instruments (e.g. fuels policies).
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Response to Revision of the Vertical Block Exemption Regulation

20 Nov 2020

Enel Group is one of the main integrated operators in the electricity and gas sectors, with a particular focus in Europe and Latin America. We operate in the generation (RES and conventional) and distribution of electricity and in the trading and supply of gas and electricity. Without prejudice to the importance and functionality of the current VBER, we believe some amendments could still improve its value to provide up-to-date guidance taking into account the growing crucial role of agreements pursuing sustainability objectives in line with the EU Green Deal policy goals. We are particularly interested to the VBER in so far as it is applicable to energy supply agreements between a supplier and large industrial purchasers, as they operate at different levels of the production and/or distribution chain (i.e. non-competitors). Due to the less significant anti-competitive scope of this type of agreements, the VBER establishes a “safe harbor zone”, that is an area of exemption from the prohibition of agreements for those that do not contain certain clauses and provided that the market shares held by the supplier and the purchaser do not exceed 30% of the market, calculated with reference, respectively, to the sales markets and the purchasing markets. The VBER regulates also the duration of these contracts. According to Art 5.1 (a) “the exemption shall not apply to any direct or indirect non-compete obligation, the duration of which is indefinite or exceeds five years.” The notion of non-compete obligation as defined in Art 1 (d) includes: (i) “any direct or indirect obligation causing the buyer not to manufacture, purchase, sell or resell goods or services which compete with the contract goods or services, (ii) or any direct or indirect obligation on the buyer to purchase from the supplier or from another undertaking designated by the supplier more than 80% of the buyer's total purchases of the contract goods or services and their substitutes on the relevant market, calculated on the basis of the value or, where such is standard industry practice, the volume of its purchases in the preceding calendar year.” Those provisions could apply also to RES Power Purchase Agreements (PPAs). With specific reference to long term RES PPAs and with the ultimate aim of guaranteeing a full achievement of the objectives of the EGD, i.e. supplying clean, affordable and secure energy, these thresholds involving (a) the duration of RES PPAs, (b) market share and (c) share of purchases, should be removed insofar as these contracts are exclusively related to the support of RES development. Moreover in many cases PPAs also require a relationship-specific investment made by the supplier, in relation to which the Guidelines on Vertical Restraints state in par. 146 that “a non-compete or quantity forcing agreement for the period of depreciation of the investment will in general fulfil the conditions of Article 101(3). In the case of high relationship-specific investments, a non-compete obligation exceeding five years may be justified”. To further support the above-mentioned proposal, it is worth underlining that - other than preventing the lack of investments necessary to achieve the EGD commitments – RES PPAs lead to efficiencies for both energy producers in terms of greater financial certainty, and for industrial consumers since they reduce exposure to the volatility of energy prices. In addition, the RES market, addressed by these contracts, is also thoroughly fragmented as demonstrated by the high number of active operators, and purchasers in this segment do frequently resort to the common practice of requesting a number of competing offers before choosing the supplier. RES Long-term contracts, regardless of market/purchase shares, may therefore guarantee not only greater certainty of the return on green investments, but can also allow businesses already involved in the support of energy from renewable sources to further commit to EGD objectives.
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Response to Revision of EU legislation on end-of-life vehicles

13 Nov 2020

Enel SpA, a multinational company in the energy sector and active in the e-mobility value chain, highly appreciates the EC initiative to revise the Directive 2000/53/EC on end-of-life vehicles (ELV) to prevent waste from vehicles, promote reuse, recycling and other forms of recovery of ELVs and their components so as to reduce the disposal of waste and improve the environmental performance of all economic operators involved in the life cycle of vehicles, especially those involved in the treatment of end-of life vehicles. In particular, we would like to underline the importance that the ELV directive will assure a coherent framework with other EU legislations under revision and in particular with the Battery directive, develop highly efficient end of life solutions in compliance with sustainability and life-cycle assessments for batteries in terms of tracking, collecting, dismantling of LIBs and post-LIBs until recovering of black mass and address the regulatory barriers that could hamper the development of solution or limit the availability for innovative second life battery uses (e.g. integrating second-life batteries from EVs in the development of High Power Charging (HPC) infrastructures) . Against this background you will find in attachment the Enel's feedback already provided to the consultation on the revision of battery Directive.(Attachment: Enel’s response to the Roadmap for Batteries Consultation dated 08/07/2020)
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Response to EU Action Plan Towards a Zero Pollution Ambition for air, water and soil

29 Oct 2020

Enel strongly welcomes the Commission Roadmap for the EU Action Plan “Towards a Zero Pollution Ambition for air, water and soil – building a Healthier Planet for Healthier People”, as pollution comes at a high price for society and ecosystems, including loss in life expectancy and morbidity, health-related costs, reduced yields, remediation costs and loss of ecosystem services. Pollution and climate change are closely related, for which the Zero Pollution ambition is a key pillar to reach the zero emissions target by 2050. In addition to this, it is paramount that the Zero Pollution Action Plan gets coordinated with the Circular Economy Action Plan, to contribute to the transition to a clean and also a more circular economy. In fact, the circular economy will be a key driver for the implementation and the enforcement of zero pollution measures, at any level both by authorities and by civil society. AIR QUALITY Air quality in Europe is still far from complying with European or international standards, with many Member States continuing to be under infringement procedure and with severe impacts in terms of life expectancy and quality, ecosystems degradation and healthcare costs. A stronger governance of air quality policies, synergic action with other climate and energy policies and a broader engagement of all actors are needed to implement effective actions enabling compliance with pollutant concentration limits. To reduce air emissions – especially in urban areas - the Zero Pollution Plan should explore means to accelerate the penetration of the decarbonized electric vector for sectors such like transport and heating and cooling which actually are not delivering effective reduction in air pollution. Electrification should be accelerated as a key solution to solve the energy “trilemma”: energy security, energy equity and environmental sustainability. In accordance with the new Circular Economy Action Plan and the European Strategy on Sustainable and Smart Mobility, the enhancing of circular practices such as product-as-a-service solutions will help reduce pollution in order to meet the zero the emissions target. The electrification of transport, residential and tertiary sectors, accompanied by the development of renewables in the power sector could significantly contribute to achieve the EU long term air quality objectives. Moreover, the initiative on the Development of post – Euro 6/VI emissions standards for cars, vans, lorries and buses should support the penetration of electric vehicles by more restrictive emissions limits, lowering at the time the risks for other diesel gate cases. WATER QUALITY Hydropower is the single largest renewable electricity source in Europe and its production capacity should be preserved. Hydropower plants are highly valuable assets to be exploited as a cost-effective and sustainable solution to achieve climate and energy goals and they provide a wide number of co-benefits all along the water management chain. Regarding the protection of water, there is a need to integrate water regulation with other, non-environmental policies, providing for a holistic view that finds a balance between the values of water for use in different sectors while preserving the underlying ecosystem. This is particularly true for energy and low carbon policies, since the water – energy nexus is not always managed in an efficient way and conflicts exist between the energy and environmental agenda. SOIL PROTECTION AND SITES REPURPOSING IN THE ENERGY TRANSITION Related to soil protection, and within the context of the coal phase-out of thermal power plants, the Zero Pollution Plan should consider and support site repurposing after the decommissioning of fossil fueled power plants. A proper decommissioning process and re-purposing for the phase-out of old units can bring to light a residual value and win-win solutions for new uses, that otherwise would be lost forever. Please see attached file for extra details.
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Meeting with Frans Timmermans (Executive Vice-President) and Volkswagen Aktiengesellschaft and

1 Oct 2020 · Discussion on Green Recovery

Meeting with Frans Timmermans (Executive Vice-President)

29 Sept 2020 · Green deal and recovery related issues

Response to Review of Directive 2012/27/EU on energy efficiency

21 Sept 2020

Enel strongly welcomes the Commission combined Evaluation Roadmap and Inception Impact Assessment for the review of Directive 2012/27/EU and amending Directive 2018/2002 on Energy Efficiency, as the “Energy Efficiency First” principle constitutes one of the main pillars of the EU’s fight against climate change and a successful and sustainable energy transition. Enel supports the Commission’s proposal of an increased EU decarbonization ambition by 2030 to reduce GHG emissions at least 50% and towards 55% compared to 1990 levels in a responsible way, and to reach climate neutrality in the EU by 2050. Upscaling climate action through the energy transition will deliver substantial benefits in terms of economic and resource efficiency, reduction of global and local pollution, resilience to economic, technological and environmental change. Enel supports the assessment within the Impact Assessment of an upwards revision of the 2030 EU energy efficiency headline target to 35%. To further decarbonize the EU energy system, energy efficiency must be prioritized. The policy options assessed in the Impact Assessment should consider a wide range of target scenarios delivering on the potential contribution of energy efficiency to a higher greenhouse emissions reduction target. The revision of the Energy Efficiency Directive should consider the potential benefits and feasibility of setting sectorial sub-targets. There is a large energy savings potential to be exploited through synergies among end-uses of energy in the different sectors. One good example is the synergy between the transport and the buildings sectors, where both sectors can support each other to increase energy savings. Through specific sub-targets Energy Efficiency can capture value from sectors with high potential for energy savings. Electrification can effectively support the ‘energy efficiency first’ principle and generate substantial energy savings throughout Europe: - Shifting to electricity as the most efficient energy carrier plays an important role in reaching the energy efficiency targets, by means of technologies spanning across sectors. Thanks to its efficiency, electrification results in a significant reduction in overall energy consumption. - Electrification brings multiple benefits, including enhanced decarbonization, better sector coupling, energy system integration, increased flexibility, air quality improvement, resource efficiency, citizen empowerment and new quality jobs. -The Primary Energy Factor (PEF) should be updated in the event of a revision of the Energy Efficiency Directive to a value lower than 2.0 in order to better reflect the current energy supply mix. The future revision of the Energy Efficiency framework should reinforce the role of digitalization in the efficiency of energy systems including grid infrastructure, products and services. The impact assessment should address the need for upgrading and digitalizing transmission and distribution grids. It should explore the best means of accelerating the integration of ‘smart-ready’ equipment and appliances in networks and end-use sectors, enable and maximize efficient flexibility and demand response services and support continuing the roll out of smart meters and transitioning from early 1st generation to 2nd generation of smart meters. The policy design of a revised Energy Efficiency Directive should consider the need to set stronger links between the Energy Efficiency Directive and other regulations, including the EU Renovation Wave for buildings and the Renewables Directive. Building renovation needs to rapidly become much deeper, structurally incorporating electrification, heat pumps and demand response. Furthermore, the upwards revision of the target could be supported by a number of new and existing measures including adressing tariffs overburdening, extension of audits to SMEs, more stringent standards and voluntary certificates at EU-level . Further details in the attached paper.
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Meeting with Mario Nava (Director-General Structural Reform Support)

14 Sept 2020 · Decarbonization looking at 2030 and 2050 horizons – Presentation of the study

Response to Requirements for Artificial Intelligence

9 Sept 2020

Dear Members of DG CNECT .A.2, Enel SpA, a multinational company in the energy sector, highly appreciates the EC proposal for a legal act laying down requirements for Artificial Intelligence. At Enel, we use Artificial Intelligence and technology to make the energy and power systems more efficient, more predictable and more sustainable, making easier for our customers to interact with us and to play a more active role in the energy system, mainly in the liberalised energy market. The European digital strategy released on February this year, stresses that citizens need to be able to trust the technology itself as well as the way in which it is used. The European Commission White Paper on AI, maps out various policy options and reveals that clear and mandatory requirements would “in principle” apply only to AI systems or applications which are considered ‘high-risk’, i.e. employed in sectors where significant risks can be expected to occur, or used in such a manner that significant risks are likely to arise. In line with the non-binding Ethics Guidelines by the AI HLEG, the White Paper on AI suggested that the mandatory requirements for high-risk systems could cover the following aspects: • Training data; • Data and record-keeping; • Information to be provided; • Robustness and accuracy, with an ex-ante consideration of the potential risks; • Human oversight; • Specific requirements for certain AI applications, such as remote biometric identification. Considering this and welcoming a risk-based approach, Enel advices the European Commission that the risks are in the infringement, not in the technology or in the sector and, recommends to assess and establish the characteristics of different types of risks and threats with a ‘sector-by-sector’ approach, requiring inter alia a ‘sectoral’ data protection assessment. Within this view, the different classes of use-cases must be integrated. It is worth noting that in the energy sector, which is considered “high-risk” according to section C of the White Paper, all its AI based applications cannot systematically be categorised such as “high-risk”. For instance, an application utilised to interact online with clients about customer care activities will normally not pose risks of such significance to justify, at this time, legislative intervention. Possible mandatory legal requirements to be imposed on high-risk applications should be carefully evaluated before establishing them as (ex-ante) obligations for businesses. Enel believes also necessary to better define ‘high-risk’ and the methodology to assess it. Poor categories and definitions might deter private investments and become a competitive disadvantage to European companies. Given the actual economic crisis together with the financial risk nature of research and innovation activities, Enel urges the Commission to build a financial structure to back organisations involved in the mentioned ‘high-risk’ sectors. If the EU system is not supportive towards innovation, the opportunity for innovations to come from Europe will be reduced. Therefore, the Enel Group promotes the development of long-term European action plans on digital policy, which should be evidence-based, promote security by design, guarantee high data quality standards, promote ethical evaluation for different use cases and enable new technologies and business models, without imposing unnecessary burdens and costs nor obstacles to innovation.
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Response to Review of EU rules on fluorinated greenhouse gases

7 Sept 2020

Enel Group welcomes European Commission initiative for the review of Fluorinated Greenhouse Gases rules. Enel is strongly committed to the objectives of the Paris Agreement and the achievement of a 2050 zero-emission goal, alongside an ambitious science based certified reduction target by 2030. Therefore, pursuing the GHG reduction commitments, alongside the decarbonisation of our electricity mix, Enel’s Distribution System Operators (DSOs) are deeply involved in the active measures on sulphur hexafluoride (SF6 insulating and circuit breaking medium) management in electrical switchgears. Enel DSOs are strongly committed to improved operation and strengthened maintenance policies and procedures with the aim to minimize GHG emissions and to investigate effectiveness of innovative switchgear design to finally avoid SF6 use as soon as these gases will be no longer needed. Nonetheless, it is important to highlight that SF6 represents a very limited part of current F-gas emissions, considering a share of only 0.1% of overall EU GHG yearly emissions. Indeed, it important to mention that in all MV secondary substations new switchgears the “sealed for life” containment already includes small SF6 quantities and ensures very low emission rates, while in primary substations non-SF6 circuit breakers experience, using Air Insulated Systems (AIS) is widespread. In spite of the current level of maturity for a deployment on the entire electricity network, Enel DSOs confirm the willingness to test SF6 alternative technologies leading the industrial experience and supporting solutions fine-tuning for proven reliability. Comprehensive analysis of results shall support a Life Cycle Assessment (LCA) over a complete industrial cycle (from operation and maintenance to end of life and recycling), to define phase-down ambition in line with actual technological development. Nevertheless, up to date, the availability of alternatives to SF6 between different electrical applications and voltage levels is not homogenous and consistent to plan the F-gases prohibition in electrical switchgears in the near term. For applications where alternatives are in place, although non-SF6 switchgears would be more expensive and could have higher dimensions than SF6 switchgear (leading economic impacts on regulated electrical tariffs and troubles in retrofitting urban limited-space substations), these are not the main reasons for the aforementioned conclusion. Full viability and sustainability of any potential alternative has yet to be proven in compliance with REACH framework and strict technical standards that currently switchgears must meet to prevent risks for safety, health and environment. Enel DSOs are committed in testing on-field non-SF6 alternatives ability to perform as required in actual work-conditions, supporting the risk assessment and comprehensive likely impacts evaluation. Available solutions, following scouting initiatives of most advanced SF6 free equipment, are under trial both in MV sealed equipment technology and in HV circuit breakers.
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Response to Revision of the NIS Directive

5 Aug 2020

Dear Members of DG CNECT H2, Enel SpA, a multinational company in the energy sector highly appreciates the EC initiative to review the Directive (EU) 2016/1148. The first suggestion to revise the future legislation relates to the provisions allowing Member States to define essential services and identify operators of essential services in their territories. The Enel Group agrees with the considerable degree of fragmentation across the Union when it comes to the identification of OES, identified by the Commission at the report on the operators of essential services. For multinational companies as Enel, having different ways of application of these provisions as well as different schedules hinders risk management practices of operators and represents a burdensome administrative approach. Furthermore, actual security and incident reporting requirements diverge among EU countries, hampering cross-border cooperation and information sharing between operators. Enel firmly believes that, a more harmonized process of identification of operators of essential services, as well as the timing of the implementation will foster cooperation with National CERTs and hence, prevent and respond to cyberattacks. Some further initiatives aiming to enforce the harmonization process could be: 1. unified criteria for defining ‘type of entities’ to include in the sectors and subsectors in the NIS Directive Annex II 2. alignment on criteria for defining thresholds (both qualitative and quantitative) 3. coherence on the application of the “lex specialis” principle amongst Member States. Moreover, considering the growing digitalization of the Energy Sector, it should be evaluated to include in Annex II some services (as ‘cloud computing services’) that are in Annex III or that are considered ‘additional sectors’ (as ‘information infrastructures’). Enel also considers paramount to involve Generation companies and public lighting services to avoid holes in the cyber security of our energy system, including the function “generation (distributed or centralised) and public lighting services” in Annex II. Potential threats associated with new and emerging technologies (such as drones, 5G, AI , etc.) should be considered as an input to identify new OESs. Finally, we would like to remark the actual desirable and relevant regulatory initiatives asking for solutions to similar issues. Enel strongly recommends that the overall policy framework regarding critical infrastructure protection and cyber security is reviewed with an holistic approach, encompassing all on-going initiatives. The NIS Directive review, the cross-sectoral financial services act on operational and cyber resilience, the Cyber Security Network Code, the documents issued by ENISA on the subject, and the National perimeters protections, are strictly related and interdependent addressing a common objective: a continuous Risk-based evaluation and consequent improvement measures of the service-related cyber assets and processes. Therefore, we strongly recommend to rationalize the whole EU cyber security regulatory framework to be sustainable across countries and companies by applying the principles of “hierarchy” (starting from a general act/statement/directive towards the domain specific one), “inheritance” (the compliance to part of the framework of higher hierarchy transitively applies also the following ones with lower hierarchy) and, adopting a single format of representations of the relevant information to EU authorities. This would avoid risks of inefficiency and extra efforts for Critical Infrastructure operators that in turn could be transposed in additional costs for services’ end users. Furthermore, the infrastructures in scope of the future directive on protecting EU critical infrastructure cannot be limited to the transport and energy sectors but, considering the next “Digital Society”, also information and digital infrastructure should be considered as EU Critical Infrastructure.
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Response to EU Methane Strategy

5 Aug 2020

Enel welcomes the upcoming Commission communication on an EU Methane Strategy, as methane is a relevant contributor to GHG emissions. Methane emissions contribute with a relevant share (approx. 15%) to global GHG emissions, being second in relevance after CO2 emissions. Methane losses in natural gas and oil upstream and midstream operations are a significant part of it, representing about a half of the methane anthropogenic emissions. Furthermore, methane has a notable impact on air quality issues, as it is an important precursor for tropospheric ozone. Structurally addressing EU direct and indirect methane emissions through an EU Methane Strategy is a long awaited issue since the Commission declaration attached to the National Emission Ceilings Directive 2016/2284 expressed concerns about a strong air quality case to reduce methane emissions, and the Governance of the Energy Union Regulation 2018/1999 called on the Commission to deliver a strategic plan to reduce methane emissions. Tackling methane emissions should become an ever increasing priority for the EU strategy to fight against climate change. Methane losses along the gas value chain represent extra-GHG emissions of up to 30% according to most estimates. According to the Fifth Assessment Report 5 (AR5) of the Intergovernmental Panel on Climate Change, average methane losses on the gas value chain are 2-3% of the natural gas consumed, although it could reach up to 5% for some geographies. According to internal calculations, this represents up to additional 30% GHG emissions to the emissions derived from the combustion of that gas. In 2015, the European Commission conducted a study on the field , concluding that average methane losses in the EU are 1.1%, being more than half of them related to the transport and distribution of the gas. Enel would like to emphasize that the EU methane strategy should tackle energy-related methane emissions from a structural point of view, taking into account the impact of direct and indirect methane emissions in terms of climate warming and air quality when planning new investments and assessing new energy and climate policies. The achievement of Member States’ and EU’s GHG reduction obligations can benefit from effective sectoral policies that reduce methane emissions in sectors involving gas and oil activities. New investments on infrastructures related to fossil fuels should be gradually replaced with investments with higher potential effects on GHG reduction, as well in terms of methane reduction. Related direct and indirect methane emissions shall become an additional criteria for EU taxonomy on climate and sustainable finance and awarding of EU funds. The likely underestimation of methane losses along the EU gas and oil value chains should be addressed in the strategy, deepening in the root causes and updating the knowledge on the issue through reliable data and empiric experiences, so as to become a better guide for policy makers. Estimates of methane emissions from losses in gas and oil operations are exposed to a high degree of uncertainty, and recent studies point out that methane losses along the gas value chain may be underestimated. The upcoming EU methane strategy should promote policies and best practices to prevent methane emissions related to oil and gas operations that could be avoided at no cost or at a reduced one. According to the International Energy Agency, it is technically possible to avoid around three quarters of today’s methane emissions from global oil and gas upstream and midstream operations. Around 40% of current methane emissions could be avoided at no net cost. The EU methane strategy should take specific attention to the management of methane emissions from new sources of methane such as biomethane and synthetic gases. New sources of methane such as biomethane or synthetic methane may cause additional emissions of methane to the atmosphere. - Please see attached paper for further details -
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Response to Enhancement of European policy on critical infrastructure protection

4 Aug 2020

Enel Group welcomes the Commission’s initiative and the intent to intensify the pace of the measures to enhance the protection and resilience of critical infrastructure through the establishment of a more comprehensive legislative framework. In terms of threats, it will be useful that the new framework on critical infrastructure protection defines a set of minimum threats to be analysed and addressed for every sector of critical infrastructure. As regards cooperation and communication between stakeholders, it will be useful to improve information sharing by promoting the identification and designation of liaison officers at the Operators of critical infrastructures and competent administrations. It will also be useful to reflect on how to use financial support to create a cooperative substrate, accompanying the imposition of obligations with the provision of resources. Within the European Union, under the guidance of the European Commission, several desirable and relevant regulatory initiatives ask for solutions to be applied in the face of very similar issues. Enel Group strongly recommends that the overall policy framework regarding critical infrastructure protection and cyber security is reviewed with a holistic approach, encompassing all the on -going initiatives. The review of the Directive on security of network and information systems (NIS), the cross-sectoral financial services act on operational and cyber resilience, the Cyber Security Network Code in the energy sector, the relevant documents issued by ENISA on the subject, the National perimeters protections are strictly related and interdependent, at the end addressing a common objective: a continuous risk-based evaluation and consequent improvement measures of the service-related cyber assets and processes. Therefore, we strongly recommend to rationalize the whole EU cyber security regulatory picture in order to be sustainable across all the member States and companies by applying the principles of “hierarchy” (starting from a general act/statement/directive towards the domain specific one) and “inheritance” (the compliance to part of the framework of higher hierarchy transitively applies also the following ones with lower hierarchy) and adopting a single format of representations of the relevant information to the relevant EU authorities. This would avoid the risks of inefficiency and extra efforts for Critical Infrastructure operators that in turn could be transposed in additional costs for services’ end users. Furthermore, the infrastructures currently in scope of the directive cannot be limited to the transport and energy sectors but considering the context moving toward a “Digital Society”, also information and digital infrastructure should be part of European Critical Infrastructure. Alongside cybersecurity measures, enhancing climate adaptive capacity and strengthening resilience by reducing vulnerability to climate change is paramount. Mitigating the corresponding physical and economic risks calls for the mobilization of significant financial and technological resources. Investments allocated to increase resilience and flexibility of grids with the application of latest generation digital technology will continue to enable and guarantee continuity of operations and service on Europe's grids. Furthermore, by investing in renewable energy such as wind or solar and increasing the electrification of the final uses, Europe can enhance energy security and mitigate energy external dependency concerns. As for the policy options, we consider that the best-suited choice should bring elements from both option 3 and 4. We believe that the revision of the current European Critical Infrastructure Directive is needed, with the objective to enhance the harmonization framework at European and national level, while expanding the scope also to sectors beyond energy and transport, such as the digital infrastructures and services.
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Response to A New Consumer Agenda

4 Aug 2020

Enel welcomes the Commission’s initiative to enhance consumer empowerment in both the green and the digital transitions. Having the largest customer base among European competitors, at Enel we strongly believe that EU customers will continue to play a more significant role in achieving the decarbonisation targets as long as, we as industry, will continue to prioritise sustainable products in terms of clean electricity generation and sources ls. Enel welcomes the framework introduced by the Clean Energy Package on prosumers and energy (renewables) communities, recognizing the key role that citizens will have in the energy transition. Empowered consumers, enabled to produce, consume, share, store and sell electricity, generated in particular from renewables, will represent a fundamental lever to achieve Europe’s decarbonisation targets. Thanks to new smart and clean technologies and new services allowing their integration into energy markets, prosumers and communities have the potential to bring benefits both to citizens and the electricity system itself, e.g. by boosting the development of distributed energy renewables solutions and bringing generation closer to consumption. In the electricity sector, smart meters will provide the consumers full awareness of their energy consumption and their large deployment should be accelerated EU wide. It is necessary for the utility sector to transform smart metering into an engaging and compelling proposition for customers and leverage it to deliver grid resiliency. European Commission should strongly continue to promote across Member States the importance and benefits of a clear smart meter roadmap, encouraging EU Countries to accelerate plans for a smart meter (architectural) roadmap after 2020, alongside further energy management systems. A transparent relationship with the customers is paramount and it can be easily boosted by digitalisation. Continuous attention to the customer and commitment to providing quality products and services are essential aspects in the relationship between the service/product provider and the customer. Reliability, safety and continuity of distribution, together with quality, effectiveness and transparency in the sale of energy should characterise each stage of the relationship with the customers. We strongly believe that all contracts, communications and advertising messages addressed to customers should be clear and simple, written in plain language, in order to ensure that customers fully understand them. They should be compliant with current regulations, without resorting to elusive or incorrect practices, without neglecting any information needed by the customer to make a decision. In Enel, we strongly believe that EU’s energy transition should be inclusive for combating the effects of energy poverty. Therefore, collaboration between the private sector and Governments is essential for the fight against energy poverty. Access to clean and affordable energy to the vulnerable population can be facilitated by promoting innovative, inclusive and flexible offers in services that enable the consumer to achieve energy efficiency and sustainable behaviour. In the energy transition a new and reinforced relationship with consumers should be managed, which will use different methods of communication with markets, businesses and Governments, in line with the evolution and interaction of AI, increasingly widespread IT technology, smart devices and new computational interfaces. Moreover, considering COVID19 circumstances, EU should reinforce the necessity to define new business models, promote different forms of inter-sector collaboration and develop increasingly innovative financial instruments and new channels for interacting with customers that are reducing the health risks for both the customers and employees, such as digital payments channels or video connection methods.
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Response to Empowering the consumer for the green transition

4 Aug 2020

Enel welcomes the EC’s legislative initiative on empowering consumers in the green transition, as a very relevant piece of the Circular Economy Action Plan and European Green Deal agenda. Improving and promoting the environmental sustainability of products and services should be a strategic priority for both private sector and institutions. When designing products or services, it is essential to evaluate the success and effectiveness of the circular economy, considering the flow circularity, which considers all components of materials and energy in the input and output phases and circularity of use, which measures the materials utilisation factor. The energy supply to the production and use of sustainable products and services should become one of the criteria taken into account to identify and label sustainability for consumers. The energy supply is one of the most relevant items linked to the sustainability of a product during its entire life cycle. In this vein, consumers should have the right to become aware about the impacts that their choices have in terms of energy requirements for the production and use of each product and service. This could be addressed by providing information on carbon footprints, product and organisation environmental footprint, renewable energy production involved and estimated GHG emissions and air quality impacts. A transparent relationship with customers is paramount and it can be easily boosted by digitalisation. Continuous attention to the customer and commitment to providing quality products and services are essential aspects in the relationship between the service/product provider and the customer. Reliability, safety and continuity of distribution, together with quality, effectiveness and transparency in the sale of energy should characterise each stage of the relationship with the customers. Access to more detailed information about their consumption habits and electricity usage per household appliance has to be strengthened through digitalization, the deployment of the smart meter, flexible and tailored offers that enable customers to consume energy more efficiently and become more aware about their energy consumption and footprint. Moreover, we would like to highlight the importance of the “greenwashing” principle, envisaged also in the Unfair Commercial Practices Directive, especially when it comes to practices of creating consumers the impression that a good or a service has a lower impact on the environment than the ones of the competitors. Therefore, a clear definition and criteria that set the concept of greenwashing are needed at European level, such as information on transparency, metrics and indicators adopted, alignment to the main actions defined from EU (renewable, electrification, circular). Consequently, we proposes to blacklist greenwashing practices as well as to make e-commerce greener by stimulating sustainable delivery and return options. Within the circular economy agenda, “Key Product Value Chains” should focus on the benefits of the EU consumers. We must ensure that the coverage of the entire value chains of products and services are managed in a systematic way (e.g. materials, waste, labour and sites) and should promote industrial partnerships across sectors and along the full value chain creating decarbonized circular industrial ecosystems. We strongly support the proposal for a new regulatory framework for an EU battery value chain for e-Mobility to become more sustainable and boost their circular potential. Regarding the policy options, we consider that a clear set of harmonized EU rules are highly needed by combining elements from both 1st and 2nd options, which will enable consumers to access detailed information on products’ sustainability and will encourages NRA to promote a clear set of measures to be nationally applied.
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Response to Sustainable and Smart Mobility Strategy

29 Jul 2020

The 2011 White Paper aimed at completing the internal market for transport, where considerable barriers remain, reducing the dependence on fossil fuels and cutting CO2 emissions. However as underlined in the European Green Deal, to reach the net zero emission goal by 2050, the transport CO2 emission reduction goal has to be revised upwards. We support the ambition to set a 90% reduction of transport emission within 2050. In order to translate such ambition into actions the upcoming strategy should provide strong signals to accelerate the transformation required, if action is insufficient in the short-medium term, it will be essentially impossible to make up for the deficit later. Road transport accounts for 72% of all CO2 emissions of the sector. Considering the continuous technological development and innovation (i.e. fall in the batteries cost, improvement of performance, technologies for smart EVs grid integration) the largest share of road transport can be easily decarbonized thanks to the BEVs uptake. BEVs allow transferring downstream the benefit of the decarbonisation of the power sector, concomitantly reducing Europe's dependence on imported fossil fuels improving air quality and abating noise pollution. The Strategy should: Foster a swift phase-out of ICEs and the transition to BEVs (e.g. via purchase incentives, revision of CO2 standards) in all road transport modes, tackling in priority the segments responsible for the largest share of emissions and where the use of EV is the most effective decarbonization and technological ready option (e.g. LDV, buses, light duty truck). Support the deployment of private and public charging infrastructure and foster the financial sustainability of public one (including airport and port infrastructure for ground movements and onshore power supply) through funding (e.g. CEF, state aid) and low-interest financial loans (e.g. through EIB) and OpEX measures (e.g. encourage Member States to define in the incipient phase dedicated tariff for recharging service both for public and private charging point taking into consideration the potentiality offered by smart meter in defining such tariff). In addition to the other measures above a dedicate ETS system for transport should be evaluated as complementary measure. Foster the vision of e-Mobility as an ecosystem of services providing an unequivocal indication that the recharging activities should be considered as a “comprehensive service”, beyond the mere supply of energy, both for public and private charging points. Remove the legislative and regulatory barriers that could hamper the deployment of new services and new integrated solutions for the customers (e.g. enable customers who recharge the vehicle at a private charging infrastructure to have access to additional services when the such infrastructure is used by a plurality of customers; uncertainties from the classification of recharging activity in the VAT directive) Reach the EVs full grid integration through an active participation to the energy markets in terms of smart charging strategies and provision of ancillary services to the TSO/DSOs. The completion of EVs integration into the electric system will bring incremental benefits in terms of efficiency, RES development and security of supply and at the same time will reduce the EV Total Cost of Ownership. Taxation should be reviewed in order to encourage the deployment of the most efficient and less polluting energy vectors thus supporting the EU climate objectives meanwhile protecting the competitiveness of EU industry. Tax exemption that benefit vessels for on-board diesel-electricity generation should be removed as it deters actions to improve energy efficiency and reduce emissions; a transitory exemption for the taxation of electricity as a fuel for transport should be considered in the light of positive environmental and energy efficiency externalities and to support EVs deployment in an incipient phase of the market.
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Meeting with Mauro Raffaele Petriccione (Director-General Climate Action)

23 Jul 2020 · Sector decarbonisation

Meeting with Antoine Colombani (Cabinet of Executive Vice-President Frans Timmermans), Riccardo Maggi (Cabinet of Executive Vice-President Frans Timmermans)

17 Jul 2020 · Green finance

Meeting with Kadri Simson (Commissioner) and

10 Jul 2020 · Exchange of views on energy system integration and hydrogen strategies.

Response to Modernising the EU’s batteries legislation

7 Jul 2020

Dear Members of DG ENV.Unit B3 – Waste Management & Secondary Materials Enel SpA, a multinational company in the energy sector highly appreciates the EC initiative to ensure a competitive, circular, sustainable, and safe value chain for all batteries placed on the Union market. To ensure a sustainable battery end-of-one-life and unlock markets for innovative battery uses, the following topics must be addressed at the Battery Directive (BD): The recovery metric should change for Li-ion batteries (actually defined as industrial batteries), from actual % average weight, as it is an inappropriate method for heavy batteries (as EVs). Recycling targets for Li-Ion Batteries based on its expected progression and the technical and economic feasibility must be defined. Although batteries can be repurposed under the BD, the processing entities should be authorized as recycling facilities, which requires a lengthy and expensive process that should be simplified. Recycling facilities are also in charge of the batteries transport (“waste transport”) and subject to additional financial and logistical burdens that also needs revision. The repurposing and reuse of EV batteries in stationary applications will enhance sustainability and reduce costs however, is not addressed by the current Extended Producer Responsibility (EPR) definition, causing difficulties in the promotion of second-life applications. Enel firmly considers that there should be a transfer of EPR obligations from the original producer to the responsible for the new status. The current BD allows the export of waste batteries outside the EU as long as the receiving country can provide similar recycling facilities (without specifying recovery targets). The definition of these recovery targets along with a clarification of EPR responsibilities would help to manage battery’s export. Nowadays, the existing BD is significantly overlapping with the End-of-Life Vehicles Directive and REACH Regulation; thus impeding the development of an independent, domestic battery manufacturing and recycling industry. Thus, Enel will strongly welcome a common EU Battery Strategy ensuring a sustainable regulatory framework for batteries. As among the most relevant impacts are the use of raw materials and the alignment with climate goals; Enel would be in favor of setting reporting obligations and/or thresholds on environmental impact and, on responsible sourcing of raw materials. The carbon footprint threshold should be based on calculations considering the energy mix used at the production phase and the transportation of raw materials (from mining), proven by the appropriate documentation. In addition, renewable energy and batteries must be managed in a circular economy perspective, therefore avoiding the risk of creating new energy dependencies in the energy supply chain. Second life batteries will build a competitive advantage for EU batteries responsible production, however, technical difficulties to integrate repurposed cells in the grid are a hurdle for the development of stationary applications so, we urge the EC to help the industry in developing an easier solution to accommodate batteries in the grid. Taking the next step, Enel deems fundamental the establishment of a digital tracking and identification system (a ‘digital battery passport’) for the entire life and changes of ownership of each battery on the market, which we consider especially relevant for EV batteries, containing information about battery’s health (residual capacity, cycles, efficiency, damage), history and chemistry. The registry could help to reduce recycling costs by decreasing complexity, resolve the problem of orphan batteries, speed-up the repurposing process, and reduce testing times. To take the utmost from the EU’s battery registry, we encourage the EC to boost the development of a technical solution interoperable with the on-board devices able to disclose the battery’s health.
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Meeting with Adina-Ioana Vălean (Commissioner) and

1 Jul 2020 · Sustainable and Smart Mobility and EU Recovery Fund

Response to Commission Communication – "Renovation wave" initiative for the building sector

8 Jun 2020

The Enel Group strongly welcomes the Commission’s Roadmap for a “Renovation Wave Initiative for Buildings” as one of the main pillars of the EU’s fight against climate change. Action is urgent in the building sector as the sector is lagging behind in the process of decarbonization despite its significant potential. Electrification through mature electric technologies such as solar panels and heat pumps offers important opportunities for decarbonizing the building sector. Building renovation needs to rapidly become much deeper, structurally incorporating Demand Side Response and dynamically interacting with the electricity sector. Ever smarter buildings need to digitally interact with ever smarter grids helping to maximize system wide efficiencies that will increasingly be characterized by millions of supply and demand points. Synergies between the building and the transport sector need to be sought out more aggressively. The transformation required in the building sector needs to be pursued through a Circular Economy approach tackling the significant non-economic barriers along the value chain. Accelerating the rate of renovation in the EU building sector calls for the deployment within a just transition framework of a diverse set of policy measures. The latter range from targets to administrative simplification for permitting, from standardizing financing procedures to strengthening building standards, but also include fiscal incentives and actions aimed at abating non-economic barriers. Please see the Position Paper attached to the consultation reply for further details on the Views of the Enel Group
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Response to A EU hydrogen strategy

8 Jun 2020

Hydrogen is best used as a complement to electrification, not a competitor: electrification offers the cheapest and the most efficient route to decarbonize light-duty transport, heating and many industrial processes. Hydrogen has an efficient role to decarbonize those parts of the economy that cannot be easily or economically electrified, the hard-to-abate sectors: heavy industry, aviation, long-distance heavy-haul road and maritime transport. Europe cannot afford to waste resources promoting its use in sectors that can be decarbonized at a lower cost with electrification. A Guarantees of Origins system and an unequivocal and transparent taxonomy for the different routes to produce hydrogen, based on GHG emission and the origin of the input (RES/not RES) is a precondition for an effective regulatory framework and to provide the correct market signals on the “greenness” and the sustainability of gases. Hydrogen needs to be renewable, produced via electrolysis fed by 100% RES power (H2 RES), this is the only sustainable production pathway at zero GHG emissions. To overcome the current extra-costs with respect to other ways of producing hydrogen, transitory supporting tools could be introduced. On the contrary, blue hydrogen relies on natural gas, a non-renewable imported energy source, emits GHG for the share of CO2 it cannot capture and for methane leaks. It hampers the transition by contributing to locking-in into fossil fuel infrastructures and doesn’t represent a viable pathway due to the current lack of CO2 storage capacity (currently this capacity is estimated at 1,7 M tonnes/yr) and the limited deployment expected in the coming years (also due to the uncertainty on the environmental effects of CO2 underground storage and adverse public opinion). Efforts should be focused on developing EU domestic production of H2 RES that can improve the security of supply and lower a country/region’s dependency on fossil fuel imports. Conversely, importing H2 RES from third countries means substituting one imported energy product with another. H2 RES production can help accelerate the decarbonization of the power sector if it comes from electrolyzers coupled with grid-connected renewable power plants. Co-locating electrolysis and RES plants feeding power to the grid is a true energy system integration enabler that allows RES to more effectively balance the power system, providing new sources of flexibility boosting the transition. A mandatory target on blending hydrogen in the gas grid would be an inefficient policy option. The blended hydrogen would end up feeding final uses for which other more effective and efficient decarbonization options already exist, creating lock-in effects into gas-based technologies (e.g. in the heating sector, where buildings insulation and electric heat pumps have higher CO2 emissions reduction potential at a lower abatement cost). A more efficient policy option to support the scale-up of H2 RES production could consist in prompting hard-to-abate energy end-use sectors - via market based tools - to decarbonize their activities via H2 RES, while protecting their competitiveness. A prompt development of a new hydrogen network or the extensive retrofitting of the existing gas infrastructure should be avoided. A staged-in approach is recommended to ensure the decarbonization process sticks with the least-cost pathway, minimizing the risk of stranded assets: the first deployment of hydrogen projects should start from production as close as possible to the consumption point, relying on short pipeline connections; thus gas pipelines retrofitting should initially be limited to small sections connecting large hydrogen demand points from off-takers that can use hydrogen as an efficient decarbonization solution and the closest high RES resource location for hydrogen production. Hydrogen production is a competitive activity: it should be carried-out by market players to let consumers enjoy the benefits of competition.
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Response to Revision of the guidelines for trans-European Energy infrastructure

8 Jun 2020

TEN-E’s priorities and eligibility criteria have been defined in 2013 and so the current regulation is no longer fully in line with the evolution of the energy system and with the new policy priorities. TEN-E networks should not only reflect the energy transmission but also the distribution and energy customer solutions landscape of tomorrow, including smart grids for distributed energy resources (i.e. storage, EVs as V2G), demand side management and sector integration. TEN-E regulation should facilitate the needed investment by broadening its scope of cross-border projects to local, decentralized and participative smart grid projects and phasing out the support to project no longer aligned with the EU climate goal.TEN-E regulation should avoid supporting energy infrastructure that might not be future proof with the new policy goals. TEN-E regulation largely foresees support to new projects related to Natural gas. In amending TEN‐E regulation it will be crucial to ensure that the selection of the best‐value technologies for decarbonization is made on sound economic principles. Hence, given the significant uncertainties on the evolution of the demand for gas new investment decisions in gas infrastructure should be carefully assessed. Due to the uncertainties and local character of the potential demand of hydrogen in this incipient phase of sector coupling technologies it is definitely premature to know if a dedicated hydrogen network will be needed. Europe should carefully evaluate the relevance of such infrastructure before plan for launching large development of a new hydrogen infrastructure or extensive retrofitting of the existing gas infrastructure. It is paramount to amend the specific evaluation criteria for the inclusion of lower voltage lines up to 150 kV to include all electric transmission infrastructures in the PCI list and apply the same criteria to the projects included in the TYNDP and in any other following list. Such amendment could be useful to the reduction of congestions, increase in exchanges through additional network capacity, market integration and support the development of private investments in the power transmission sector. To support the integration of small scale distributed energy sources, distribution system operators are increasingly investing in new digital-based technologies aimed at improving operating efficiency, ensuring security of supply and preparing the system for the growing penetration of distributed generation and flexibility sources, such as rooftop solar, battery storage, demand response and EVs. The deployment of smart grid solutions, enabling flexibility services for the congestion relief and management, responds to an operational necessity for both distribution and transmission network. Most projects in this field do not comply with the criteria set out in the Regulation, as they concern LV and MV infrastructure, and/or only involve one Member State and have a limited cross-border impact. In order to be aligned to the energy transition goals and bring specific support to new business models and advanced technologies in this context, barriers should be alleviated to allow more smart grid projects to become PCI. Synergies project between energy, transport and digital sectors shall be made as a priority of TEN-E. The industry shows increased interest in investigating and experimenting synergies e.g. between high power charging for EVs and medium-voltage level energy storage to provide long-term benefits to the overall system reliability, sustainability and efficiency. Regulatory misalignment between different Member States (where present) still slow down the authorization process and PCI status does not overcome this obstacle, for instance, in case of interconnection project the exemption under the EU regulation is needed before obtaining the MS authorizations in Austria while in Italy the opposite. Revision of TEN-E with the aim of tackling these issues is of paramount importance.
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Meeting with Mauro Raffaele Petriccione (Director-General Climate Action)

19 May 2020 · Climate policy developments

Meeting with Thierry Breton (Commissioner) and

4 May 2020 · Impacts of the COVID-19 Pandemic on the Renewable Energy Sector

Response to Revision of Alternative Fuels Infrastructure Directive

30 Apr 2020

The current directive fails to mitigate the environmental impact of transport, since many of the alternative fuels currently allowed emit CO2 since some of them are pure or derivate fossil fuels. The current directive does not set the adequate framework to achieve long-term EU CO2 emissions reduction objective, as it does not adequately support the deployment of zero emission mobility. The analysis of the NPFs revealed differing levels of effort, ambition and available funding between Member States. The deployment of recharging infrastructure can fall short to pace with the EV market development and to be comprehensive and evenly distributed at Union level. It becomes evident that NPFs are not coherent at Union level and this can lead to a market fragmentation preventing the development of economies of scale on the supply side and Union-wide mobility on the demand side. The DAFI should mandate infrastructure targets only for zero emission transport modes in order to reach the 2050 climate neutrality goal. In particular, zero emission electric mobility is key to achieve the European decarbonization goals. Electric battery vehicles allow transferring downstream the benefit of the decarbonization of the power sector. Zero emission electric mobility brings benefits beyond decarbonization such as reduced local pollution, noise, and import dependency on imported fossil fuels. More effective policy instruments to enforce targets for the deployment of charging points should be considered. The revised directive should enforce binding targets per each Member State for each category of charging point: slow, fast and ultrafast. The target of one charging point every 60 km on the TEN-T Core Network by 2025 should be further enforced and made binding. In addition, binding targets should be set for the TEN-T Comprehensive network in urban, and near urban areas with full coverage mandated by 2025 (at least one site every 60 km by 2025 at the latest). Indeed the Comprehensive Network is a further pain point that will need to be addressed quite urgently by the revised Directive, fostering zero emission vehicles uptake also in regions not covered by the Core Network, hence bridging the gap in terms of social and economic disparity. Infrastructure for heavy duty vehicles will be crucial to decarbonize road freight, road passenger and public transport. Several EU-level actions have been taken to stimulate supply of electric trucks or buses however action on power supply infrastructure is still missing. Binding targets for on-shore power supply (OPS) infrastructure deployment in seaports and inland ports should be enforced per each Member State. Smart charging services are paramount to efficiently integrate EVs into the electricity system. Smart chargers (charger V1G ready) shall be the minimum requirement for all the public and private charging points. Promotion within Member States of three different financial instruments to support the financial sustainability of public charging infrastructure: funding (e.g. CEF), low-interest financial loans (e.g. through EIB) and OpEX aids (e.g. through the definition of proper tariff for the regulated components of recharge service as well as including charging infrastructure clean fuel credits where the operator of charging infrastructure can sell credits to fossil fuel suppliers. Charging an electric vehicle is a unique and comprehensive service and not a mere supply of electricity. Uncertainties and additional requirements coming from the classification as a supply of electricity (indeed interpretations greatly vary within some Member States in different areas of legislation e.g. definition for electricity directive vs VAT directive purposes) could cause unnecessary additional barriers and hinder electromobility players to make cross border business in the EU and slowing down the deployment of affordable electromobility services.
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Response to Climate Law

30 Apr 2020

• Enel fully supports the EU’s efforts to increase its 2030 climate ambition • Enel welcomes the proposed Regulation on European Climate Law (ECL) enshrining the climate change challenge at the core of the European Green Deal (EGD) • Enel welcomes the framework for the irreversible and gradual reduction of emissions and the binding EU target of net climate neutrality by 2050 set by the ECL • The importance of setting forth within the ECL provisions for a possible acceleration of the EU’s path towards climate neutrality is fully shared, although its governance needs to be explored • Enel welcomes the inclusion of the revision of the 2030 GHG emission reduction target in the proposed Regulation • Enel supports the proposed revision of all relevant EU legislation following the revision of 2030 EU climate target • Enel supports setting and updating a Union level trajectory to achieve the climate-neutrality objective through delegated acts, although it needs to be solidly framed within a political process of stocktaking and updating interim targets • Enel supports the periodic assessment of progress at EU and Member State level • The ECL should more explicitly provide reference to the need for a “just transition” The extended feedback is provided in the document attached
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Response to Report on the application of the General Data Protection Regulation

29 Apr 2020

ENEL SpA response The new Regulation is a key enabler for economic growth, job creation, innovation and scientific progress in Europe. Strict data protection rules are necessary to rebuild the trust of individuals in how their personal data is being used. We believe that the GDPR introduces many important improvements from the business perspective by unifying Europe's rules on data protection, creating new business opportunities and encouraging innovation. However Enel underlines that more attention should be paid, to - At present GDPR is working fine, Enel does not believe it has to be modified but EDPB and the DPO’s community has to cooperate to best interprete and support homogeneous implementation of the GDPR in Europe. That is why we look forward to establish a Permanent Group of Global DPO representing European companies with a European turnover (almost 30%) and a worldwide business presence. Collect their experience is essential. The Multistakeholder Expert Group does not take into account this. First, it was created before the GDPR (2017) came into action; second, it does not see the direct participation of DPO’s. The practical experience of DPO of large companies is useful to understand what is working of GDPR and what can be improved by soft regulation from EDPB; - Adequacy decisions must be subject to ongoing monitoring and periodic review, as required by Union law, which is essential to ensure adequate protection of the rights of the data subject. EU should engage more countries to make adequacy decisions and clarify UK situation. - The standard contractual clauses for data transfers to third countries developed under Directive 95/46/EC have not been updated in light of developments since they were originally adopted. - International intra-group data transfer, without prejudice to compliance with the competition and regulatory rules, has to be favoured by a fast track procedure approval of binding corporate rules. - The EDPB guidelines are welcomed, we encourage the Board to continue its work in preventing fragmentation, with more guidance of concrete guidelines in practice and implementation of the certification schemes. - Increase measures in order to encorauge the drafting of codes of conduct by sector stakeholders at European Level; GDPR impacts on European Data Strategy - We believe that the legislative framework for the governance of common European data spaces will determine what data can be used in what situations, facilitate cross-border data use, and prioritise interoperability requirements and standards within and across sectors. - One of the pillars of the new data-driven ecosystems outlined by the new European Data Strategy is a Cross-sectoral governance framework aiming at creating necessary rules for a data-agile economy. There will be the need for legislative action on issues that affect relations between actors in the data-agile economy to • foster business-to-government data sharing for the public interest • support B2B data sharing • seek to identify and address any undue existing hurdles hindering data sharing and to clarify rules for the responsible use of data (such as legal liability). - The current COVID crisis and the need of using personal data for monitoring purposes have accelerated the search for solutions to conciliate privacy rights with the use of data for the common good. These solutions must offer anonymization and pseudonymization techniques aimed at protecting the privacy rights of individual data subjects and allow organizations to balance this right to privacy against their legitimate goals. These solutions must be shared and consolidated in other markets (like US) and must become one of the points in the continuous monitoring of the alignment between EU Data Protection laws and the EU –U.S. Privacy Shield. The same should apply to data protection provisions of China’s Cybersecurity Law. Please, check the position paper enclosed to continue reading our position.
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Response to FuelEU Maritime

24 Apr 2020

Maritime sector is a large and growing source of greenhouse gas emissions and related emissions are projected to increase significantly if mitigation measures are not put in place swiftly. Shipping emissions could increase between 50% and 250% by 2050 under a business-as-usual scenario, undermining the objectives of the Paris Agreement [Third IMO Greenhouse Gas Study 2014]. There is significant untapped potential to reduce maritime emissions, solutions such onshore power-supply (OPS) in ports, electrification of short-range ship are already available even if more expensive than on board generation with fossil fuels. For longer-range ships the deployment of synthetic fuel based on green hydrogen is a less mature solution but represent one of the few viable options in this particular “hard to abate” transport mode. Onshore power-supply allow docked ships to turn off their engines and connect to the electricity grid to power ships. Benefits of shore power facilities include the reduction of ship noise and the reduction of GHG and pollutant emissions allowing the positive spillover effect of decarbonization of power sector into the maritime sector. So far, few Member States have implemented OPS due mainly to tax break granted to fossil fuel and high cost of electricity tariff. Against this background, fossil fuels tax break shall be ended and OPS should be supported enabling the roll out of the related infrastructure that should be deployed on a mandatory basis. While onshore power-supply solutions in ports are already technologically mature but not yet in the money, synthetic fuels based on green hydrogen are a viable alternative fuel and the only future proof solution for fuel longer-range ship in navigation. It combines the positive externalities of zero GHG emission and offer the possibility to have a real form of sector integration between the different economy sectors. To boost the uptake of hydrogen synthetic fuel as a replacement for conventional diesel fuel Europe should promote via its funding programs R&I and first deployment project to support the ramp-up of the production of such carbon neutral fuel to allow a timely cost reduction of such technologies and kick start the green hydrogen market. To achieve a low-emission, climate-neutral shipping and ports it is paramount to create an adequate and supportive framework. -We welcome the initiative to evaluate the possible extension of ETS to such transport mode as an effective and efficient policy instrument to decarbonize this sector -The review of Energy Taxation Directive is pivotal because the current Directive does not take into account the differences in emissions between different energy sources. This phenomena is further exacerbated by the existence of multiple exemptions in different MS which is a form of subsidies on fossil fuels. Energy Taxation needs to be reviewed in line with enhanced climate and environmental objectives. Taxation should encourage the deployment of the most efficient and less polluting energy vectors, thus supporting the EU climate objectives and protecting the competitiveness of EU industry. A transitory exemption shall be considered for the taxation of electricity as a fuel in consideration of the positive environmental and energy efficiency externalities. -A timely revision of Alternative Fuel Infrastructure Directive is paramount. The current directive fails to minimize dependence on oil and to mitigate the environmental impact of transport, since many of the alternative fuels currently allowed in the present release of the directive emit CO2 as it does not adequately support the deployment of effective and climate friendly solution as OPS. -Adequate financing instrument to support the enhancement of the electricity infrastructures to power the port systems are paramount to exploit fully the potential of OPS.
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Meeting with Kadri Simson (Commissioner) and

22 Apr 2020 · Introduction of Enel, decarbonization and digitalization, sustainable investment, recovery and upcoming EU energy initiatives.

Response to EU rules on industrial emissions - revision

17 Apr 2020

The successive policies applied in the EU to prevent pollutants emissions from the production of energy in large combustion plants have demonstrated to be significantly successful. According to the EEA data, the EU Public electricity and heat production reduced SO2 emissions by 65% over the period 2000-2010, mostly due to the IPPC directive. Furthermore, SO2 emissions declined by an additional 21% from 2010 to 2017, because of the implementation of industrial emissions policies at EU level, including the Industrial Emission Directive 2010/75/EU. NOx and PM2.5 also experienced significant reductions in the 2000-2017 period (53% and 65% respectively). The Industrial Emission Directive has already avoided the emission of thousands of tons of pollutants into the atmosphere and has improved the quality of life in industrialized areas, by promoting considerable investments in retrofitting fossil fuel-fired power plants and low/zero pollutant-emitting technologies (e.g. RES and combined cycles). We deem the current form of the Industrial Emission Directive fit-for-purpose in the power sector and actions should be now focused in the end-uses of energy. The corresponding evidence is unquestionable as related air quality measurements have constantly improved over time. Actions to improve air quality should now focus more on end-use sectors often lagging behind, such as transport and residential. The goal must be to reduce exceedances of pollutant concentrations limits, particularly in urban and semi-urban areas where most of the population lives. Furthermore, we consider it still too early to perform a revision of the Industrial Emission Directive, as several of its relevant provisions are still under implementation and its fully realized potential not yet observable. Regarding flexibility mechanisms, the Directive introduced a transitional period (between 1 January 2016 and 30 June 2020) for the enforcement of its limit values via Transitional National Plans. This means that for many installations the Directive’s limit values are not yet implemented. As for the Large Combustion Plants Commission Implementing Decision (EU) 2017/1442 establishing Best Available Techniques (BAT) conclusions, the impact of their adoption on the improvement of air quality cannot be quantified as the new limits will apply starting August 2021. Nevertheless, the provisions still under implementation are expected have a noteworthy positive effect on emissions reduction. However, given that the Commission has set forth a clear roadmap to review the Industrial Emission Directive by 2021, we would like to provide the process with the following general recommendations: • The synergies with circular economy, decarbonization of the EU economy, sectoral coupling and clean energy policies need to be carefully assessed. • New efforts must be proportionate to the expected results without endangering the sustainability of the system and the coherence with other EU legislation should be kept. • For large combustion and incineration plants, the revision of the IED should avoid existing overlaps with BREF requirements. • The aggregation rule should be better clarified to avoid arbitrary application by competent authorities from overburdening environmental monitoring activities. • The Commission needs to provide guidance to Member States and to their Competent Authorities on Large Combustion Plants BAT-BREFs implementation into practicable licenses through a robust and consolidated mechanism. This would be paramount to ensuring a level playing field across Europe. Please check the attached paper in support for further details.
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Response to 2030 Climate Target Plan

15 Apr 2020

Enel fully supports the EU’s efforts to increase its climate ambition and strongly welcomes the Commission’s Inception Impact Assessment (IIA) initiative. Enel supports EU climate neutrality by 2050 and increased 2030 ambition. Upscaling climate action will deliver substantial benefits in terms of economic and resource efficiency, reduction of global and local pollution, resilience to economic, technological and environmental change. Enel itself is committed to decarbonizing its global activities well before 2050. Improving on past exercises, the IA should take into account all three dimensions of Sustainable Development, focusing on the social dimension and on the means of ensuring a Just Transition for Europe. The paths ahead should be assessed against the full set of SDGs along the: A) Social dimension – The relevance of this area has recently emerged through the just transition debate and has become urgent in light of the ongoing global pandemic. Enel supports the preliminary scoping of the IIA and recommends special focus and improved methodologies in exploring co-benefits as well as employment and distributional impacts, especially in light of the apparent lack of adequate data and modelling tools.  Economic dimension – In this area within the IIA scope the greatest challenges arise in the areas of competitiveness and investment flows, where the EU’s role within global low carbon supply chains and the issue of stranded assets play key roles. Apparently not included in such scope are two key areas: infrastructure digitalization requirements needed to drive system level synergies (e.g. smart grids, network digitalization for automation, monitoring and control DERs flexibilities); EU level interconnection necessary to ensure resource pooling (e.g. RES generation). More needs to be done in modelling the positive effects of increased digitalization of electricity grids.  Environmental dimension – Accelerated decarbonization can be achieved only if the full set of sustainable development benefits it generates are aligned. The IA should not reserve to “co-benefits” the limited role assigned to them in past. Environmental issues such as air quality, resource efficiency, circular economy will have a very important role in driving the energy transition. In light of their perceived urgency among EU citizens, co-benefits should enjoy a greater standing compared to the past. Within a framework of “new technological neutrality”, the IA of specific technologies should consider their full set of potential benefits as well most recent cost reductions while exploring the impact of potential disruptions and resilience to change. The “technology neutrality” concept should evolve and be measured not only against climate change, but also against other SDGs such as air quality and circular economy. On the other hand, the desirable but often yet distant disruption for other key technologies, should be tested against the resilience of context changes (e.g. CCS and H2). The IA should explore cross-sectorial synergies and not limit itself to optimizing individual sectorial contributions. Bridging across sectors is ever more critical as upscaling deployment of low carbon technologies will increasingly require partnerships spanning across industrial boundaries. For the IA to adequately support policy making in identifying the best solutions, it is key that it effectively simulates cross-sectorial spillovers and synergies. The challenge of modelling the impact of instruments choice should be tackled, overcoming the difficulties of simulating policy performance/delivery. The rigidity of command&control measures as opposed to the flexibility of economic instruments should be considered. The synergies of different policy instruments should be taken into account. The ability of models to adequately simulate the performance of the full set of existing policy mechanisms should be scrutinized, especially in terms of distributional social impacts.
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Meeting with Kadri Simson (Commissioner) and

15 Apr 2020 · Risk-preparedness in electricity sector, impact of crisis on clean energy investments, priorities of electricity sector for the upcoming energy initiatives under the Green Deal

Meeting with Frans Timmermans (Executive Vice-President) and Eurelectric aisbl and

15 Apr 2020 · Risk-prepardness in electricity sector, impact of crisis on clean energy investments, priorities of electricity sector for the upcoming energy initiatives under the Green Deal.

Meeting with Daniela Rondinelli (Member of the European Parliament)

5 Mar 2020 · National and european energy sector

Meeting with Marco Piantini (Cabinet of Commissioner Paolo Gentiloni)

23 Jan 2020 · Exchange of views on Invest EU/Green Deal plans

Response to A new Circular Economy Action Plan

20 Jan 2020

Enel, leveraging on its existing commitment on decarbonisation and transition to a sustainable business model, already included Circular Economy as a strategic company driver more than four years ago. In the Enel vision, the circular economy is not only about ‘end of life’ but about reimagining the whole value chain through innovation in order to decouple business activities from not renewable resources consumption. The Enel approach to both decarbonisation and circular economy is essentially an integrated one. To implement the transition along the whole value chain, we are at first strongly decarbonizing our production mix. Our commitment is science based and in line with the requirements of the +1,5C scenario. Besides that, we are managing the decommissioning of our ‘end of life’ thermal plants in a circular prospective. Moreover, we are applying Circular Economy all along the whole value chain: - Suppliers: since three years we have launched a project to improve the circularity of what we buy, through metrics, k factors in tendering and co-innovation with suppliers. Circularity has to start from the true beginning. - Assets: besides decarbonizing the sources we are working on the circularity of our assets (networks and generation) along the whole value chain (design, construction, lifecycle, decommissioning). - Clients: Enel X, our division in charge of all product and services to clients besides the commodity (e.g. electric mobility, home solutions, industry solutions) has placed circular economy as a driver both in reimagining its offer and in supporting clients transition toward circularity also through a metrics based assessment. Another relevant field of engagement has been the metrics. We developed our model - the “Circulability model”-, systematically applied it throughout our activities and made it public. Enel warmly welcomes the Commission roadmap initiative to publish a new Circular Economy Action Plan in the first quarter of 2020. The roadmap represents a step forward from the previous circular economy action plan, as it intensifies efforts not only on waste but with a much wider scope in a wider value chain perspective. We agree with its focus and scope and we appreciate that now Circular Economy is approached in a strategic way, along the whole value chain. Even though, we think that it what is still missing is a stronger integration between circular economy and decarbonisation: awareness is growing of the close relation between these two issues and last COP 25 has perfectly shown it. Therefore, in the above we would like to provide the roadmap process of the Circular Economy Action Plan with the following guidelines and recommendations: • Circular economy is a key lever in order to reach decarbonisation targets. Recent studies esteem that its contribution could be of the same order of magnitude of renewable energy and efficiency. Integrating both approaches will help meet the goals of the Paris Agreement and increase the resilience of our economies • Renewable energy should become a pillar of any circular economy initiative. • Renewable energy and batteries -now that are becoming mainstream and reaching huge volumes of capacity-, must be managed in circular economy perspective. • Develop tailored regulations fit for the circular economy. • Develop rigorous circular economy metrics. • Drive the cultural change towards a society prone to circular economy attitudes. • Place circular procurement at the core of the circular economy. • Promote circular design and extension of the useful life to maintain the value of assets and goods. • Focus on sustainable innovation. • Promote circular economy in urban environments, as cities are the protagonists of change. • Support the transition of industrial chains. • Reconsider the waste hierarchy for secondary raw materials. Please find further details on the recommendations provided in the attached file.
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Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis)

13 Jan 2020 · Sustainable finance

Meeting with Miguel Arias Cañete (Commissioner) and Eni S.p.A. and

6 Jun 2019 · Long Term Strategy

Response to Evaluation of the Alternative Fuels Infrastructure Directive

20 Mar 2019

The Directive 2014/94/EU was adopted at a time when the market of alternative fuel vehicles was still an emerging market. In 2018, a major milestone was reached as Europe accounted for its first million electric vehicles on the road and the future market outlook is promising. Nevertheless, according to the latest IPCC special report, the next years are critical for curbing CO2 emission: if action is insufficient in the short-medium term, it will likely be impossible to make up for the deficit later, this requires a substantial decrease in CO2 emissions and a faster transition to zero emission mobility. The current directive does not set the adequate framework to achieve long-term EU CO2 emissions reduction objective as it does not adequately support the deployment of zero emission mobility. Therefore, we call for its revision, in 2020. The EU must now accelerate the deployment of charging points on the TEN-T core, comprehensive network and also in urban and near urban areas (also outside the TEN-T core network), where vehicles are being used for most of the time. Investing into these areas will produce also knock-on effects for the deployment of recharging infrastructure. We recommend the following more specific issues to be addressed: To support the full decarbonisation of the road transport sector. Many of the alternative fuels currently allowed in the current directive emit CO2, sometimes as much as or even more than fossil fuels, while some are pure fossil fuels. The AFI Directive shall mandate infrastructure only for zero emission transport modes in order to reach the 2050 climate neutrality goal. Zero emission electric mobility is key to achieve decarbonization goals. Electric vehicles allow transferring downstream the benefit of the decarbonisation of the power sector and are significantly more efficient than alternative vehicles. Zero emission electric mobility brings benefits beyond decarbonization such as reduced local pollution, noise, and import dependency on imported fossil fuels. In this context, the price of the recharge service for electric vehicles assumes a fundamental role. The price for electricity is the main cost element of the recharge service and strongly depends on the regulated components. The European Commission should guide Member States to set proper tariffs for the regulated components to be applied to recharge points in order to allow competitive recharge service prices. To set binding minimum targets per Member State for the deployment of public electric charging infrastructure, reflecting the diversity of charging infrastructure options. The European Commission and Member States should consider new metrics and methodologies to assess the right geographical coverage of infrastructure to meet the demand of EV drivers. Target of one charging point every 60 km on the TEN-T Core Network should be brought forward from 2025 to 2022 and made binding. In addition, binding targets should be set for the TEN-T Comprehensive network in urban, and near urban areas with full coverage mandated by 2025. The current indicative target of one public charging point for 10 electric vehicles should be enforced densely populated areas where a growing number of EV drivers will not have access to a private garage or parking. The charging infrastructure shall be equipped with smart technology that enables smart pricing and by extension smart charging, the precondition for successful and cost-effective EV grid integration. This would be essential to enable e-mobility to provide services to the electricity grids when a significant number of electric vehicles will be on roads. On-shore power supply (OPS) infrastructure should be deployed on a mandatory basis. So far, few Member States have implemented OPS, which can provide significant air quality improvements close to seaports and inland ports, due to tax break granted to fossil fuel. OPS should be rewarded and supported to level the playing field with fossil fuel.
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Response to Evaluation of the 2011 White Paper on Transport

7 Mar 2019

The 2011 White Paper defined a long-term vision for a transport sector. It aimed at completing the internal market for transport, where considerable barriers remain, reducing Europe's dependence on imported oil and cutting CO2 emissions from transport by 60% by 2050. Taken the latter into due consideration, the initiatives launched to implement the white paper’s goals - “European Strategy for Low-Emission Mobility” in 2016 and the “clean mobility packages” in 2017 and 2018 - have contributed to move forward in the right direction, but many initiatives remain aspirational and have not been translated into concrete actions. According to the latest IPCC special report, the next 12 years are critical: if action is insufficient in the short-medium term, it will likely be impossible to make up for the deficit later. Moreover, the 2050 60% target for the transport sector was defined considering a long-term objective of reducing EU’s CO2 emission by 80%. The latter is not consistent with the “well below 2°C degree” goal. This means that the 2050 CO2 emission reduction target for the transport sector has to be revised upwards in order to achieve the Paris Agreement Goals. It should be considered also that an increasing number of governments, civil society organisations, industrial leaders as well as the European institutions are calling for carbon neutrality by 2050 in order to limit the increase in temperature to 1.5 °C. In the transport sector, this requires a substantial decrease in CO2 emissions and a faster transition to zero emission mobility. A new comprehensive European roadmap for the transport sector is needed to accelerate the transformation required. It shall take into account the technological innovation (i.e. fall in the batteries cost, improvement of batteries performance, increase of electric vehicles models in all categories, technologies for EVs grid integration) and consider along with decarbonisation also the other benefits that each technology can bring (e.g. improved air quality, increased energy efficiency, enhanced security of supply). Accordingly, we recommend the following more specific issues to be addressed: Accelerate the phase-out of combustion vehicles and the transition to zero emission mobility in all road transport mode. Zero emission electric mobility is key to reduce local pollution and to achieve decarbonization goals. Zero emission electric vehicles allow transferring downstream the benefit of the decarbonisation of the power sector, increasing the overall efficiency and reducing the Europe's dependence on imported fossil fuels. Focus on to the strengthening and digitalization of electricity distribution grids as well as to the deployment of recharging infrastructure along core highway network, cities and near urban areas (inside and outside the TEN-T core network), as they are a crucial catalyst for the deployment of zero emission electric vehicles. Remove the tax exemption for on-board diesel-electricity generation as it deters actions to improve energy efficiency and reduce emissions. So far, only a few Member States have studied the possibility to implement on-shore power supply (OPS), which can provide significant air quality improvements close to seaports and inland ports, due to tax break granted to fossil fuel. Shore side electricity should be able to compete on equal basis with on-board electricity generation. Review transport taxation by linking vehicle taxation to environmental performance and internalising external costs (noise, local pollution and congestion). Current VAT system and fuel taxation should be reviewed to foster the deployment of zero emission vehicles. It might be considered a transitory exemption for the taxation of electricity as a fuel in transport, especially in the incipient phase of the e-mobility market, and the removal of the additional taxes and levies not related to the cost of supplying and serving the electricity to the consumer.
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Meeting with Bernd Biervert (Cabinet of Vice-President Maroš Šefčovič)

11 Dec 2018 · Reform Electricity Market Design, 2050 Strategy

Meeting with Stefano Manservisi (Director-General Directorate-General for International Partnerships)

11 Jul 2018 · Exchange on the EU projects on renewable energy in Africa.

Meeting with Telmo Baltazar (Cabinet of President Jean-Claude Juncker) and ELECTRICITE DE FRANCE and

9 Jul 2018 · Energy Union and Climate Strategy

Response to Post 2020 light vehicle CO2 Regulation(s)

26 Mar 2018

Enel welcomes the proposal as a necessary instrument to reduce emissions from the European transport sector. However, it needs to be improved to enable the EU to meet its long-term emission reduction targets, effectively address air quality issues and foster Europe’s industrial growth: •More ambitious standards targets – at least 25% reduction by 2025 and at least 50% reduction by 2030 – to put Europe on track to reach the long-term goal of reducing by 60% transport GHG emissions by 2050 compared to 1990. Applying proposed standards means jeopardizing the achievement of the 2050 GHG emission targets, forcing further reductions in other non-ETS sectors, not reaping the benefits of improved air quality. Also findings of independent relevant reputable studies (e.g. CE Delft and ICCT) support this position. •The threshold for zero and low-emission vehicle definition should be lowered to 40 g/km for vans and 25 g/km for cars. The revision for the Clean Vehicles Directive sets lower thresholds for clean vehicles. The definition provided in this regulation for ZLEV should be aligned to the threshold proposed in the Clean Vehicles Directive, in order to encourage the adoption of cleaner technologies. •A “ZLEV mandate” requiring manufacturers to sell a minimum proportion of ZLEV of at least 20% at 2025 should be introduced, along with a credits trading scheme for flexibility in fulfilling obligations. Non-compliance penalties are necessary to ensure the mechanism is effective. The impact assessment does not properly justify the discarding of a mandatory quota for ZLEV. The proposal would lead to a ZLEV sales share lower than the benchmark in both reference years (2025 and 2030), which shows the proposal is weak. A stricter mechanism would ensure that Europe does not lose track in the innovation path for ZLEVs, while supporting Europe’s GDP and jobs increase. A ZLEV mandate will give a clear signal to the whole sustainable mobility ecosystem on the direction Europe is taking. By providing more certainty to investors, this will lower the cost of the infrastructure necessary to its deployment (e.g. charging infrastructure) and support the development of new European value chains, i.e. batteries manufacturing, promoting Europe’s industrial growth. It will also help Europe to catch up with global competitors such as China and the U.S. that moved first in the transition towards more sustainable transport technologies. An accompanying credit trading mechanism can provide flexibility for compliance and stimulate competition promoting new entries of pure ZLEV manufacturers in the market. To be on track with the objectives of the transport white paper to phase out conventionally fueled cars in cities by 2050, the regulation shall set a ZLEV mandate of at least 20% at 2025. Then an intermediate target to 2030 of minimum 50% will be required to allow reaching a close to 100% ZLEV new sales quota in 2035. Considering an average 15-year vehicles lifetime, this is the necessary path to fulfil the long-term target to 2050. The review of the regulation, foreseen by the proposal, could be used to adjust the 2030 target to the uptake of ZEVs in the early 2020s. •Although an improvement has been made going from NEDC to WLTC test cycles, targets should be backed by a transition to a real driving-emission test. In order to avoid uncertainties, loopholes and prevent cases like the diesel gate, a transition to a real driving-emission test should be introduced after 2025. •Monitoring and reporting on the effectiveness of this regulation should be reinforced. Efforts of reducing CO2 emissions in transport of current regulations have been undermined by the divergence between emissions from tests (NEDC test) and real world emissions. The governance of the European Union in effectively cutting transport emissions needs to be restored. The Commission should be empowered to react in advance in case of demonstrated lack of effectiveness of the new regulation.
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Meeting with Miguel Arias Cañete (Commissioner)

15 Mar 2018 · Clean Energy Package

Meeting with Ann Mettler (Director-General Inspire, Debate, Engage and Accelerate Action)

14 Mar 2018 · Sustainable Development Goals

Response to draft proposal on the promotion of clean and energy-efficient road transport vehicles

23 Jan 2018

Enel welcomes the Clean Vehicles Directive proposal as through public procurement it can effectively support clean vehicles market uptake and the reduction of CO2 and air pollutant emissions. Under a technology neutral approach, it defines a framework enabling public authorities to lead by example in the transition to a more efficient and sustainable European transport sector. However, in order to make the framework more effective, Enel would like to bring to your attention the following recommendations: - Further widen the scope of application to include taxi services and further waste collection services - Increase the level of procurement targets for clean cars and vans; taking into consideration the expected cost reduction, setting targets close to 100% for all Member States should not represent a financial burden. - For trucks and buses, the procurement targets for 2030 should be reviewed in light of the upcoming CO2 emission standards. - More in general, given the rapidly evolving EV and battery market it is key that the Clean Vehicles Directive is regularly reviewed (e.g. every 2 year) to flexibly cope with technological improvement in low and zero emission mobility. - For heavy-duty vehicles, the Directive proposal envisages that those with zero emissions at tailpipe or fully operated on biomethane shall be counted as 1 to contribute to the mandate up until a minimum procurement mandate of 50%. In or opinion, only those with zero emissions at tailpipe should be counted as 1, regardless the minimum procurement mandate of the Member State.
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Meeting with Friedrich-Nikolaus von Peter (Cabinet of Commissioner Violeta Bulc)

11 Oct 2017 · Meeting regarding the action plan on alternative fuels.

Response to Evaluation Energy Taxation Directive

26 Sept 2017

As general principles, the revision of the Energy Tax Directive should aim at encouraging the deployment of the most efficient and less pollutant energy carriers. Taken the latter into due consideration, and the effect of other EU policies, it shall also aim at creating a level playing field among the different energy products. Accordingly, we recommend the following more specific issues to be addressed: - A transitory exemption shall be considered for the taxation of electricity as a fuel for transport. Taxing it in an incipient phase of the market would establish a further barrier to EVs deployment and prevent market uptake, jeopardizing the transport sector decarbonization. Once the market is established, the taxation of electricity should be the same disregarding its use, to avoid issues related for instance to households equipped with a charging point and to avoid undue discrimination between the costs of charging EVs at home and at publicly available recharging stations. - A tax exemptions shall be considered for (the share of) renewable electricity to account for the positive externalities associated (e.g. no air pollutants and no costs for public health, no CO2 emissions). - The fact that electricity generation is subject to ETS and to air pollutants emission control shall be taken into account when establishing minimum tax rates for the different energy products with the aim to create a level playing field. - On-shore power supply (OPS) shall be able to compete on equal basis with on-board electricity generation. The tax exemption for on-board diesel-electricity generation shall be removed as it currently deters actions to improve energy efficiency and reduce related emission.
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Meeting with Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen) and Eurelectric aisbl and Finnish Energy - Energiateollisuus ry

25 Sept 2017 · CO2 emission standards for cars and vans, reform of the Clean Vehicles Directive

Meeting with Daniel Calleja Crespo (Director-General Environment)

22 Sept 2017 · Circular Economy

Meeting with Jos Delbeke (Director-General Climate Action)

12 Jul 2017 · ETS

Meeting with Robert Schröder (Cabinet of Commissioner Carlos Moedas)

11 May 2017 · Commission’s science policy, the EU’s Research Programmes

Meeting with Alessandro Carano (Cabinet of Commissioner Violeta Bulc)

11 May 2017 · exchange of views with high level Enel’s representatives on sustainable mobility policies

Meeting with Maria Elena Scoppio (Cabinet of Commissioner Pierre Moscovici)

3 Feb 2017 · Presentation of ENEL and discussion on possible initiatives in the field of energy taxation and discussion on FTT

Meeting with Maroš Šefčovič (Vice-President) and

18 Jan 2017 · Energy Winter Package

Response to Commission Regulation establishing a guideline on electricity balancing

2 Jan 2017

1. Compared to previous versions of the Guidelines, we welcome the introduction of a clear timetable for the introduction of European platforms for FRR and RR; these deadlines should not be exceeded even if there is a TSOs’ proposal for modification 2. The hierarchy between standard and specific products must be clarified; it is not clear if operationally TSOs are allowed to use specific products only after having demonstrated that standard products are not adequate. In general, it is important that the use of specific products is minimised and connecting TSO should not need to convert bids from specific to standard form and the local rules relating to settlement of balancing actions should be consistent with the central, integrated market. Standard products shall be designed around the minimum performance that can be supplied by service providers and that is yet sufficient to contribute to the coverage of system needs 3. TSOs operate with different philosophies (self-dispatching or central dispatch) and approaches (passive or active) leading to different reserves sizing and activation periods. This may result in uneven levels of SoS and competition, different aggregation possibilities and imbalance areas; these differences should be avoided in order to provide a level playing field. The current proposal penalises market participants under central dispatch. After the Integrated Scheduling Process Gate Closure, the possibility to modify production and consumption plans is greatly reduced 4. Cross-zonal Balancing Energy Closure Time should be shorter than Cross-zonal Intraday Closure Time. Only in this way, it will be possible to avoid reduction of liquidity in intraday markets and gaming between intraday and balancing markets. Moreover, balancing energy should not be activated by the TSO before the XB ID gate closure. Before that, TSOs should only contract long-term (also above 1 year) balancing capacity 5. TSOs should allow voluntary participation of all BSPs to the supply of all balancing products. To guarantee a level playing, a provision obliging TSOs to accommodate a BSP-TSO model should be included in Art. 17.1 6. Under the current formulation, exchange of balancing energy from TSO-BSP agreements is allowed if and only if between the TSOs there is an exchange of capacity. In our view, this limitation should be eliminated because in many cases, TSO-BSP agreements are easily implemented and they allow reaping the benefit from integration of balancing market 7. In order to function properly prices should be able to raise above Value of Lost Load (as correctly identified in article 47). For this reason, article 45 should be redefined in order to avoid trigger shortage pricing that does not reflect VOLL 8. The current draft Guidelines eliminate from art 15 the provision that TSO cannot provide balancing services. In order to be compliant with the unbundling regimes, this limitation should be re-introduced 9. Reservation of Cross-Zonal Transmission Capacity for balancing purposes – if necessary at all – should be open to market parties to take the financial risk and bear the consequences of it, as they do in the Day-ahead time horizon. All available cross-border capacity should be allocated to the market and that reservation by TSOs should be seen as a last resort solution 10. The implementation deadline for ISP should be modified to 2025, according to the New Package. The possibility to introduce derogations should be set at national level not per “synchronous area level” based on CBA provided by the TSO and be accompanied by a stakeholders consultation (similar to 2012 ACER Framework Guidelines) 11. As already seen in the integration of day-ahead markets, the same details of information on bids, demand and supply curves shall be available to market participants 12. Guidelines should ensure the principle that every product should be remunerated, e.g. FCR in different MS
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