OpenLobby.EU
Explore

ENERGIA NATURALIS d.o.o. za ulaganje i upravljanje

ENNA

Energia Naturalis d.o.o.

Lobbying Activity

Response to Modernisation Fund - first evaluation of the operating rules

26 May 2025

On behalf of ENNA, a private company actively investing in all renewable energy sources (geothermal, wind, solar) in Croatia, hereby we submit our contribution to the consultation on the first evaluation of the operating rules of the Modernisation Fund. 1. Baseload-Capable Renewables Must Be Prioritized The current evaluation should assess whether the definition of priority investment projects adequately considers energy technologies that provide stable, dispatchable, and weather-independent renewable electricity. The existing priority categories cover renewable electricity broadly, but there is no clear distinction favoring continuous-output technologies that are critical for grid stability, especially in light of increasing reliance on intermittent sources. To ensure system-level resilience and avoid over-dependence on variable generation, the evaluation should recommend a differentiated prioritization that recognizes the unique role of renewables capable of supplying baseload capacity. 2. System Flexibility and Grid Balancing Technologies Should Be Recognised The definition of priority investment areas should explicitly include renewable technologies that contribute not only to decarbonization but also to the structural flexibility of the electricity system. Technologies that can deliver predictable, controllable, and continuous power regardless of seasonal or hourly variation are essential to balancing supply and demand. This becomes increasingly relevant as the share of weather dependent sources expands. The evaluation should therefore consider amending the delineation of priority investments to recognize the dual role of such technologies in both climate mitigation and system operability. After becoming an active participant in balancing the Croatian electricity system in March this year, ENNA Next was the first in Croatia to issue a bid and receive a positive confirmation in the tender for the provision of aFRR+ service - automatic frequency restoration reserve in the direction of increasing production or reducing electricity consumption, with a capacity of 3 MW. 3. Efficiency Assessment Must Include System-Level Benefits The efficiency of the Modernisation Fund should not be measured solely by comparing unit investment costs or short-term climate indicators. Renewable technologies that provide system-level benefits such as grid stability, controllability, and 24/7 power delivery create significant external value not reflected in direct cost metrics. In particular, investments in dispatchable renewables reduce the need for balancing services, capacity reserves, and expensive market interventions caused by volatility. The evaluation should recommend expanding the efficiency assessment framework to include long-term system value, avoided infrastructure costs, and reduced market disruptions. 4. Relevance Must Reflect Strategic Energy Independence and Include Cross-Border System Impact In evaluating the relevance of the Modernisation Fund, it is important to consider not only climate-related objectives but also the EUs strategic goal of reducing dependency on external supply chains. Renewable technologies that rely on diversified, domestic, or EU-based components particularly those not dominated by non-EU suppliers contribute directly to the Unions energy sovereignty and strategic autonomy. The current MF design does not differentiate among renewables based on their exposure to geopolitical risks or external market volatility. The evaluation should consider updating the priority investment criteria to favor technologies that reduce import dependence, enhance internal resilience, and align with the EUs Critical Raw Materials Strategy and REPowerEU objectives. The added value of the Modernisation Fund should include support for renewable energy technologies that contribute to cross-border system stability, long-term market balance, and EU wide energy resilience.
Read full response

Meeting with Ditte Juul-Joergensen (Director-General Energy) and TotalEnergies SE and

20 Dec 2022 · Energy Platform. Bulgargaz, SPP, EPH, DEPA, Geoplin, Eesti Gaas, Enovos, DEFA, Conexus Baltic Grid and GOGC participated as well.

Meeting with Maroš Šefčovič (Executive Vice-President) and

20 Dec 2022 · EU Energy Platform; Bulgargaz, SPP, EPH, DEPA, Geoplin, Eesti Gaas, Enovos, DEFA, Conexus Baltic Grid, GOGC participated as well.

Meeting with Kadri Simson (Commissioner) and

26 Oct 2022 · Joint purchasing options.