OpenLobby.EU
Explore

Energy Technologies Europe

ETE

The Energy Technologies Europe is the voice, at European level, of companies supplying power plants, components and services.

Lobbying Activity

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

17 Sept 2020

Energy Technologies Europe (ETE) represents the suppliers of energy conversion technologies. ETE Members are located throughout Europe and are engineering cutting edge technologies contributing to a clean, secure, and affordable energy supply. ETE is particularly engaged with the future of the EU’s decarbonised industry with a focus on a multitude of technologies ranging from energy efficiency, bioenergy, waste to energy, renewable fuels and Carbon Capture, Utilisation and Storage (CCUS). ETE calls upon the Commission to swiftly undertake the revision of the EU Energy Efficiency Directive (EED) in order for it to fit the wider context of EU’s goal of achieving climate neutrality by 2050. Within the context of the impact inception assessment, ETE believes that only Option 3 will be the adequate policy option forward. Despite the positive results that Option 2 may provide, clear legal action must be prioritised as it will be needed to effectively guide our Union’s efforts towards the 2030 and 2050 targets. For these reasons, ETE believes that the EED requires a revision and an enlargement of its current scope. ETE believes that in order to achieve energy savings, the efficiency measures should be applied across the entire energy value chain: generation, transmission, distribution and consumption. Once these savings are achieved, they will deliver important benefits to EU citizens, including GHG emission reductions and lower energy bills. EU policy-makers need to ensure a level playing field within the energy sector and promote a fair competition between all efficient solutions. In this momentum, ETE argues that Member States should set indicative national energy efficiency targets based on primary energy consumption. Article 3 of the EED states that Members States can use either primary or final energy consumption, primary or final energy savings, or energy intensity to define their indicative national energy efficiency targets. However, suggesting different approaches for setting such targets may lead to different ambitions since national targets also take into consideration specific national circumstances. ETE believes that expressing energy efficiency targets in primary energy consumption will enable the sector to better compare the efficiency of different energy mixes. Using multiple measures and definitions when setting efficiency targets complicate the conversion process of data reported by Member States. Furthermore, using primary energy consumption as a metric allows a country to measure its total energy demand, as consumption of the energy sector itself, losses that occur during conversion, transmission and distribution of energy and final consumption by end-users are taken into account. ETE calls on the EC to review the EED because improved energy efficiency plays a key role in the transition towards a competitive, secure and sustainable European energy system.
Read full response

Response to Revision of the Renewable Energy Directive (EU) 2018/2001

17 Sept 2020

Energy Technologies Europe (ETE) is the European association representing technology providers of state-of-the-art solutions for energy conversion technologies, their components and other related energy services. ETE welcomes the EU’s ambition to raise its climate objectives to reach carbon neutrality by 2050. Concerning the REDII consultation, ETE supports Policy Option 5 since a combination of Options 2, 3 and 4 is the only strategy to appropriately reach climate neutrality. ETE calls upon the European Commission to take into consideration the following policy measures as they are quintessential to ensure a fair and enabling legislative framework for innovative energy technologies necessary for reaching climate neutrality. -Clean Fuels- ETE believes that the overall target of clean fuels should be increased in order to further boost the uptake of all clean fuels in the transport sector and elsewhere. In this impetus, the use of Renewable Fuels of Non-Biological Origin (RFNBOs) and Recycled Carbon Fuels (RCFs) in sectors other than the transport sector (power, heat, chemical and other) should be recognised. ETE urges the EC to set a sub-target for RCFs and RFNBOs in the transport sector so that such fuels will finally be equally incentivised compared to their biological counterpart. RCFs are particularly disadvantaged since they are not recognised as contributing towards the transport target and this specific recognition is left in the hands of MS. -Renewability and Guarantee of Origin (GoO)- Recital 90 of the RED recast mentions that the electricity used for the production of renewable liquid and gaseous transport fuels of non-biological origin should be of renewable origin. In line with this, the EC is empowered by means of a delegated act to develop a methodology that evaluates the renewable share of grid electricity. This methodology should recognise that the renewability of electricity taken from the grid can be proven by the use of Guarantees of Origin as recognised in Article 19 of the RED recast. In addition, ETE urges the European Commission to stick to the principle of using the Member State’s grid as a reference, when grid electricity is used without use of GoO, and apply this consistently throughout its legislative proposals and initiatives. -Additionality- The producer of RFNBOs has to prove not only that the electricity used is renewable, but, according to Article 27, the producer must prove that there is an element of additionality. Renewable Power Purchase Agreements (RPPAs) can provide proof of additionality. However, since curtailment of renewables frequently occurs, any solution that makes use of this otherwise curtailed electricity should be regarded as meeting the additionality principle. Furthermore, it should be ensured that the additionality principle is not applied in a discriminatory way and thus be applied to all energy supplied to the transport sector, including the direct use of electricity. -Integrated processes- As it stands, the existing methodology to calculate the GHG emissions for bioenergy may be interpreted in a way that unjustifiably penalises integrated processes (e.g. the pyrolysis of biomass to make bio-oil in a CHP plant). Therefore, in any methodology for the calculation of GHG emissions of integrated processes, the net energy flows (e.g. between the bio-oil and heat & power production) must be taken into account. Analogous to ensuring low carbon intensity of electricity via the use of GoOs and certificates, ETE proposes that introducing a green certification of heat would help in the accounting process of energy exchanges within integrated processes. ETE calls upon the European Commission to opt for Policy Option 5 outlined in the impact inception assessment of the REDII consultation. Particular focus on Option 4, which requires a revision of the scope (e.g. transport and heating) of the REDII, will be necessary to meet the goals of the European Green Deal
Read full response

Response to Climate Law

29 Apr 2020

Energy Technologies Europe (ETE) represents the suppliers of energy conversion technologies. ETE members are located throughout Europe and are engineering cutting edge technologies contributing to a clean, secure, and affordable energy supply. ETE is particularly engaged with the future of the EU’s decarbonised industry with a focus on a multitude of technologies ranging from energy efficiency, bioenergy, waste to energy, renewable fuels and Carbon Capture, Utilisation and Storage (CCUS). As announced by European Commission President Von Der Leyen, the EU’s focus is on the policies that constitute the European Green Deal. The proposed policies and legislation align with the goal of making considerable advances for speeding up the decarbonisation towards 2030 and achieve carbon neutrality by 2050. As the EU will need to fulfil the promise it has made in signing the Paris Agreement to keep global average temperatures to +1.5°C and avoid a +2°C scenario compared to 1990 levels, it is imperative that the required targets of the Green Deal are enshrined in EU law. Even with the ongoing health crisis, the EU will need to remain focused on these climate objectives and ensure that European economies and industries can swiftly transition to a low-carbon economy in a cost-efficient way. Now more than ever, The European Union must find a way to ensure there is a place for emerging technologies on the market for technologies such as hydrogen, e-fuels, biofuels, RCFs and CCUS technologies. The EU needs to take the opportunity to directly facilitate the market uptake of these crucial decarbonising technologies. This means that next to setting climate targets, clear targets need to be set for these technologies to ensure investors as well as the companies in the supply chain that there is and will be a market for these technologies. ETE calls on the EU to swiftly launch and empower the EU Climate Law to serve as the legal entity that will monitor Member States’ progress concerning their National Energy Climate Plans (NECPs) and guide further collective EU efforts in achieving climate neutrality by 2050. The EU Climate Law should, therefore, contribute towards a low-carbon economy by providing a legal basis for the EU’s climate goals whilst ensuring that measures that lead to real carbon abatements and provide the required market security for emerging decarbonisation technologies are taken.
Read full response

Response to Carbon Border Adjustment Mechanism

1 Apr 2020

The EU’s ambitious climate objectives Many energy-intensive industries are key industrial value chains for the European economy and their pathway towards net-zero greenhouse gas (GHG) emissions by 2050 is likely to be challenging. To meet these ambitious goals, the EU will need to ensure that European economies and industries swiftly transition to a low-carbon economy in a cost-efficient way. A carbon border adjustment mechanism may be needed in order to minimise carbon leakage. As long as no global price for carbon emissions is established and until countries align with the same climate ambitions, a carbon border adjustment mechanism may be necessary to minimise the risk of carbon leakage and incentivise decarbonisation outside of the EU. As we approach Phase IV of the EU Emissions Trading System (ETS) which is expected to increase the carbon price to all-time highs, the real test for European industries and economies is still to come. In preparation for the potential carbon leakage, the EU aims to create an internationally more level playing field for these industries through the carbon border adjustment mechanism (CBAM). As such, the CBAM will be directly complementary to the EU Emissions Trading System (ETS), so the EU must ensure that the EU has an emissions trading system with an appropriate carbon price and adequate rules. Therefore, the current review of the Monitoring and Reporting Regulation (MRR) is quintessential to the successful development of the CBAM. In line with this, an accurate carbon accounting system will be needed. Such an accounting system would need to take into account the benefits related to the use of energy efficient technologies, bioenergy, waste-to-energy, renewable fuels of non-biological origin and CCUS. Specifically, the benefits of all types of CCU need to be recognised. It needs to be understood that many types of mineralisation (next to the recognised precipitated calcium carbonate) can permanently store carbon. Furthermore, the MRR needs to recognise that the capture and use of CO2 in fuels does not lead to additional emissions and that thus these fuels need to be regarded as low carbon or zero carbon when compliant with article 25 of REDII (2018/2001/EU). Finally, the potential of negative emission technologies needs to be revisited. Currently, plants that would capture CO2 from the air or from sustainably sourced biomass complying with art. 29 of REDII and ensure the permanent storage of the captured carbon are not adequately remunerated. These technologies need to be remunerated for their contribution to the decrease of atmospheric carbon levels. Without remuneration, the technologies will struggle to mature and the rollout of these much needed negative emission technologies will be delayed or even completely barred from commercialisation. A CBAM should, therefore, contribute towards a low-carbon and competitive European industrial sector, supporting the EU’s climate goals while acknowledging all measures that lead to real carbon abatements. Energy Technologies Europe (ETE) represents the suppliers of energy conversion technologies. Members are located throughout Europe and are engineering cutting edge technologies contributing to a clean, secure, and affordable energy supply. ETE is particularly engaged with the future of the EU’s decarbonised industry with a focus on a multitude of technologies ranging from energy efficiency, bioenergy, waste to energy, renewable fuels and Carbon Capture, Utilisation and Storage (CCUS).
Read full response

Response to Revision of the Energy Tax Directive

1 Apr 2020

Energy Technologies Europe (ETE) represents the suppliers of energy conversion technologies. Members are located throughout Europe and are engineering cutting edge technologies contributing to a clean, secure, and affordable energy supply. ETE is particularly engaged with the future of the EU’s decarbonised industry with a focus on a multitude of technologies ranging from energy efficiency, bioenergy, waste to energy, renewable fuels and Carbon Capture, Utilisation and Storage (CCUS). The EU’s ambitious climate objectives The Energy Taxation Directive (ETD) must bring a just recognition of the nature and impact current EU energy products have on global GHG emissions. The decarbonisation of the value chains of transport fuels, electricity and energy products will be challenging yet crucial in achieving net-zero greenhouse gas (GHG) emissions. ETE believes that the ETD must incur real change in the way Member States (MS) exercise tax reductions and exemptions on the use of clean fuels. ETE also believes that the revised ETD should contain a form of indexation mechanism to avoid previous mistakes and keep the proposed directive relevant. Energy Taxation Directive, integral to the European Green Deal The ETD will tackle the decarbonisation of energy products and electricity by also supporting electricity generation from renewable sources and the production of low-carbon fuels. In order for the ETD to comply with the aforementioned, Article 15, paragraphs 1 (a) to (e) should be elaborated to include all climate-friendly solutions. These points recommend MS to allow partial or total tax exemptions to electricity from renewable energy, pilot projects for technological developments of environmentally-friendly products and energy products and electricity generated from combined heat and power generation. To address the decarbonisation of energy products and electricity, these technologies have to be further elaborated and others must be introduced in the revised ETD. In Art. 15 (a), it is stated that tax exemptions are encouraged for “fuels of renewable resources”. However, no further mention is given to biofuels or Renewable Fuels of Non-Biological Origin (RFNBO). ETE recommends that the ETD aligns with art. 25 and art. 29 of the RED II to adequately consider RFNBOs and biofuels respectively. In Art. 15 (b), it is specifically stated that electricity generated from hydrogen fuel cells may face tax reductions. However, fuel cells are not the only technology able to use renewable hydrogen. Turbines and some engines are able to use hydrogen as a feedstock and thus need to be included. Therefore, ETE recommends to make a reference to all technologies that consume hydrogen or consume other renewable fuels. Should the EU desire a comprehensive and technology-neutral approach to fuels that align with the RED II (2018/2001/EU) in the greater context of EU climate goals, ETE proposes that article 15 is further elaborated and changed to include exemptions for RFNBOs, biofuels and e-fuels that comply with RED II. Policy mechanisms proposed by the EC ETE endorses the suggested concept of changing minimum excise rates and the inclusion of the maritime and aviation fuel sectors within the scope of the ETD. ETE finds the further elaboration and emphasis on the third policy mechanism proposed; product coverage, to be quintessential to the revised ETD. This product coverage must result in the promotion of low- (or zero) carbon fuels so that they may eventually compete with traditional fossil fuels. We believe that in order to truly decarbonise a sector like aviation, we will need a policy-derived appreciation for low-(or zero) carbon fuels such as biofuels, RFNBOs and e-fuels that are finding notable success in pilot projects.
Read full response

Response to Fast-track interservice consultation on the 'SEIP including a JTM and the JTF"

10 Mar 2020

Energy Technologies Europe, the association representing the suppliers of energy conversion technologies, welcomes the EU’s initiative for the Just Transition Mechanism. The association believes that it is of great importance to ensure a fair energy transition in the regions that are most dependent on fossil fuels. Many of the fossil fuel intensive regions have elaborate infrastructure and a portfolio of assets linked to the production and/or consumption of fossil fuels. However, in the future, these assets and the infrastructure can no longer be used for their original purpose. In order to prevent the impact of the sunken costs and to make the transition as efficient as possible, these assets and infrastructure will need to be converted to service a low carbon economy. For example, current coal power plants can be converted into future biomass power plants. Furthermore, today’s gas infrastructure can be decarbonised by feeding in sustainable biogas or synthetic methane or can be adapted to transport other clean gases such as hydrogen. Making the optimal use of that what is already present will reduce the costs of the transition and also ensures that as many jobs as possible can be maintained while at the same time new jobs are created. In light of these benefits of repurposing assets and infrastructure, we also urge the EU to give due consideration to using part of the existing coal supplies for non-energy purposes that do not involve significant emissions such as the production of graphene, carbon nanotubes and activated coal. The latter warranting significant attention as a capturer of CO2 due to its microporous structure akin to natural geological structures found in CCS processes. Therefore, such projects diverting coal from emission intensive uses to clean uses should be supported. Altogether, Energy Technologies Europe supports the development of the Just Transition Mechanism and is looking forward to contributing to the transition of these fossil fuel intensive regions towards a clean economy while being supported by this new funding mechanism.
Read full response

Response to A new Circular Economy Action Plan

20 Jan 2020

Energy Technologies Europe (ETE) and its members welcome the Commission initiative on Circular economy for a new action plan to increase recycling and reuse of products in the EU. Improving the possibilities to reuse and recycle products can significantly contribute to reducing waste-management issues. However, even with a well-functioning reusing and recycling system in place, there would still be a fraction of waste which cannot be reused or recycled (e.g. due to impurities/degradation of materials). A study published by the European Commission states that “Collection and recycling targets focus on increasing the amounts of recycled materials, not on their quality regarding the absence of toxic substances. <…> legislation does not incentivise activities to decontaminate waste/recycled materials.” To this end, ETE urges to take action on the heterogeneity of the state of play of waste management across EU member states. In particular, ETE remains very concerned about the persisting high landfilling rate of municipal solid waste (MSW). 11 of the 28 EU member states landfill ≥50% of MSW, a long way to the 2035 target of ≤10% MSW landfilling. The landfilling of waste is the least desirable destination for our waste as confirmed by the EU waste hierarchy. It involves increased environmental risks such as the release of the potent greenhouse gas methane, and the potential contamination of waters through the generation of leachate. Action is needed to limit the residual waste streams and avoid landfilling in accordance with the waste hierarchy and the Directive 1999/31/EC on the landfilling of waste . Therefore, Waste-to-Energy (WtE) plants are needed to deal with the residual waste that cannot be reused or recycled. However, the installed capacity of WtE plants remains limited in several EU countries, with countries like Greece, Romania, and Bulgaria having no WtE infrastructure at all but a staggering MSW landfilling rate of 82%, 80%, and 64% respectively. ETE remains convinced that landfilling rates poor performances and limited WtE installed capacity are no coincidence, and advocates for appropriate measures to be included in the Circular economy for a new action plan initiative to make sure all EU countries can replicate the success stories of Germany, Austria, Sweden, Finland, Denmark, Belgium, and The Netherlands, countries with a remarkable MSW landfilling rate of 3% or less. Furthermore, ETE wishes to highlight the role of furnaces in the production industry, where by-products and residues from the production line can be promptly processed within the plant to recover raw materials and energy instead of exiting the site as waste. To this end, ETE believes that this aspect of industrial circularity should be given appropriate recognition in the new Circular economy action plan. Finally, as stated in the EU 2050 long-term strategy, “Carbon, capture and utilisation (CCU) is a technology closely linked with the circular economy” . In light of this, ETE also advocates for the inclusion of CCU in the Commission initiative on Circular economy for a new action plan. Furthermore, ETE believes that to achieve the climate targets it is necessary to ensure the circularity of CO2 which must be enshrined in the new Circular Economy action plan. Please find attached a version with referenes included.
Read full response

Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)

26 Jun 2018 · Present new European Power Plan Suppliers Association

Meeting with Elżbieta Bieńkowska (Commissioner) and

24 Jan 2018 · Exchange of views on Industrial Policy

Meeting with Isaac Valero Ladron (Cabinet of Vice-President Miguel Arias Cañete)

16 Jun 2015 · Developments at EU/OECD

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

15 Apr 2015 · Export Credit Support for coal-fired power plants

Meeting with Jean-Luc Demarty (Director-General Trade)

16 Mar 2015 · OECD export credit support for coal-fired power plants

Meeting with Dominique Ristori (Director-General Energy)

6 Mar 2015 · European Energy Policy priorities

Meeting with Yvon Slingenberg (Cabinet of Vice-President Miguel Arias Cañete)

15 Dec 2014 · ENERGY EFFICIENCY IN THERMAL POWER PLANTS