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ENGIE

ENGIE

ENGIE is a global energy company focused on low-carbon solutions and the energy transition.

Lobbying Activity

Meeting with Virgil-Daniel Popescu (Member of the European Parliament) and Eurelectric aisbl and

10 Dec 2025 · Conference Debate "The grids package: storage for system strength and affordability"

ENGIE Urges EU to Align Green Taxonomy With Energy Laws

5 Dec 2025
Topic — The initiative reviews the EU taxonomy environmental delegated act to update technical screening criteria.
Message — ENGIE requests that green investment criteria be fully aligned with existing EU energy directives to simplify compliance. They advocate for a grandfathering principle to protect the status of long-term capital investments. The group also proposes using default values for environmental assessments to reduce administrative costs.123
Why — This would lower administrative expenses and ensure long-term regulatory certainty for their infrastructure.45
Impact — Climate groups lose as stricter emission limits for the energy sector would be delayed.6
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Meeting with Laurence Farreng (Member of the European Parliament) and Fédération bancaire française and

25 Nov 2025 · Défis européens des grandes entreprises françaises

Meeting with Maroš Šefčovič (Commissioner) and

11 Nov 2025 · EU-US-China Relations in the Gas and Energy Sector

Meeting with Pascal Canfin (Member of the European Parliament)

28 Oct 2025 · Energy Union

ENGIE urges fair ranking rules for energy comparison platforms

22 Oct 2025
Topic — EU regulation on consumer protection against dark patterns and unfair digital practices.
Message — The organization requests transparent ranking rules for energy comparison platforms, non-discriminatory supplier access, and standard contract presentation formats. They want commercial influence clearly disclosed and separated from objective results.123
Why — This would ensure ENGIE's offers appear fairly on comparison sites without paying for privileged visibility.45
Impact — Comparison platforms lose revenue from paid placement and sponsored ranking fees.67
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ENGIE Calls for National-Led Energy Poverty Strategy

22 Oct 2025
Topic — EU strategy to reduce poverty and implement the European Pillar of Social Rights.
Message — ENGIE requests that energy poverty be addressed within broader social policy rather than in isolation. They urge that identification and definitions remain at Member State level, with EU coordination focused on monitoring and exchange rather than new binding instruments.123
Why — This maintains their direct partnerships with local authorities while avoiding EU-wide obligations.45
Impact — Vulnerable consumers lose harmonized EU-wide protections against energy poverty.6
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Energy giant ENGIE urges EU to simplify digital regulations

14 Oct 2025
Topic — The European Commission seeks to simplify digital regulations and reduce administrative burdens for businesses.
Message — ENGIE proposes a one-stop-shop for AI compliance and a single platform for cybersecurity reports. They request clearer energy-sector definitions and a restrictive interpretation of data in prompts.123
Why — Consolidated reporting and clearer rules would significantly lower administrative burdens and compliance costs.45
Impact — Privacy advocates and citizens may lose protections if AI prompts bypass GDPR rules.6
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ENGIE Urges Integrated Energy Security Framework Beyond Gas-Focused Crisis Response

13 Oct 2025
Topic — Revised EU energy security framework for decarbonized, electrified and integrated energy systems.
Message — ENGIE requests an integrated security framework coupling electricity and gas sectors, strategic gas reserves at national/regional level, and recognition that electricity benefits from gas infrastructure flexibility. They oppose mandatory storage filling targets and advocate market-based commercial storage with cross-sectoral cost allocation.1234
Why — This would shift gas storage costs to electricity consumers benefiting from gas flexibility and remove mandatory filling requirements.56
Impact — Gas consumers would no longer bear exclusive costs for storage benefiting electricity sector.7
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Meeting with Peter Liese (Member of the European Parliament)

13 Oct 2025 · Austausch

ENGIE calls for technology-neutral heating strategy with renewable gases and networks

9 Oct 2025
Topic — EU strategy to decarbonize heating and cooling sector and advance energy system integration.
Message — ENGIE requests that the heating and cooling strategy prioritize technological neutrality and the 'energy efficiency first' principle. They advocate for territorial planning approaches, broad development of renewable energy sources including renewable gases and geothermal, support for efficient district heating and cooling networks, and appropriate EU financial support for decarbonized heat projects.12345
Why — This would allow ENGIE to deploy its diverse heating solutions including gas networks and district heating systems.678
Impact — Electrification-focused competitors lose if gas infrastructure and hybrid solutions receive equal policy support.910
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ENGIE urges EU to expand state aid rules for energy transition

6 Oct 2025
Topic — Revision of EU rules exempting certain state aid categories from prior Commission approval.
Message — ENGIE requests allowing grants to cover operational costs not just capital costs, increasing aid intensity for heating and cooling networks to 50%, and raising notification thresholds to accelerate energy transition projects. They argue current rules are too restrictive for hydrogen and biomethane projects.123
Why — This would reduce compliance delays and increase funding for their district heating, hydrogen, and biomethane infrastructure projects.45
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ENGIE urges swift adoption of EU carbon removal certification framework

22 Sept 2025
Topic — EU regulation establishing methodologies to certify permanent carbon dioxide removal activities.
Message — ENGIE calls for swift adoption of the delegated act and remaining secondary legislation to enable first certifications. They request recognition of CO₂ midstreamers' role, extension of storage eligibility to UK sites, and alignment with RED certification to reduce administrative burden.1234
Why — This would provide legal certainty for their €10 billion annual energy transition investments and enable their midstreamer business model.567
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ENGIE Calls for Implementation Focus in Citizens Energy Package

11 Sept 2025
Topic — This initiative aims to protect and empower consumers within the European energy transition.
Message — ENGIE requests prioritizing the implementation of current rules before adding new regulation. They propose structural policies for energy poverty and transparent, simple consumer services. They also advocate for a planned 10-15 year gas phase-out.12
Why — This approach helps ENGIE avoid administrative burdens and maintains market-driven innovation.3
Impact — Vulnerable households may face higher risks if disconnections are not banned during crises.4
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ENGIE urges EU to formalize roles for CO2 midstreamers

11 Sept 2025
Topic — This initiative focuses on establishing competitive European markets and transportation infrastructure for carbon dioxide.
Message — ENGIE requests formal recognition for CO2 midstreamers to manage cross-border emissions transport. They support standardizing CO2 quality and removing regulatory barriers to international storage. Additionally, they propose including permanent carbon removals within the EU ETS.12
Why — Formal midstreamer status allows ENGIE to maintain ownership of molecules and secure financing.3
Impact — Infrastructure operators lose direct ownership of the CO2 molecules moving through their networks.4
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Meeting with Radan Kanev (Member of the European Parliament) and Eurelectric aisbl

9 Sept 2025 · EEF- Delivering flexibility: keeping the lights on with supply and demand

ENGIE urges binding zero-emission targets for corporate fleets

8 Sept 2025
Topic — The consultation seeks to set minimum requirements for zero-emission vehicles in corporate fleets.
Message — ENGIE advocates for mandatory 100% zero-emission targets for large corporate fleets by 2035. They request streamlined grid connection processes and transparency from distribution system operators. The group supports using bioNGV for heavy-duty transport alongside electricity and hydrogen.123
Why — Mandating zero-emission fleets increases demand for ENGIE’s charging infrastructure and renewable energy.4
Impact — Small transport companies struggle with costs as electric trucks lack price parity.5
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Meeting with Stéphane Séjourné (Executive Vice-President) and

5 Sept 2025 · - Compétitivité des entreprises - Marché intérieur - Protection de la souveraineté et du pouvoir d’achat - Relation US/EU

ENGIE Urges Regulatory Alignment to De-Risk Sustainable Transport Investment

4 Sept 2025
Topic — A strategic initiative to increase investment in renewable fuels for aviation and shipping.
Message — The company calls for consistent rules that value renewable fuels in heavy transport. They also want long-term support schemes and direct subsidies for green aviation fuel.12
Why — Clearer rules and subsidies would lower financial risks for their clean fuel investments.3
Impact — Firms failing to transition would face immediate financial penalties and increased regulatory pressure.4
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ENGIE urges split of LNG risk groups for landlocked states

12 Aug 2025
Topic — EU update of regional gas supply security risk groups under Regulation 2017/1938.
Message — ENGIE requests splitting the proposed EU-wide LNG risk group into two separate groups: one for 20 countries with LNG terminals and one for 7 landlocked countries. They also call for maintaining a dedicated L-Gas risk group for Belgium, France and Netherlands until France completes its conversion process in 2029.123
Why — This would ensure continued coordination for ENGIE's L-Gas operations in France during the conversion period.45
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ENGIE urges faster permitting to unlock European energy grids

5 Aug 2025
Topic — The Commission is consulting on measures to accelerate the expansion of energy infrastructure.
Message — ENGIE requests reduced permitting times and objective eligibility criteria for grid connection queues. They also propose a European Hydrogen Infrastructure Strategy to coordinate future network planning.123
Why — Streamlined permitting and increased funding would lower costs for ENGIE’s renewable energy deployments.45
Impact — Speculative developers would be excluded from queues to prevent the blockage of grid capacity.67
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ENGIE urges technological neutrality in radiator energy labelling

29 Jul 2025
Topic — EU initiative to create energy labels for radiators to improve space heating efficiency.
Message — ENGIE advocates for technologically neutral evaluation criteria that include high efficiency gas boilers and hybrids. They suggest a framework reflecting the technical and economic realities of existing buildings.12
Why — ENGIE would protect its gas-related business assets and reduce the risk of costly renovations.34
Impact — Heat pump manufacturers lose the exclusive competitive advantage the original proposal would have provided.5
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Meeting with Stéphane Séjourné (Executive Vice-President) and

26 Jun 2025 · Compétitivité; relations USE-UE, CSRD/CS3D, Simplification

ENGIE urges harmonized rules for gas and electricity switching

16 Jun 2025
Topic — The consultation establishes interoperability requirements for data access during electricity supplier switching.
Message — ENGIE recommends better alignment of gas and electricity switching processes to ensure simplicity for consumers. They request clarity on the 24-hour timeline and suggest allowing credit risk assessments.12
Why — Automated data sharing and credit checks would reduce administrative costs and financial risks for suppliers.3
Impact — Customers with poor credit history may face increased barriers or rejection when switching energy providers.4
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Meeting with Boriša Falatar (Cabinet of Commissioner Hadja Lahbib)

10 Jun 2025 · Security of supply of energy

Meeting with Kitti Nyitrai (Head of Unit Energy)

5 Jun 2025 · Discussion on the EU Methane Regulation and methane emission tracing options

Meeting with Thomas Pellerin-Carlin (Member of the European Parliament)

3 Jun 2025 · Energy security

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 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 ENEL SpA 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

ENGIE calls for simpler taxonomy rules and voluntary reporting

25 Mar 2025
Topic — Amendments to EU taxonomy rules aimed at simplifying sustainability reporting for companies.
Message — ENGIE suggests applying the 10% materiality threshold to individual activities rather than cumulatively. They advocate for making taxonomy disclosures voluntary for large companies already subject to CSRD. The company also recommends removing the OpEx KPI, which they find burdensome.123
Why — These measures would significantly lower administrative costs and reduce technical reporting complexity.4
Impact — Investors may lose detailed insights into a company's operational sustainability performance.5
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Meeting with Patrice Pillet (Cabinet of Commissioner Wopke Hoekstra)

20 Mar 2025 · Energy Taxation Directive

Meeting with Dan Jørgensen (Commissioner) and

19 Mar 2025 · biofuels, and gas markets

Meeting with Andrea Wechsler (Member of the European Parliament) and Stegra (formerly H2GS AB) and Carl Zeiss AG

19 Mar 2025 · EU Energy and industry policy

Meeting with Elena Arveras (Cabinet of Commissioner Maria Luís Albuquerque)

12 Mar 2025 · Sustainability Omnibus

ENGIE urges flexible procurement rules for faster decarbonization

7 Mar 2025
Topic — This consultation evaluates the effectiveness and relevance of European public procurement directives.
Message — ENGIE requests more flexible rules for contract amendments to support decarbonization and renewable energy. They also propose digitizing documentation and rewarding innovative solutions in project tenders.12
Why — This flexibility would allow the company to develop renewable energy facilities more rapidly.3
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Response to Implementing Act on non-price criteria in renewable energy auctions

21 Feb 2025

ENGIE appreciates the Commission's efforts to harmonise the application of non-price criteria under the NZIA Regulation. ENGIE supports the introduction of non-price criteria (NPC) to achieve strategic objectives such as making supply chains more resilient, decarbonizing supply chains, increasing social acceptability, as long as such NPC do not jeopardize affordable energy costs. ENGIE reiterates that Europe needs to strike the right balance between resilient supply chains and competitive electricity supply. The document attached contains our detailed feedback and reflects this balanced approach. - Risks and recommendations: While highlighting the positive elements (technology-specific approach, consultation of market players and reference to EU law and international practices), ENGIE identifies several risks associated with the draft act, including legal uncertainty, increased costs, undercapacity for alternative suppliers and limited competition between them, and additional administrative burdens. ENGIE recommends simplifying the language, providing additional guidance to Member States, and adopting a pragmatic and phased approach to the implementation of non-price criteria to allow the manufacturing industry to adapt. - Resilience contribution: ENGIE provides detailed comments on the resilience contribution, including the need for transparency on the Commission's timetable for updating the dependency assessments and the importance of a phased approach to avoid bottlenecks in the supply chain. ENGIE also suggests changes to Article 7 to improve clarity and flexibility: o Solar PV: ENGIE proposes to limit the requirements particularly if the resilience contribution is used as a pre-qualification criterion, in order to limit the risk of under-subscription in auctions and thus the deployment of renewable energy. o Onshore wind, offshore wind and electrolysers: ENGIE recommends limiting the accumulation of requirements, while these technologies are likely to be considered "resilient" for the time being. In addition, the proposed rules might significantly reduce the competition between suppliers/manufacturers. Member States should consider such risks when applying the resilience criterion. These adjustments would contribute to a more balanced and effective implementation of the resilience contribution while preserving the deployment of renewable projects and ensuring the achievement of EUs energy and climate targets. - Sustainability contribution: ENGIE recommends minimising the number of criteria used to fulfil the sustainability contribution and avoiding overlaps with existing legislation. o Carbon footprint: ENGIE endorses the possibility of demonstrating actual emissions, instead of using a default value to evaluate corporate decarbonisation efforts. o System integration: ENGIE believes that system integration requirements for the possible application of the sustainability contribution should not be prioritised by Member States as non-price criteria. Instead, system operators should be responsible for ensuring system integration, flexibility markets should be developed and network investments should be encouraged. - Responsible Business Conduct: ENGIE asks the Commission to clarify that the compliance with the core elements of Due Diligence and the linked public communication is not project-specific but company-specific (or business-unit specific). -Additional considerations: o ENGIE also stresses the importance of proportionate penalties (considering account events beyond the developer's control), indexation provisions and carefully calibrated bid caps, taking into account the additional costs associated with the application of non-price criteria. o Finally, to avoid unintended consequences, penalties for non-compliance should be capped and proportionally shared between bidders and the supply chain. Developers should not bear the full burden of supply chain constraints beyond their control.
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Response to List of net-zero technology final products and their main specific components

20 Feb 2025

We thank the Commission for the organization of the public consultation on the list of net-zero technology final products and their main specific components and would like to provide the following remarks. As a general remark, we ask for visibility on future updates of the dependency assessment of the net-zero technology final products and their main specific components. In particular, we ask the Commission to provide visibility on the envisaged timeline to update the dependency assessment for the final products and their main specific components from dominant third countries. This is paramount for the definition and adjustment of long-term procurement strategies. On the list of main specific components: - Solar PV: Mounting structures should be added in the list of main specific components for solar PV as they are fully part of solar PV supply chain. In addition, we propose the Commission to define the concept of large-scale plants (10 MW would be a good reference). Mounting structures for fixed solar installations are essential components of photovoltaic (PV) systems. They are specifically designed and manufactured for this application in dedicated facilities. - Wind Offshore: Foundations and floaters should not be in the list of main specific components. Resilience should be assessed without including foundations and floaters, as these components are not subject to the same supply chain vulnerabilities as other critical offshore wind elements. The market for foundations and floaters is already well-diversified, with multiple suppliers operating across different regions, ensuring a stable and competitive supply chain.
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Meeting with Isabelle Le Callennec (Member of the European Parliament)

3 Feb 2025 · Engie's Decarbonization Pathways for Europe

Meeting with Bruno Tobback (Member of the European Parliament)

3 Feb 2025 · Event: decarbonization pathways for Europe

Meeting with Tiemo Wölken (Member of the European Parliament)

3 Feb 2025 · Industry Decarbonization (staff level)

Meeting with Dan Jørgensen (Commissioner) and

23 Jan 2025 · Charting the future of European green competitiveness.

Meeting with Wopke Hoekstra (Commissioner) and

23 Jan 2025 · Exchange of views on the implementation of Fit for 55 and upcoming initiatives

Meeting with Stéphane Séjourné (Executive Vice-President) and

22 Jan 2025 · State of play of Energy sector

Meeting with Hubert Gambs (Deputy Director-General Internal Market, Industry, Entrepreneurship and SMEs)

16 Jan 2025 · Exchange of views on hydroelectric policy, at the request of ENGIE

Meeting with Kurt Vandenberghe (Director-General Climate Action)

16 Jan 2025 · climate policy issues

Meeting with Andrea Wechsler (Member of the European Parliament)

13 Jan 2025 · EU Energy and Industry Policy

Meeting with Pascal Canfin (Member of the European Parliament)

8 Jan 2025 · Clean Industrial Deal

Meeting with Christian Ehler (Member of the European Parliament)

13 Dec 2024 · Hydrogen

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

13 Dec 2024 · Energy policy

Meeting with Yvan Verougstraete (Member of the European Parliament)

11 Dec 2024 · Electricity market

Meeting with Wouter Beke (Member of the European Parliament)

6 Dec 2024 · Low Carbon Delegated Act

Meeting with Barry Andrews (Member of the European Parliament) and European Energy Forum

5 Dec 2024 · Electricity Trading

ENGIE calls for market-based energy security with sector integration

26 Nov 2024
Topic — EU evaluation of electricity and gas security frameworks after energy crisis.
Message — ENGIE requests maintaining undistorted price signals on wholesale markets while completing missing framework pieces like bilateral solidarity agreements. They emphasize energy efficiency, supply diversification, and sector integration across electricity, gases, and heat. Emergency demand reduction measures should remain temporary.123
Why — This would protect their gas infrastructure investments and create demand for flexibility services.45
Impact — Consumers lose stronger protections against price volatility and market manipulation during crises.67
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Meeting with Bruno Tobback (Member of the European Parliament)

26 Nov 2024 · Energy sector in Europe and energy grid infrastructure

Meeting with Wouter Beke (Member of the European Parliament)

13 Nov 2024 · European energy policy

ENGIE demands technological neutrality in EU low-carbon fuel rules

25 Oct 2024
Topic — Defining the methodology for calculating lifecycle greenhouse gas emissions for low-carbon fuels.
Message — ENGIE supports a technology-neutral methodology where the 70% emission reduction threshold is the fundamental eligibility criterion. They recommend extending the fossil fuel comparator to industry and allowing electricity sourcing via power purchase agreements. They also urge grandfathering clauses to protect investors who have already reached final investment decisions.123
Why — These measures would protect existing investment projects while lowering production costs for low-carbon fuels.45
Impact — Environmental groups lose as fossil-based production and industrial CO2 use are extended until 2050.67
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Meeting with Christophe Grudler (Member of the European Parliament)

17 Sept 2024 · Politique énergétique européenne

Meeting with Pascal Arimont (Member of the European Parliament)

17 Sept 2024 · Low-carbon Hydrogen

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

10 Sept 2024 · EU Energy Policy

Meeting with Angelika Niebler (Member of the European Parliament) and BASF SE and EnBW Energie Baden-Württemberg AG

10 Sept 2024 · EU Energy Policy

Meeting with Christian Ehler (Member of the European Parliament) and BASF SE and EnBW Energie Baden-Württemberg AG

10 Sept 2024 · Low-carbon hydrogen

Meeting with Tsvetelina Penkova (Member of the European Parliament)

25 Jul 2024 · Future priorities

ENGIE urges stable rules for renewable fuel carbon accounting

19 Jul 2024
Topic — The Commission is updating rules for monitoring and reporting greenhouse gas emissions.
Message — ENGIE requests simpler compliance through self-declarations and mandatory recognition of database evidence. They demand grandfathering of current CO2 accounting rules to ensure long-term regulatory stability.12
Why — These changes would lower administrative costs and protect the profitability of existing projects.34
Impact — Climate groups lose if grandfathering prevents timely updates to inaccurate carbon accounting rules.5
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Meeting with Jens Geier (Member of the European Parliament) and EUROGAS and EnBW Energie Baden-Württemberg AG

18 Jul 2024 · Exchange on Low Carbon Hydrogen

Meeting with Magda Kopczynska (Director-General Mobility and Transport) and Airbus and

15 Jul 2024 · Transport and mobility priorities / Funding / Decarbonization solutions

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

11 Jul 2024 · Energiepolitik allgemein

Meeting with Maroš Šefčovič (Executive Vice-President) and

11 Jun 2024 · Hydrogen

Meeting with Rachel Smit (Cabinet of Commissioner Adina Vălean) and Air France-KLM and Groupe ADP

8 Apr 2024 · Meeting with Région Ile-de-France and stakeholders on SAF and ReFuelEU

Meeting with Tatiana Marquez Uriarte (Cabinet of Commissioner Kadri Simson) and CMA CGM

7 Mar 2024 · Presentation by Engie and CMA/CMG of the Salamandre Project

ENGIE Urges Technology-Specific Rules for Renewable Energy Auctions

1 Mar 2024
Topic — The consultation concerns the design of qualitative criteria and indexation for renewable auctions.
Message — ENGIE requests technology-specific auctions using clear, transparent, and non-discriminatory criteria. They want price indexation included to prevent withdrawals during high inflation. Developers should be consulted at the design stage to avoid undersubscription.123
Why — Predictable criteria and indexation would lower financial risks and compliance costs.4
Impact — Consumers could face higher electricity prices if uncapped negative bidding is permitted.5
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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

Unlocking private investment in energy efficiency ENGIEs contribution The EU's energy savings target for 2030 has - rightly - been revised upwards to achieve full decarbonisation of the EU by 2050. The EU's investment gap, noted by the Commission in this sector, risks however preventing the achievement of the objectives set. To remedy this, an increased amount of public financing and greater mobilization of private investment in energy efficiency operations is essential. Regarding private investments in energy efficiency, the capacity of public framework and public incentives to leverage more private investments towards energy efficiency measures is instrumental. A conducive environment is paramount and should encompass : sufficiently high market prices for energy and CO2 allowances, mandatory energy saving targets for primary and final energy consumption in Member States, a regulated relaxation of the rules on the intensity of public aid granted for energy efficiency operations, a State aid intensity independent from the projects service provider, the training of professionals performing energy efficiency actions certified by the public authorities The process of getting public support must be as simple and understandable as possible, without multiplying the various-stop shops. A one-stop shop for energy efficiency operations should be favoured in each Member States. Public spending should also be more predictable (without stop and go) and take advantage of a stable framework. All these conditions are essential to accelerate the completion of potential operations. Besides, to favour private investments, the development of energy performance contracts in the EU should be recommended and considered as a priority. Indeed, it provides a stable framework over several years, commits the operator on guarantees of results giving confidence to the beneficiary and secures investments and cash flows. This kind of contract can also facilitate the use of third-party financing, the beneficiary taking advantage from an entirely financed project that he starts reimbursing only at the work's delivery. It is difficult to finance, without guarantees and without accounting deconsolidation, energy saving operations, which produce their effects gradually over many years (while the investment is to be made up front), with possibly a risk of customer insolvency. A guarantee fund supported by initial public funding might prove useful to reduce the counterparty risk that banks and insurance companies refuse to cover. At last, it is worthwhile to reinforce synergies between public and private funding. For instance, the combination of public subsidies with private funding, such as the white certificates for energy efficiency operations, should be encouraged across the EU.
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Response to Assessment of the energy efficiency public funding support at Union and national level

26 Feb 2024

Assessment of the energy efficiency public funding support at Union and national level ENGIEs contribution The EU's energy savings target for 2030 has - rightly - been revised upwards to achieve full decarbonization of the EU by 2050. The EU's investment gap, noted by the Commission in this sector, risks however preventing the achievement of the objectives set. To remedy this, an increased amount of public financing and greater mobilization of private investment in energy efficiency operations is essential. Regarding public financial support, at European and national levels, a sufficient volume of public funds for the implementation of energy efficiency actions is paramount as well as a greater efficiency of public spending. Currently, none of the EU funding programs provide funding dedicated exclusively to energy efficiency operations (notably not for energy efficiency actions in the building, tertiary and industrial sector). If public EU support were to be increased and a dedicated mechanism set up at EU level, it might make sense for it to be tailored to the local context and channel its funding (for its greater part) through already existing national funding programs, to be effective and quickly accessible. The process of getting public support must be as simple and understandable as possible, without multiplying the various-stop shops. A one-stop shop for energy efficiency operations should be favored in each Member States. Public spending should also be more predictable (without stop and go) and take advantage of a stable framework. All these conditions are essential to accelerate the completion of potential operations. But using public funds cost-effectively is essential too, especially at a time when public funding is limited. As regards energy efficiency, collective solutions may favor efficient public spending by working with local authorities at district level and thus allowing public support at this adequate level (for energy renovation operations of a group of buildings, the connection to an efficient energy network, the hybridization of boilers ). Financing instruments for energy efficiency should be prioritized for operations whose energy performance is guaranteed over time, for example through tools such as energy performance contracts, which enable several actions and benefits for public authorities. The latter very often carry out their project lot by lot with projects of a single action. An efficient way could be to implement energy efficiency operations comprising a combination of actions with an operator able of playing the role of tasks aggregator. To favor the development of public investments by public authorities (which must set an example in terms of energy efficiency as part of the energy efficiency directive recast), a specific type of market could be promoted in a manner sustainable in the EU: the global energy performance market, associated with a third-party financing mechanism. This type of contract, concluded with local authorities, is an all-in-one contract, encompassing the design, construction and maintenance of a project. In this context, the single operator selected, after competitive bidding (launch of a call for tenders), commits, for the entire duration of the contract, on guarantees of results (the energy performance of equipment for example) with a bonus/malus system linked to the results actually obtained in relation to the commitments made contractually. In this context too, payment for the works does not have to be made in advance, it is deferred. Payment for the works by the public authority is made by installments (from receipt of the works to the end of the contract, i.e. over the duration of operation of the project). This type of market, experimentally existing in France, enriches the range of solutions for financing the energy transition of various public authorities and could be promoted across the EU.
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Meeting with Maroš Šefčovič (Executive Vice-President) and

22 Feb 2024 · Clean Transition Dialogue on Clean Technologies

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

22 Feb 2024 · Energy market

Response to Reporting scheme for data centres in Europe

15 Jan 2024

ENGIEs feedback on Common European Union rating scheme for data centres (DC) Annex II Comments and additions about on-site power and cooling generation On-site power and cooling generation is mentioned in Annex II. ENGIE is aligned and think it can be of great importance in regions in development as well as developed ones, where power is lacking, whether because the infrastructures are not developed or reliable enough yet, or because there are too many consumers nearby (currently, internet hubs such as Paris, Frankfurt, ..., lack available power). ENGIE suggests to better highlight and promote this energy approach. When it comes to on-site power generation and cooling, ENGIE uses the terms Microgrid. Microgrids could be defined as follows: Microgrids are local integrated utilities services networks, incorporating thermal and electrical distribution, cabling, control & monitoring, and water services, with the ability to be connected or disconnected from the national grid when and where necessary. The scale of these networks can range from a single large data centre to several buildings on a single site, to a district scale set up where several different sites and buildings are connected. Microgrids guarantee the availability of utilities serving the data centre and secondly, future-proof the schemes that allow for the incorporation of zero carbon generation, as new technologies and fuels come to market. Microgrids are both a means for the data centre industry to keep on developing in areas where power is lacking, but also and above all a support to the resilience of the national electricity grids (by avoiding reserving critical power capacities and through the possibility to provide grid services such as Firm Frequency Response). They are also local enablers for the use of low-carbon energies. Annex II (k) Comments about Waste Heat Reuse In the very last paragraph of Annex II item (k), ENGIE understands that the waste heat directly reused for the cooling process of the data centre shall be discounted from Ereuse indicator. ENGIE suggests considering the waste heat reused in cooling process when calculating the Ereuse indicator. Indeed, ENGIE considers that it is an excellent use case improving the overall efficiency of a data centre and not requiring huge investments. Moreover, ENGIE suggests developing an indicator measuring the available waste heat capacity from data centres. Hence facilitating the potential of waste heat reuse for any district heating network or heat-demanding industry development. Annex III Comments on KPIs to assess DC sustainability The data centre industry sustainability assessment is, today, mainly driven towards one indicator, the PUE. In Annex III, ENGIE is pleased to observe that the current version of the text suggests the use of several other KPIs than just PUE. Indeed, if this indicator proved itself to be relevant for assessing a part of the energy efficiency, it is not comprehensive and has always had flaws. The other indicators suggested so far by the text will help provide a more precise assessment of the sustainability of a data centre. In addition, ENGIE is currently developing new KPIs for the industry with the goal to give a holistic view on data centre sustainability. Assessing the use of renewable energies does not give a holistic view of the carbon footprint of a data centre. The French energy mix, for example, is highly decarbonized, whereas other countries use more renewable energies. If the aim is to decarbonize industry, then the GHG emissions of data centres should also be assessed. Here are indicators that ENGIE suggests for any data centre and especially when it comes to on-site electricity and cooling production: Carbon Reduction Factor CRF=ACTUAL CARBON EMISSIONS (kg C02)/THEORITICAL CARBON EMISSIONS BASED ON 100% ENERGY COMING FROM THE GRID (kg CO2) Waste heat reuse efficiency WHE=TOTAL HEAT REJECTED FROM COOLING SYTEMS (kWh)/ACTUAL HEAT EXPORTED (kWh)
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Meeting with Ruud Kempener (Cabinet of Commissioner Kadri Simson)

19 Dec 2023 · Update on Engie hydrogen projects

Meeting with Kurt Vandenberghe (Director-General Climate Action) and Airbus and

24 Oct 2023 · Cercle des Grandes Entreprises françaises

ENGIE demands more detailed transparency for European ESG ratings

1 Sept 2023
Topic — Proposal to enhance reliability, comparability, and transparency of ESG ratings in Europe.
Message — ENGIE requests a detailed presentation of methodologies including rating formulas and numerical thresholds. They oppose requirements for separation from credit ratings to maintain integrated performance. Agencies using artificial intelligence should provide more details on data collection and evaluation.123
Why — Standardized rules help the company monitor its sustainability performance internally using transparent tools.4
Impact — Rating agencies lose proprietary advantages by being forced to disclose specific rating formulas.5
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Meeting with Ditte Juul-Joergensen (Director-General Energy) and BASF SE and

29 Aug 2023 · Energy transition and security

ENGIE backs EU carbon auctions but seeks funding flexibility

4 Aug 2023
Topic — The consultation implements competitive bidding and updates to the EU's Innovation Fund.
Message — ENGIE supports the new auction mechanism but wants bid price to represent most of the ranking criteria. They urge the Commission to allow projects to combine different funding sources. For hydrogen, they suggest a fixed premium scheme without competitive bidding to accelerate deployment.123
Why — Allowing multiple funding sources helps ENGIE bridge financial gaps and advance mature decarbonization projects.45
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Meeting with Pascal Canfin (Member of the European Parliament) and Confédération des Petites et Moyennes Entreprises

19 Jul 2023 · Green Deal

ENGIE calls for flexibility and delays in sustainability reporting standards

7 Jul 2023
Topic — The consultation seeks feedback on the first set of European Sustainability Reporting Standards.
Message — ENGIE supports the broad application of the principle of materiality and urges sufficient time for implementation. They request full interoperability with global standards and clear recognition of market-based instruments for carbon accounting.12
Why — These changes would reduce compliance costs and avoid costly and time-consuming tick-the-box exercises.3
Impact — Investors could face data gaps if companies use materiality to omit mandatory indicators.4
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Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans), Riccardo Maggi (Cabinet of Executive Vice-President Frans Timmermans)

27 Jun 2023 · Decarbonization and energy challenges

Meeting with Cristian-Silviu Buşoi (Member of the European Parliament) and Friends of Europe and Deutsche Gesellschaft für Internationale Zusammenarbeit (GIZ) GmbH

27 Jun 2023 · speaker at Climate and Energy summit Brussels

Meeting with Olivier Guersent (Director-General Competition)

26 Jun 2023 · Marché de l’électricité dans l’UE et en France, Inflation Reduction Act

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

14 Jun 2023 · Exchange on the gas market directive and the electricity market design (staff level)

ENGIE urges diversified approach to European heat pump deployment

26 May 2023
Topic — The European Commission is developing an action plan to accelerate heat pump deployment.
Message — ENGIE advocates for a mix of technologies including hybrid heat pumps and green gases. They emphasize that systems must be properly sized and professionally installed to prevent inefficiency.123
Why — Allowing diverse technologies lets ENGIE maintain its current gas and heating network businesses.4
Impact — Grid operators lose as a purely electric transition would require massive infrastructure upgrades.5
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Meeting with Christophe Grudler (Member of the European Parliament, Shadow rapporteur) and Transport and Environment (European Federation for Transport and Environment) and Ecocem Materials Ltd

24 May 2023 · NZIA

ENGIE urges EU to include renewable fuels in vehicle standards

19 May 2023
Topic — Revision of EU CO2 emission standards for heavy-duty vehicles to support zero-emission mobility.
Message — ENGIE calls for a carbon correction factor to allow vehicles to run on biomethane and e-fuels. They suggest lowering transition targets to align with infrastructure and giving cities flexibility for bus fleets.12
Why — This protects ENGIE's biomethane investments and prevents existing refueling infrastructure from becoming stranded assets.34
Impact — The electricity grid faces peak demand risks and high investment requirements from excessive electrification.5
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Meeting with Tiemo Wölken (Member of the European Parliament, Rapporteur for opinion)

15 May 2023 · EU-Lieferkettengesetz (staff level)

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.

ENGIE urges flexible taxonomy criteria and reporting delays

3 May 2023
Topic — The initiative establishes environmental sustainability criteria for investment purposes across several key objectives.
Message — ENGIE asks that desalination criteria focus only on energy intensity rather than direct greenhouse gas emissions. They also request a 12-month reporting delay to manage the complexity of new disclosure requirements.12
Why — This allows ENGIE to secure sustainable investment for global desalination projects despite local grid conditions.3
Impact — Environmental groups lose strict oversight of carbon emissions from energy-intensive desalination processes in third countries.4
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Response to Ecodesign requirements for local space heaters (review)

18 Apr 2023

The future revision of the ecodesign regulation should not ban the use of technologies essential for a realistic and feasible energy transition at the lowest cost for consumers. - highly efficient, gas boilers are 95% benchmarked, and can reach thresholds of 98%, combined with smart control ; - affordable for households, boilers are entry-level heating products ; - and are fully compatible with decarbonation, by fuelling them with renewable gas or liquids (the European Commission targets 380 TWh of renewable gas for 2030, and the potential for 2050 is 1600 TWh...) We cannot afford to exclude options that are compatible with the decarbonization pathway. District heating, for instance, can thus be considered in dense urban areas. Wood-fired boilers and electric heat pumps are important solutions, but they cannot meet all situations and may have some drawbacks: for instance fine particle emissions for wood-fired boilers or poor cold performance for heat pumps*... Furthermore, the deployment of heat pumps may require a considerable reinforcement of the electrical network as well as a touchy management of huge peaks of electrical consumption in winter ... **). Therefore, boilers fueled by renewable gases or liquids are important tools for a realistic, rapid and cost-effective transition, and they shall remain a possible choice for households, consistent with the "Energy Performance of Buildings" amended directive, voted by Parliament on March 14, 2023. A total electrification of heating would require a considerable reinforcement of the electrical network and lead to a difficult management to pass the huge peaks of electrical consumption occurring in winter. The impossibility of using gas to supply energy to buildings would have a strong impact on EU's security of supply. The energy bill would also experience an inevitable increase (due to the induced oversizing of the electric distribution system) and the employment in the EU would undergo a negative impact (due to the replacement of the boilers produced in the EU by electric heat pumps mainly coming from Asia). For these different reasons, ENGIE advocates : - The replacement of old gas boilers by hybrid renewable systems. --- For collective housing (heat pumps not mature): replace the old gas boilers by hybrid solutions combining electricity, boilers with very high energy performance and/or renewable heat networks. --- For individual houses: replace old gas boilers with hybrid heat pumps (coupling a heat pump and a gas boiler) or with very high energy performance boilers. - The speeding up of the greening of gas in buildings by using green gas (e.g. biomethane or H2). - The speeding up of the thermal renovation of housing, the development of offers encouraging energy sobriety and the accelerated phase-out of oil-fired boilers. This would lead to a big reduction in emissions in buildings by 2030. This would also enable the development of an European hybrid heat pump industry. * heat pumps are efficient heating systems when outside temperatures are mild, but much less so when they are cold: performance depends on the water temperature needed in the radiators, but even in the best case, with low temperature radiators, the COP can drop from 2.8 at 7°C outside, to less than 1.5 at -7°C... ** Households could be tempted by cheaper but much less efficient solutions such as electric convectors, which would multiply the need to reinforce the networks and manage the consumption peaks of electric radiators.
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Meeting with Kurt Vandenberghe (Director-General Climate Action)

11 Apr 2023 · Climate change

Meeting with Tsvetelina Penkova (Member of the European Parliament, Shadow rapporteur)

3 Apr 2023 · Meeting between Mihael MIHOV (APA) and Engie on NZIA

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

31 Mar 2023 · Energy Transition. Site visit. Organiser: Administração dos Portos de Sines e Algarve.

Meeting with Barbara Glowacka (Cabinet of Commissioner Kadri Simson), Thor-Sten Vertmann (Cabinet of Commissioner Kadri Simson)

17 Mar 2023 · Renewable energy developments (Fit for 55 and the Green deal plan and subsequent acts) and challenges, as well as the methane regulation, EMD and TEN-E.

Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur) and BUSINESSEUROPE and

8 Mar 2023 · Corporate Sustainability Due Diligence

Meeting with Valdis Dombrovskis (Executive Vice-President) and BUSINESSEUROPE and

16 Feb 2023 · Critical Raw Materials package

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

20 Jan 2023 · European Energy Policy

ENGIE Urges EU to Reclassify Intermediate Crops for Biofuels

23 Dec 2022
Topic — This consultation reviews the list of sustainable feedstocks for producing biofuels and biogases.
Message — ENGIE requests moving intermediate crops from Part B to Part A to avoid production caps. They also suggest including additional waste feedstocks like biowaste and flotation greases.12
Why — This change allows ENGIE to scale up biomethane production without restrictive regulatory limits.34
Impact — Natural gas suppliers lose market share as biomethane replaces gas in buildings and industry.5
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Meeting with Olivier Guersent (Director-General Competition)

21 Dec 2022 · discussion on gas and electricity matters that falls in COMP competences

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.

Meeting with Antoine Colombani (Cabinet of Executive Vice-President Frans Timmermans) and TotalEnergies SE and

25 Oct 2022 · Green Deal state of play

Meeting with Ditte Juul-Joergensen (Director-General Energy) and Shell Companies and

21 Oct 2022 · Commission proposal on measures on energy prices and security of supply. Innogy Česká republika and Bulgargaz also participated.

Meeting with Pascal Canfin (Member of the European Parliament)

13 Oct 2022 · Green Deal

Meeting with Pascal Arimont (Member of the European Parliament)

29 Sept 2022 · Public event on the energy supply of the future

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

21 Sept 2022 · Energy derivatives markets

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

21 Sept 2022 · EMIR review, clearing threshold

Meeting with Patrizia Toia (Member of the European Parliament, Shadow rapporteur for opinion)

13 Sept 2022 · Corporate due diligence

Meeting with Pascal Canfin (Member of the European Parliament)

13 Sept 2022 · Green Deal

Response to Greenhouse gas emissions savings methodology for recycled carbon fuels and renewable fuels of non-biological origin

17 Jun 2022

We would like to thank you for the possibility to provide our feedback on this important draft delegated act. Please refer to our position paper in attachment (see part 2 on the Delegated Regulation Establishing a Minimum Threshold for GHG Savings of RCFs and RFNBOs)
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Meeting with Gerassimos Thomas (Director-General Taxation and Customs Union)

18 May 2022 · Videoconference - Discussion on national energy taxation measures

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

5 May 2022 · Green hydrogen

Meeting with Olivier Guersent (Director-General Competition)

3 May 2022 · Overall discussion on energy matters, IPCEI, Temporary Framework

ENGIE urges flexibility and alignment in EU methane regulations

13 Apr 2022
Topic — EU legislation focusing on monitoring and reducing methane emissions within the energy sector.
Message — ENGIE requests that the regulation aligns with OGMP 2.0 standards and avoids one-size-fits-all actions. They seek flexibility for repair delays and the use of simulation tools instead of direct measurements. Finally, they insist that importers should not be liable for the data quality of external exporters.123
Why — Increased flexibility and cost recognition would lower the regulatory burden and financial risks for operators.45
Impact — Environmental goals may be compromised by the lack of mandatory inspection intervals and direct measurement requirements.67
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Response to Revision of EU rules on Gas

12 Apr 2022

ENGIE welcomes the EC’s proposal, which acknowledges the key role of renewable & low carbon gases in the energy transition. Gases market design: operational impacts and incentives The introduction of an entry-exit system that merges Transmission&Distribution (T&D) levels should ensure the integration of the distribution system level in the balancing zone and help to achieve a level playing field for Renewable and Low-Carbon (R&LC) gases connected to either the T&D level. As production facilities for biomethane are often connected to distribution grids, the proposal should mean that this production will not be constrained by capacity or demand on the distribution networks anymore. The proposal shouldn’t mean that new entry points should be created at distribution level. It should be enough that the biomethane volumes at the distribution level are taken into consideration for the daily balancing obligations of shippers and that such volumes can be traded at the Virtual Trading Point. This is expected to be an important change, which deserves a specific assessment on the consequences for operational activities from network users and T&D operators. We do not fully understand how the certification and tariff discounts will interact in practice. Policy ask: We share the objectives of promoting the integration of renewable and low-carbon gases, but the proposed definition of entry exit system should give the necessary flexibility to Member States to opt how to integrate the distribution level at the balancing regime and grant access of renewable and low carbon gases locally produced and injected in the distribution network to the wholesale markets. In addition, the impacts on all stakeholders should be dully considered, in particular with regards to the financial and administrative impacts of tariff discounts (esp. entry-exit at interconnection points) and merger of transmission and distribution grids for R&LC gases. European entity for distribution system operators The EU DSO entity, which was set up in the Clean Energy Package for fostering cooperation between electricity distribution system operators (DSOs), is extended to gas DSOs. Its missions are adapted accordingly. In particular, the EU DSO entity shall participate in the development of network codes relevant to the operation and planning of distribution grids and to the coordinated operation of the transmission networks and distribution networks. It shall also contribute to mitigating fugitive methane emissions from the natural gas system. In terms of practical internal governance rules, one single entity could generate unnecessary difficulties or complexity. Furthermore, synergies related to gases (CH4 and H2) would be less effective inside such entity rather than between two separated DSO entities. Policy ask: Given the diversity and the number of DSOs already active in the power sector, it could be more appropriate to establish a separate DSO entity for gases. High energy prices / Security of gas supply Regarding security of gas supply and joint procurement, the initial proposition made by the EC is being reinforced by the propositions made in the context of the RePower EU communication and in line with the conclusions of the European Council Summit of the 24-25 March 2022. It will be important to make these provisions written in emergency situation evolve towards sound long-term provisions adapted to the energy transition and the need for increased energy independence of Europe. Policy ask: In order to ensure security of gas supply and to keep gas prices and market volatility as low as possible during winter periods, promote the introduction of storage incentives at European level (subscription and filling). The French regulation for storage is a good illustration of what could be implemented at European level and of the benefits that could be obtained.
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Response to Revision of EU rules on Gas

12 Apr 2022

ENGIE welcomes the EC’s proposal, which acknowledges the role of Renewable & Low Carbon (R&LC) gases in the energy transition. Definition of gases The proposed gas regulation and directive are reviewing definitions to cover R&LC gases. However, the proposed definitions and the additional (undefined) terms are mixing different elements: main chemical element, origin or GHG content. The delineation between the different terminologies is not always clear or in line with common uses. An example is the definition of "natural gas". As per the proposed definition, it includes biogas, gas from biomass or any limited blending with hydrogen (H2). The common use of the term “natural gas” is related to a gaseous energy carrier consisting mostly of fossil methane (CH4) and is therefore confusing if onboarding other flavours of CH4. Policy ask: use the main chemical element and the characterisation in terms of origin/GHG content when needed (as done for instance for “LC H2”), set international standards in line with European definitions The definitions for "LC" gases are based on a GHG emission reduction threshold of 70%. However, the methodology for calculating said reduction will only be specified by the EC in delegated acts by 31/12/2024. The baseline for computing this reduction is also not specified. This approach and the associated timing fail to provide enough visibility for developing the projects needed to deliver the ambitious targets by 2030. Policy ask: accelerate the process to define “LC” gases in order to provide enough visibility to business developers and investors and provide clear targets for R&LC gases (e.g. biomethane target of 35 bcm/y by 2030 in REPowerEU Communication) Unbundling models for H2 operators The proposed gas directive provides the possibility to deviate from a full Ownership Unbundling model. However, the conditions set are deemed too restrictive on a least two aspects. An exemption seems to be only possible if the H2 network belongs to a vertically integrated undertaking on [entry into force]. This means that the H2 network should already be existing by 2023/2024 and the question is therefore to which entity this exemption could really apply in practice. The Independent Transmission Operator framework is only allowed on a temporary basis: if an existing network operator is developing a H2 network under an ITO framework, this operator will face an expiration of its designation as ITO by end 2030 and be forced to divest its H2 assets or lease them to a 3rd entity and assume all the financial risks of investment decisions taken by such 3rd entity. The proposal undermines the repurposing of CH4 pipelines to H2 ones, even if this option is considered as the most affordable and adequate solution for deploying a H2 backbone across Europe. Policy ask: Existing TSOs and DSOs under an ITO model should be allowed to invest in a H2 network and the ITO model should not be phased-out for H2 TSOs, in particular in light of the proven well-functioning of the ITO model in the gas sector (majority of gas TSOs in the EU are certified under the ITO model). Gases market design: operational impacts and incentives The deployment of R&LC gases are partly based on a certification scheme for which compliance is ensured via a mass balance system. The complexity of this system over the full value chain to track the transactions and to enable measures (e.g. tariff discounts at interconnection points) should not be overlooked. The interactions between the system of guarantees of origin (accounting view) and this mass balance system (physical view) would also deserve a proper assessment. We regret the absence of binding targets for R&LC gases production level which would seem more appropriate as a financial support tool than network tariff discount measures. Policy ask: The implementation of tariff discounts for R&LC gases, including H2, should be pursued together with a sound and upgraded GO and certification scheme
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Meeting with Radan Kanev (Member of the European Parliament, Rapporteur for opinion) and ChargeUp Europe

31 Mar 2022 · EPBD

Meeting with Thierry Breton (Commissioner)

22 Mar 2022 · Crise énergétique, transition et investissements pour le secteur

Meeting with Pascal Canfin (Member of the European Parliament)

18 Mar 2022 · Energy

Meeting with Pascal Canfin (Member of the European Parliament)

25 Jan 2022 · Green Deal

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

12 Jan 2022 · EUGB (staff)

Response to Act amending Implementing Regulation (EU) 2018/2066 on the monitoring and reporting of greenhouse gas emissions

23 Dec 2021

Predictability, regulatory and economic certainty are key to both investors investing in biomass projects, as well as operators using biofuels, bioliquids and biomass fuels for combustion in activities covered by the current EU ETS. Since several relevant delegated and implementing acts of the Renewable Energy Directive (RED) are delayed, we agree with the Commission that such delay should not create economic uncertainty for operators, nor interfere with a robust, efficient and harmonized implementation of such rules once in place. We therefore welcome the Commission’ proposal to amend article 38 of the MRR in order to postpone the application of the sustainability and GHG emissions savings criteria for biomass with one year. To the contrary, we disagree with the optionality proposed to Member States (“Member States may consider as fulfilled ….”). Investors and operators across Member States need to benefit from the same legal and regulatory certainty and no discriminatory approaches should be allowed among Member States on this particular matter. We therefore call on the Commission to make it mandatory for Member States to consider as fulfilled the sustainability and GHG emissions savings criteria during the period from 1st of January to 31rd of December 2022. Going forward, we also want to emphasize that the rules under development in these respective RED delegated and implementing acts on sustainability and GHG reduction certification and tracking should be designed in such a manner that they also allow a simple and effective application for EU ETS purposes. These rules should moreover consider the specificities of the road, maritime and aviation sector, including that biomass (fuels) may be transported by logistical means other than gas networks and can be consumed by off-grid users. A separation of the certificate and the molecules should be allowed to avoid overly complex logistics, and facilitate trading. We would like to remind that guaranties of origin (“GoO”) could be recognized as purchase record for these purposes. Moreover, this should be an opportunity for the European Commission to integrate the sustainability information within the GoO by 1st of January 2023, in order to (i) foster the trading of commodities and certificates; whilst (ii) ensuring a robust monitoring of GoOs at both national and EU levels; and (iii) avoiding double counting and risks of fraud. Additionally, when the MRR rules will be further revised in the context of the Fit for 55 discussions to apply the sustainability criteria for biomass, including biofuels, bioliquids and biomass fuels in the EU ETS, it is paramount that sustainable biomass continues to be zero-rated under the EU ETS. Not only because direct CO2 emissions are actually neutral, but also for concerns of continued regulatory and economic certainty and predictability to investors and operators. To this end, to apply the zero rate to biomass, it should be sufficient to demonstrate that the biomass complies with the sustainability criteria of the RED without additional conditions or restrictions.
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Response to European Strategy on international energy engagement

20 Dec 2021

Committed to being carbon neutral on all three scopes by 2045, ENGIE is a global reference group that acts daily to have a positive impact on the planet and on people by offering solutions for a carbon neutral and environmentally friendly world. Carbon neutrality and the preservation of the environment, major axes of the Green Deal, must notably guide the future strategy as a multilateral instrument to respond together to the global climate challenge and ENGIE subscribes to this EU ambition. At a time when the EU is adopting a climate ambition of carbon neutrality in 2050, it must ensure a coordinated approach to the carbon markets so that the deployment of these new objectives is not accompanied by carbon leakage, particularly to developing countries. This is the ambition behind the creation of the CBAM and the revision of the ETS, which ENGIE welcomes as long as these mechanisms are properly implemented and do not overburden final energy consumers, who are the “barometer” of the social acceptance of the transition, and the competitiveness of companies. Furthermore, the search for common standards, particularly for measuring the carbon intensity of products and services, is necessary (ENGIE has already deployed tools and a decarbonisation metric for companies and local authorities.) The transition must be green, digital and resilient. The solutions must be built through a fruitful cooperation of the countries; autarkic approach will not work. Indeed, only a balanced strategic autonomy between on-shoring and co-shoring will meet the objective of this strategy. Interdependencies will always exist (raw materials, rare earths necessary for renewable energies are mainly located in non-European countries, natural gas, key for accelerating the coal phase-out, is also mainly produced outside the EU, hydrogen will be both produced domestically and imported, given the volumes necessary for the EU's decarbonization etc.). Without being naïve, we have to admit that energy issues are by essence diplomatic and political matters that call for pragmatic discussions. The resilience of energy infrastructures and international cooperation in terms of cybersecurity must also contribute to an environment conducive to this triple transition. ENGIE also shares the EU ambition of a healthy environment. The prevention and control of the impact of activities on biodiversity must also be a point of attention of international cooperation in order to avoid transfering harmful activities to other countries. The strategy should therefore stress the importance of systematically contributing to the rehabilitation of natural habitats through targeted and concrete actions, as ENGIE is committed to doing in its projects. In connection with the Global Gateway aiming to develop smart, clean and secure links in the energy and transport sectors and to strengthen health, education and research systems throughout the world, development aid through the mobilization of EU funds must continue within the framework of this future strategy in order to support developing countries in taking the path of decarbonization, which sometimes requires a first step of access to energy. More generally, with all partner states, trade policy must take into account sustainable development objectives into trade agreements by including a set of ambitious standards and climate commitments, as is the EU's policy on its territory. In a nutshell, the strategy should therefore be based on the following axes: Maintaining leadership on decarbonization at international level Establishing cooperation with third countries towards decarbonization and promoting the development of a global sustainable economy Having a non-naïve and pragmatic energy diplomacy with regard to the resources that are still crucial for the EU decarbonization Maintaining development aid, aiming also at developing a sustainable industrialization and fostering access to energy in third countries that are still lagging behind
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Response to Methodology for calculating the quantity of renewable energy used for cooling and district cooling

25 Nov 2021

Engie’s answer to the Commission's draft delegated regulation on RES-Cooling proposal ENGIE welcomes the Commission's draft proposing a methodology for the calculation of renewable energy in the cooling sector and district cooling. This proposal fills a legal gap and responds to a major issue. Being able to count cooling in a fair way and to promote it when it is sustainable is both useful and necessary to achieve the European objectives set for 2030 in terms of renewable energies, energy efficiency and reduction of greenhouse gas emissions. The cooling sector and in particular modern district cooling are key elements to help cities to optimize their energy supply and reduce their environmental footprint in the most efficient and cost-effective way possible, while promoting different kinds of renewable energy. District cooling also contributes to counteracting heat islands in cities. The Commission's draft defines renewable cooling in a way that can be in line with these objectives. However, according to us, this draft could be improved to achieve a real fairness between different systems, especially between those that measure their actual performance and those that do not. The following proposed amendments should help to achieve this necessary equity. Additional information is attached to better illustrate these proposals and to bring further clarification. 1. Fairness among systems In its current form, the Commission's draft seems to favor unmeasured solutions over measured solutions such as district cooling, given that a unique pair of seasonal performance factor thresholds (low SPF and high SPF) is described when the standard theoretical values of the SPF are more than twice the real measured ones. On the one hand, as the EED promotes measured systems and the two should compete on an equal level, we recommend clarifying the perimeter of the seasonal performance factor calculations, which should only consider chillers and not auxiliaries. Indeed, we noted an inconsistency between the perimeters mentioned on pages 5 and 8. On the other hand, we suggest changing the high SPFp value (high value of the seasonal performance factor calculated in primary energy) for metered systems to 5. This would correct the bias with non-measuring systems, as this threshold would be more representative of the technological maximum of SPF for systems that measure. 2. Promoting the use of more renewable energy input To increase the use of renewable energy in the energy input of cooling systems and the development of new renewable capacities, we propose to subtract the measured local renewable energy input. Its origin should be perfectly identified, have metering devices to measure energy and a supply contract specific to the related site (between producer & user). One way to introduce this proposal is to add the following at the end of the definition of measured energy input in paragraph 3.4.1, at page 9: “The measured renewable energy specifically produced for the cooling system and therefore consumed by it can be subtracted from the energy input”. It is preferable that this proposal be implemented across the EU, but it could also be decided at Member State level to take account of their specificities. 3. Including heat driven cooling systems (absorption) In line with RED II, waste heat must be recovered. Therefore, we ask that heat driven cooling (absorption) may be included in the scope of the calculation. The actual low SPF value of 1.4 excludes most sustainable heat driven systems, as they exist to recover energy at low temperatures, even if they achieve low energy performance (absorption machines should use high temperature energy, which should be used for other purposes, to achieve an SPF barely higher than 1.4). By setting a low SPF to 0.1 and high to 1.8 for absorption driven by at least 50% renewable or waste heat, we have an incentive to use low temperature RES & waste heat, instead of wasting it, especially in summer.
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Response to EU Standard for Green Bond

27 Sept 2021

ENGIE welcomes the opportunity to comment on the proposed EU Green Bond Standard (EuGB). We believe this voluntary harmonised standard may boost the uptake of green bonds in the EU and confirm EU leadership on this matter if the standard is clear and well-designed. 1. Time-limited grandfathering The proposed 5Y-limited grandfathering (article 7 EuGB) in case of change in the technical screening criteria (TSC) set forth under the Taxonomy delegated acts creates a regulatory risk and legal uncertainty for both investors and bond issuers. It also deviates from the TEG recommendation to grandfather green bonds issued under earlier TSC for their entire tenor (p. 29 of its EuGB report and p.32 of the accompanying usability guide). Not grandfathering green bonds until their maturity will not only negatively impact their price as a result of investors pricing-in the risk of disqualification of a green bond over its tenure; it also bears the risk of diminishing investors’ interest to finance long term investments (beyond 5Y) through green bonds. In addition, a time-limited grandfathering may hamper access to the EU green bonds markets for smaller issuers that do not necessarily have a sufficient diversified or big portfolio of assets allowing them to replace the disqualified asset within the predetermined 5Y period. Also from an operational perspective it’s unclear how such time-limited grandfathering should work in practice and who should monitor and/or re-assess the continued technical eligibility of assets after their allocation (and even after the final allocation report is issued by the external reviewer). Such an obligation will trigger undue additional administrative and compliance costs whereas already today, the costly and burdensome reporting and review process linked to a green bond issuance are considered to be a barrier to the development of green bond markets. Additional complexity, cost and uncertainty will reduce the attractiveness of the EuGB label. Article 7 of the proposed EuGB standard should be amended to allow issuers to continue applying the TSC applicable at the moment the European green bond issuance when allocating the proceeds of such bonds so that EU green bonds maintain their status until maturity (regardless subsequent changes to the TSC). 2. Allocation report (art.9§6 EuGB) The proposed 30 days period to provide the allocation report to the external reviewer is difficult to meet in practice since allocations are often only completed after the financial year (FY) closing when final capex numbers are finalised. The deadline is also much more ambitious than existing rules and market practice for the preparation of the annual financial report. The reporting period should be extended to at least 60 days following the end of the year to which the allocation report refers.   3. Need for Additional guidance Few proposals in the EuGB regulation are unclear and introduce uncertainty about their interpretation or application. We would welcome additional EU guidance or clarifications on: - Art 4.1. refers to “financial year considered” and “financial year concerned” in respect of the definition of capital expenditures: i.e. “For the purposes of this paragraph, capital expenditures shall mean either additions to fixed tangible and fixed intangible assets during the financial year considered before depreciation, amortisation and any re-measurements, including the additions resulting from revaluations and impairments for the financial year concerned, (…).” It is unclear how these notions have to be understood. Our understanding (also based on earlier works of the TEG on the EuGB) is that no look back restriction is applicable in relation to capex allocation , and the proposed wording may therefore be confusing; and - how to check and demonstrate compliance with the DNSH and minimum safeguards criteria (for both EU and non-EU assets) on the basis of some concrete examples.
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Meeting with Thierry Breton (Commissioner) and

10 Sept 2021 · Clean energy transition

Meeting with Pascal Canfin (Member of the European Parliament)

23 Jun 2021 · Green Deal

Response to Commission Delegated Regulation on taxonomy-alignment of undertakings reporting non-financial information

2 Jun 2021

ENGIE welcomes the opportunity to comment this draft delegated act specifying the content and presentation of information to be disclosed under article 8 of the Taxonomy Regulation (“DA”). We support the overall objective of the Taxonomy reporting obligations and at large of the Sustainable Finance Action Plan, as we recognize that disclosing information in a comparable, relevant and reliable way may further support the transition towards more sustainability and reaching the EU Green Deal objectives. Any disclosure should however not only be meaningful and relevant for the stakeholders but also not place a disproportionate burden on undertakings considering cost and administration. The disclosure requirements should be sound and clear to apply, proportionate; coherent with existing financial reporting practices and with the requirements put forward under the Taxonomy Regulation (“TR”). We particularly welcome the phased-in approach towards the reporting obligations as proposed by the Commission for the first two climate objectives which is paramount to allow firms not only to familiarize with the technical screening criteria (“TSC”) for qualification as environmental sustainable economic activities but also to allow them to set-up and/or change existing reporting tools (see also recital 57 of the TR). A similar phasing-in of the reporting on the Complementary Delegated Act and the four remaining environmental objectives (once these are adopted) should apply and be explicitly provided in the current DA. Whereas the DA improved clarity on some topics, we believe it still falls short as regards usability, coherence and proportionality. In this respect, we have identified following key concerns. 1) The disclosure requirements exceed the legal requirements pursuant to article 8 of the TR that requests an undertaking to publish only information on “how and to what extend the undertaking’s activities are associated with economic activities that qualify as environmentally sustainable”. Reporting on activities other than those that are Taxonomy-aligned goes beyond the scope of article 8 TR. The TR does further not set forth any obligation to report on an undertakings’ future objectives and targets for the KPIs and their plans to achieve them (as per § 1.2.3.4 – Annex 1 DA). The proposed overreporting is not only disproportionally complex and burdensome, it also raises serious concerns about having to disclose commercially sensitive information that risks materially impacting the competitive position of EU firms if it were to be made public. Any reporting beyond what is set forth under article 8 TR should be on a voluntary basis only, and companies should have certain flexibility in the way they present additional information. 2) Requiring companies to publish the KPIs for the previous 5 years (article 9.3) constitutes an excessive and complex burden without proven benefit for the potential end-user. TSC and accounting norms are bound to evolve: reporting over a 5 years’ period would entail complex and recurring re-assessment leading to non-comparable and inconsistent data over time. The focus should be on reporting annual data from the previous year (N and N-1) conform to financial reporting standards, and explain (in a qualitative manner) the main changes occurred. 3) The KPIs linked to turnover and CapEx do not allow companies to account for a portion of turnover generated through and/or CapEx investments made in joint ventures accounted for under the equity method, which unduly deprives companies to be rewarded and recognized for a portion of their sustainable investments which may be significant. Companies should be allowed to reflect a portion of the revenue and CapEx in (at least) material joint ventures pro rata their equity stake in the joint venture. 4) Overall lack of materiality concept: activities not being material should not have to be reported. More detailed comments on the DA can be found in the Annex.
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Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton)

17 May 2021 · Hydrogen alliance; fit for 55 package

Response to Enhancement of European policy on critical infrastructure protection

7 Apr 2021

ENGIE Group’s response to the public consultation on the proposal for a directive on the resilience of critical entities ENGIE welcomes the proposal of the European Commission for a directive on the resilience of critical entities, as ENGIE is particularly involved in the subject as member of the ad hoc steering committee of OECD. Indeed, for years, the facts have shown that the public authorities and private companies could be victims of threats or expected/unexpected shocks that can disrupt the functioning of vital activities of the EU internal market European, which is more and more integrated. ENGIE agrees to extend the scope of intervention to ten major economic sectors, considering the energy sector was already covered by the directive 2018/114/CE. Furthermore, ENGIE welcomes the extension, in the energy sector, to the different sub sectors, including renewable energies and decentralized systems. To this end, taking into account the energy sector as a whole is important, considering that the energy transition is profoundly modifying the sector in Europe and that resilience has to be a priority for all operators and not just incumbent operators. It is particularly relevant to take into account the cascade effects in a market open to competition with regulated network operators. ENGIE considers important to reinforce the cooperation between public and private sectors, at national and European levels, by setting up specific group for cooperation, reporting and reaction to threats and shocks. If the risk assessment is already an usual practice for ENGIE, resilience should be focused on the four following items: identification and anticipation, mitigation and moderation, crisis management and planification of the responses. To that end, ENGIE considers that the group dedicated to “critical entities resilience” should be composed not only of representatives from the Member States and the European Commission but should also include representatives of European professional associations which are relevant for each focused economic sector (article 16). The Directive should also recommend to set up such a group at the national level as part of the governance of national strategies (article 3). Concerning the identification of the critical entities by each Member State, ENGIE considers that: - a subcategory should include the sub-contractors which are essential to enhance the requested resilience (article 3), - in addition to the voluntary template for reporting provided by its services (article 4), the Commission could also elaborate a global template for building resilience plan, that already exists in some Member States, - moreover, as regards district heating and cooling (Appendix 1), considering DHC networks (i) are mostly not interconnected between Member States, (ii) do not affect the operation of electricity and gas networks, (iii) have variable sizes and thus variable effect on consumers in case of failure, and (iv) do not automatically affect other critical services (such as health institutions) depending on national law , only DHC networks with a global contracted power above 100 MW should be taken into consideration by Member States for the purpose of the identification of critical entities.
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Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

22 Mar 2021

ENGIE supports the revision of the EPBD to be in line with the increased EU energy & climate ambition for 2030 and coherent with the actions proposed in the renovation wave strategy. To fulfil these objectives, the option 3 proposed by the Commission seems the most appropriate one, the current legal framework being insufficient. Building sector can play a critical role to meet this target. Increasing buildings energy efficiency allows to strengthen energy security and better address seasonal demand variations, to bring down energy bills, to improve life quality and to create local jobs. It also has other additional benefits like reducing CO2 emissions. EE actions should be the prerequisite for any other decarbonization measures by applying the “EE first principle”. The building performance cannot be evaluated in terms of energy efficiency only, but also in terms of energy load on the network. We recommend that it be evaluated especially at times when the electrical grid is under stress, to evaluate the contribution of the building to the overall efficiency of the energy system. We also recommend its hourly, daily and monthly flexibility capacity to be evaluated as well in order to rightly manage demand side at these various time steps. The current EPBD sets the common general framework for the calculation of buildings energy performance. It rightly refers to primary energy as the main performance indicator, based on primary energy factors to be set at national level. If accurately determined and periodically revised, the PEF must be kept in the next upcoming revision for assessing, among different energy options, the carbon-abatement cost effectiveness. Besides current key indicators relating to the energy performance of buildings, new ones measuring GHG emissions of new buildings could be studied, as well as the performance of the building envelope or the performance of energy systems in kWh of primary energy. The case of housing with high energy bills must be treated as a priority to address energy poverty. For these “passoires thermiques”, bans on rental or increase in rents may be relevant or eventually retrofit obligations, provided that substantial financial aid is implemented. The current legislation allows to consider renewable energy supplied through energy carriers as well as renewable energy sources generated on site. Both being necessary for improving energy efficiency and reducing GHG emissions, this non-discriminatory treatment should be kept, even whether minimum levels of RES were proposed in the building sector. It is important to improve buildings energy performance through renovation actions, but the promotion of solutions allowing effective energy management (to keep energy performance over time) is important as well. It is useful to foster across EU Energy Performance Contracts that guarantees the achievement of key energy performance by taking them into consideration when considering the revision of EPBD. They are far from being implemented to their fully potential and not harmonized across EU. It is essential too that the upcoming revision promotes a district approach for the renovation of buildings. It is important to link renovation operations with local energy planning, in particular when it comes to H&C networks. In this framework, the availability and the profitability of various energy solutions [geothermal energy, gas (including green gas & waste heat recovery), heat pumps)] can be fully considered and investment decisions easier to get, compared to building-by-building renovation. At this local level, the possible interactions between various types of infrastructures and fuels can be identified, thus allowing the introduction of a smart sector integration concept. At last, the EPBD revision must address present barriers to the installation of charging points in buildings (right incentives for investments should be developed and collective charging infrastructures should be installed).
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Response to Revision of the NIS Directive

18 Mar 2021

ENGIE welcomes the proposal for a directive on cybersecurity. We believe it is important to give the entities targeted by NIS2 the ability to define which essential services and activities need to be better protected and which are the most important computer systems and networks that support them. Methodologies and homogeneous benchmarks applicable across the EU for making such a selection using a risk-based approach would be useful and could lead to better harmonization. The objective to apply the same level of cybersecurity to all its services and all its information systems regardless of their size does not seem realistic. The extension of the scope to renewable energy generation and district heating and cooling activities risks impacting this area of activity. Indeed, the text brings a level of requirements that necessitate significant financial and human investments to implement and maintain compliance. In fact, a slowdown in the development of this market is possible due to the loss of profitability generated on already very tight margins. This could lead to reconsidering the investments made or planned. The current level of demand and the development foreseen in NIS2 risks accentuating an existing phenomenon of discrimination. The financial and human investment efforts imposed by compliance are very difficult to bear for small SME-sized entities. Provision should be made for the possibility of adapting the measures or specifying the eligibility criteria for actors. To avoid a market massification or the disappearance of small players, a graduated application rather than zero or total application depending on the size of the company or its turnover is desirable. The application of NIS2 and its provisional timetable seems hardly realistic. The context of changes in the scope of activities concerned (particularly in the electricity sector and hot and cold networks) and changes in the scope of Information Systems that must be compliant will require time and consequent investment in terms of finance and taskforce to achieve compliance. The sector already suffers from a major shortage of available skills. The constraints imposed by NIS2 will require the development of cybersecurity skills which are not available either today or in the short or medium term. A gradual, prioritized and studied implementation of the text should be studied in order to maximize its applicability and adoption by the actors concerned. The risk of very heavy penalties for non-compliance does not appear to be the best and only possible approach. A more incentive system based, for example, on bonuses / penalties could be more productive and motivating. As NIS2 lacks information about how and whether cybercriminals will be identified and tracked by the EU, companies alone cannot manage and bear the costs associated with this threat. It would be profitable for everyone if results in terms of penalization were established and operational means in place to maintain them: agreements with the countries concerned, identification and prosecution of these crimes to prevent this lucrative practice from continuing to develop. Homogeneity of transpositions is necessary. Harmonization of approaches could be achieved through the implementation of a European certification based on a benchmark common to all the Member States, the objective being to ensure uniform security for a given service throughout the entire EU but also with a minimum level for non-EU partners. The obligation to notify CSIRT of cybersecurity events that may lead to an incident or may have a significant impact in the future seems difficult to apply because it is difficult to determine in advance whether an event may have a significant impact and offers little cybersecurity capacity building. Regarding customer information, it appears more relevant to warn them about proven risks after a thorough analysis, rather than to increase the number of communications based on weak signals.
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Response to Revision of EU rules on Gas

10 Mar 2021

Please find attached ENGIE's position paper on the Hydrogen and Gas Decarbonization Package
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Meeting with Pascal Canfin (Member of the European Parliament)

1 Mar 2021 · Green Deal

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

21 Dec 2020

To begin with, ENGIE fully supports the European Commission’s work to turn the fight against climate change also into an opportunity to develop EU’s industrial excellency and growth. For this reason, ENGIE encourages the revision of the current Communication on important projects of common European interest to make sure that all available tools to support the Union’s action are exploited, and to provide the appropriate framework for private actors to accompany the Union in its action. In this regard, we wish to bring to the Commission’s attention the following reactions in relation to the problems highlighted in the Roadmap : - The expected spillovers from an IPCEI based on the specific criteria 23 of the Communication should receive further guidance. Expected contribution towards the EU’s climate and industrial objectives could be included for instance, especially referring to the EU Green Deal, the Industrial Strategy, the Smart Sector Integration Strategy, the Hydrogen Strategy, but also the TEN-E regulation. This component would furthermore facilitate the combination with different sources of support, such as the Innovation Fund which already has this requirement. - Precisely by mentioning the possibility to finance an IPCEI with structural funds orother EU funds under shared management, and allowing a combination with other centrally managed EU funds (Innovation Fund, CEF, Horizon Europe, etc.) would strengthen the European character of IPCEI. - The calls for expression of interest launched by interested Member States should be more transparent and standardized both in their calendar and requirements. This would enable the relevant undertakings to anticipate the type of information required, and give them sufficient time to produce that information. This increased transparency of the expected requirements would promote the collaboration between projects located in different Member States by (i) facilitating the matching of the compatible technological bricks which are expected to structure the IPCEI, (ii) provide a level-playing field of supported technological bricks between Member States, and (iii) increase the European dimension of IPCEI (not only the addition of national projects). In order to develop an IPCEI which will be able to support EU policies, and contribute to the achievement of the Union’s objective, it is paramount to tailor the eligible costs to the barriers of the sector supported. In the case of hydrogen, the OPEX should be eligible for support for projects developed under the point 23.
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Response to Climate change mitigation and adaptation taxonomy

11 Dec 2020

ENGIE is a global player in the energy market and leader in the energy transition. We are fully committed to the 2050 climate neutrality goal and support the EU sustainable finance agenda; of which the EU Taxonomy is an important building block. Whilst notable improvements were made to the technical screening criteria (“TSC”), significant shortcomings persist. If these are not tackled appropriately in the final delegated acts, it will make the EU Taxonomy covering only a very small niche market of green activities, foregoing the massive contribution other renewable and low carbon technologies and transitional activities can bring to a cost-efficient, resilient and socially inclusive energy transition. Our key concerns relate to: 1) the generation of power/heat from gaseous fuels, which is qualified as “transitional” activity where it is meeting the “green” threshold of 100grCO2e/kWh as proposed by the TEG. • Firstly, since natural gas has a key role in the quick decarbonization of the energy sector (coal-to-gas switch) and system resilience with increased intermittent renewable energy, a dedicated threshold for gas as transitional activity, allowing a credible decarbonization trajectory, should be set at 250gr CO2e/kWh (LCA) in average of the economic lifespan of the asset. • Secondly, all gas-assets that have GHG emissions below 100grCO2e/kWh (due to increased volume of renewable and low carbon gases) should be considered as “environmental sustainable” and not referred to as “transitional”. • Thirdly, the DNSH criteria set under the climate change adaptation (Annex 2) should be set at a GHG emission level corresponding to 270grCO2e/kWh direct emissions in average over the (remaining) economic lifespan of the asset. 2) the treatment of bioenergy as transitional activity, and the introduction of stricter GHG emissions savings criteria than those recently introduced by REDII. Sustainable bioenergy is a renewable and dispatchable source of energy with numerous positive externalities and needed to integrate renewable electricity in the system. It should be explicitly referred to as significantly contributing to climate change mitigation as per article 10.1. of the Taxonomy Regulation. It is not justified to treat sustainable bioenergy differently from other renewable energies. The TSC should also be aligned with the sustainability criteria of REDII. 3) the overly restrictive GHG emissions savings threshold for the manufacture of hydrogen, which risks ruling out the use of solar energy for the production of green hydrogen through electrolysis, undermining the EU Hydrogen Strategy’s ambitions. The manufacture of hydrogen should be eligible if meeting a threshold of at least 4.4tCO2e/tH2, in line with the CertifHy methodology (60% GHG emissions saving requirement relative to a fossil fuel comparator of 91gCO2e/MJ H2). 4) Mobility: Since the transport sector represents 26 % of total GHG emissions in the Union, the EU should embrace and incentivize any technology that can contribute to the energy transition in that sector starting today, including stimulating existing sustainable renewable gaseous and liquid fuel solutions that have the immediate potential to reduce GHG emissions, mainly for those modes of transport where there is no credible alternative today (e.g. heavy-duty road, maritime transport). We regret that the Commission has adopted a biased stance as regards transport, whilst considering direct tailpipe emissions only, excluding other low carbon options such as (bio)CNG/LNG. The latter can have lower well-to-wheel emissions than electrical vehicles because of the carbon-intensity of the electricity generation. For a more detailed analysis, we kindly refer to the attached paper. We call upon the Commission to make the required changes to the delegated acts to ensure that the EU Taxonomy is as inclusive as possible and can take up its future role in guiding the EU economy in the energy transition.
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Response to Revision of the Energy and Environmental Aid Guidelines (EEAG)

10 Dec 2020

Europe is striving to become the 1st carbon-neutral region by 2050 with ambitious targets already for 2030 on GHG reduction, renewables and energy efficiency that are subject to upward review. These targets are reflecting energy policy objectives. As they cannot be delivered through market forces alone, complementary cost-effective measures are needed, including the creation of enabling regulatory and market frameworks and financial support. Carbon pricing is a key tool to support decarbonization but will not be sufficient. To achieve a GHG reduction target of 55% by 2030 all levers have to be activated, including energy efficiency, renewable electricity, renewable and low-carbon gases and district heating and cooling. Many of the solutions required are new or at least not yet largely deployed and competitive (such as renewable H2, pyrogazification, CCUS, etc.) and need to scale up in order to support a rapid growth and to realize cost reduction potentials. Even for well-proven and mature technologies (e.g. production of renewable electricity or biomethane from anaerobic digestion), a pure merchant approach will not bring forward the necessary volumes needed to achieve political targets. The business cases remain too uncertain for investors. This could be linked to inappropriate market designs (e.g. short-term markets vs long-term investment cycles), market distortions (taxes, network tariff design, etc.), the lack of sufficient sector integration, missing internalization of externalities, etc. Moreover, enabling technologies needed to integrate intermittent renewables in the system (assets providing back-up and flexibility) and to ensure the policy target of security of supply, are facing similar issues. Addressing these shortfalls by their root causes (i.e. by improving market design, removing distortions, fostering sector integration, internalizing externalities) is necessary and challenging, but will not be sufficient to deliver on the policy targets (e.g. decarbonization, security of supply). A framework for state aid is therefore needed. It should be applied in a competitive, market-based and least distortive way, notably for the most mature assets. Besides, the total cost of energy transition for consumers should be kept under scrutiny. This requires paying attention to system integration costs, externalities and impacts on other sectors, and not only to the cost of individual projects (LCOE). Support should be made available if needed to all solutions contributing directly or indirectly to the energy transition, without “picking winners” at an early stage. However, different solutions are de facto not competing on a level playing field, due to different stages of maturity and development or due to the distortions explained above. Purely technology-neutral approaches tend to overlook this aspect and jeopardize a cost-efficient transition in the long run. For instance, renewable H2 is not cost-competitive today with other forms of low-carbon H2, while it is a key solution to decarbonize hard-to-abate sectors in the future. It could therefore be promoted specifically to trigger scale effects and cost reduction. Similarly, dispatchable biomethane (with numerous positive externalities for agriculture, waste management, circular economy, etc.) and variable renewable electricity are fully complementary and should not be put in competition and compared on a simple LCOE-basis. Finally, renewable electricity should continue to benefit from technology-specific tenders, which provide better visibility to investors and allow exploiting complementarities across technologies (such as complementary production profiles for better system integration, etc.). For similar reasons, we advise against linking state aide with the EU taxonomy as the latter does not take a system-wide perspective recognizing the complementarity of different decarbonization solutions and does not sufficiently value the contribution of transition technologies.
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Meeting with Pascal Canfin (Member of the European Parliament) and Compagnie de SAINT-GOBAIN

3 Dec 2020 · Renovation wave

Response to Revision of the CO2 emission standards for cars and vans

26 Nov 2020

Europe is striving to become the first carbon-neutral continent by 2050 and as a key milestone on this path, the European Commission proposes to raise the greenhouse gas (GHG) reduction target for 2030 to at least 55%. Transport is identified as one of the sectors which need to step up efforts urgently. ENGIE supports this very ambitious target. However we would like to highlight that the challenge is immense and requires to activate all levers. The share of electricity in transport and other sectors is expected to increase substantially – which requires massive development of renewables to achieve real decarbonization. The related challenges in terms of cost and feasibility are already visible today: Heavy investments in networks and back-up capacities are needed to integrate renewable and developers are increasingly facing serious issues with permitting/delays and acceptance. To make the energy transition feasible and cost-effective, complementary decarbonization options have to be used next to renewable electricity, notably renewable and low-carbon gases/fuels. In transport, all solutions with a credible decarbonization potential will be necessary, including electricity, gas ((bio)CNG, (bio)LNG) and clean hydrogen, as each of them has its benefits and limits. All these solutions need to be increasingly based on renewable and low-carbon sources and must be able to compete on a level playing field. This is however not the case, due to the tailpipe approach to measure CO2 emissions in transport. Battery-electric and fuel cell vehicles are considered “zero emission vehicles”, even though they can come along with a significant carbon footprint. The electricity mix is still based on fossil sources by almost 50% and emissions related to battery production are important. Hydrogen can be produced from renewable or fossil sources, with or without CO2 abatement. As these impacts are neglected by the CO2 standards, OEMs have a strong incentive to invest primarily in such vehicles. In contrast, gas vehicles operating on biomethane (bioNGVs) have a very good climate balance which is not taken into account by the tail-pipe methodology. The CO2 emitted at the tailpipe of bioNGVs has been absorbed from air during the growth process of the biomass. The balance of what is called a “short carbon cycle” is therefore neutral and this should be taken into account also in the CO2 standards (as is already the case in other EU legislation, e.g. the EU ETS). In certain cases, for instance, when biomethane is produced from liquid manure or bio wastes, the total GHG emissions can be zero or even be negative. These examples show that a correct and meaningful comparison of the climate impact of different solutions requires a life cycle analysis or at least a well-to-wheel approach. Revision of the CO2 emissions standard regulation: Despite being a valid scientific argument, we recognize the difficulties of introducing a full Well-to-Wheel approach in the revision of this regulation. But we insist on the need to integrate an appropriate methodology to recognize the climate benefit of renewable and low-carbon fuels, as already provided for in Art. 15 of the regulation. The CO2 credit generated should be available to OEMs to demonstrate that investments in dedicated CNG and LNG vehicles, are contributing beyond the simple tailpipe benefit. This acknowledgement must lead to a “net-zero” emission vehicle labelling, equivalent to the current “zero” level recognized only to full electric solutions. It is important to recall that it is not sufficient, albeit necessary, to promote renewable gases and fuels through the Renewable Energy Directive as this directive does not affect vehicle manufacturers. OEMs need to have a clear incentive to continue developing NGV models which should be counted towards their CO2 reduction target reflecting the full climate benefits of the use of renewable gases.
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Meeting with Pascal Canfin (Member of the European Parliament)

23 Nov 2020 · Taxonomie

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

28 Oct 2020 · Decarbonisation, Taxonomy

Meeting with Thierry Breton (Commissioner) and

14 Oct 2020 · Stratégie d’ENGIE et plan de relance européen

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

21 Sept 2020

ENGIE's point of view : The impact assessment accompanying the Commission’s communication on stepping up Europe’s 2030 climate ambition showed that the increased ambition for GHG reductions by 2030 would also require higher Energy Efficiency ambition. Furthermore, the first Commission’s EU-wide assessment of national energy and climate plans, underlined that although the collective ambition for 2030 in the EE field has been increased compared to the scenario from the Member States’ draft plans, there remains a gap compared to the Union’s 2030 target of at least 32,5%, which still stands at 2,8% for primary energy consumption and at 3,1% for final energy consumption. Efficient use of energy is key to achieve the European Green Deal targets. It is also a privileged tool for successfully implementing the Paris Agreement. However, the present headline targets embedded in the EED seem insufficient to reach the ambitious although essential European objectives. To address the gap to the existing 2030 targets, ENGIE supports the possible revision of the EED, setting up at European level a higher (35%) and binding EE target. Such a compulsory framework would allow Member States and investors to have a LT perspective to adapt their strategies and plan their projects with greater certainty. The introduction of additional non-regulatory alternative policy instruments (training, information dissemination, awareness raising campaigns, financing measures) can also be considered, but not as a sole solution (options 3 & 2). The revision of specific targeted provisions of the EPB directive can also be envisaged. ENGIE considers that more focus is needed on primary energy consumption, as primary energy is the real indicator of the energy effectively consumed. To achieve this, the PEF used to have an actual view of implemented energy policies must remain a technical tool, with a value based on a real assessment of the evolution of the power mix and not become a policy instrument based on an expected theoretical value. To favor positive and long-lasting structural changes able to boost the effectiveness of the EED, other provisions, in conjunction with the forthcoming renovation wave initiative, would potentially be considered: - Greater consistency between energy savings and climate objectives. - Vigilance, about CO2 emissions, on the production means planned to get through the winter electrical peaks. - Promotion of active energy management and energy performance contracting, with simplified contractual models, to ensure energy performance. - The generalization of energy saving certificates (white certificates) to boost renewal of obsolete energy equipment. - Fast implementation of national long-term renovation strategies including stringent measures as regards building sector (energy or environmental performance standards for instance). The role of public bodies must be exemplary and ENGIE expects that the scope of the current annual renovation rate obligation (3%) be extended to all public bodies’ levels. - Greater consideration of the local dimension in the decision making. Local and integrated energy planning must be fostered to facilitate and accelerate renovation of buildings whose decision making is more difficult at individual level. At district level, the optimum of all energy carriers could be found to answer local demand and integrate other important issues like green mobility. - Implementation of sustainable renovation support mechanisms allowing for phased renovations. - Better focus on all the potentialities of heating and cooling networks as regards energy savings and decarbonation. For instance, waste heat recovery should be promoted both on industrial sites and via a district and cooling networks thus promoting a circular economy. - Appropriate financing mechanisms to offset the lack of trust and of guarantee mechanisms for investments in EE operations which are characterized by often long payback times and low rates of ROI.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

21 Sept 2020

ENGIE welcomes the opportunity to participate to this consultation allowing to stimulate reflections on how a revised Renewable Energy Directive (RED) can effectively contribute to a more integrated energy system which should enable the achievement of greenhouse gas (GHG) reduction targets and carbon-neutrality by 2050 at lowest cost for society, while ensuring security of supply. Energy efficiency, renewable electricity, district heating and cooling, renewable and low-carbon gases, as well as infrastructures for transport and storage, are key pillars of this integrated energy system. In particular, the development of renewable and low-carbon gases is lagging behind and has to be accelerated, which requires an appropriate regulatory framework, as well as European and national funding and support mechanisms. The Energy System Integration Strategy released on 8 July 2020 correctly outlines that the uptake of biogases has been hampered by regulatory uncertainty. ENGIE firmly believes that a revision of the RED should provide clear signals for the development of biogas/biomethane, notably through targets as described below. In addition, further measures should be envisaged (outside RED II) for instance to promote the valorization of agricultural residues into biogas through the Common Agricultural Policy etc. The Hydrogen Strategy sets a very clear signal for the development of hydrogen, with priority for renewable hydrogen and a transitory and complementary role for non-renewable, low-carbon hydrogen. ENGIE is convinced that both renewable and non-renewable, low-carbon hydrogen are needed to achieve Europe’s ambitious climate targets towards a full decarbonization. For example, CCUS can play a role to swiftly decarbonize grey hydrogen currently used in industry and will help to kickstart the market, paving the way for future large-scale deployment of renewable hydrogen. Nevertheless, separate policy approaches are required to promote hydrogen from electrolysis of renewable power on the one hand and low-carbon hydrogen on the other. Renewable hydrogen is less competitive than low-carbon hydrogen today but has many specific virtues and a significant cost reduction potential in the future. Therefore, each type of hydrogen needs its own support policy. The RED II Directive 2018/2001 in force is hence a key piece of legislation to implement crucial elements of the Energy System Integration and Hydrogen Strategies and its assessment and revision need to go further than adjusting the level of the 2030 headline target for renewable energies (RES). It should be evaluated in a holistic approach, taking into account different options regarding the “legislative architecture for an integrated energy system” - part of which is the RED II - but also other legislation, such as the internal market directives on electricity and gas, EU ETS and Effort Sharing directives, as well as potential new legislation (e.g. a dedicated hydrogen directive). A sound assessment is needed on which measures should be included in which legislation in order to take into account the respective features and challenges of renewable and low-carbon gases/fuels while at the same time ensuring coherent rules and swift implementation. Please consult our position paper attached for our concrete recommendations regarding the upcoming assessment and revision of RED II, notably: - the future target architecture including an increased RES headline target, a sub-target for renewable gases as well as sector-specific measures - a comprehensive methodology for renewable and low-carbon gases which is partly already implemented in RED II (for biogas/biomethane) but needs to be complemented for instance on renewable hydrogen, etc. - guarantees of origin and certificates - specific demands for the heating & cooling sectors - clarifications regarding sustainability and GHG reduction criteria for bioenergy
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Response to Empowering the consumer for the green transition

31 Aug 2020

ENGIE welcomes the European Commission's initiative to enhance the empowerment of consumers in line with the Green Deal action plan. ENGIE Group is dedicated to supporting its clients' commitment to the green transition in many ways by helping our customers to use energy more efficiently and reducing their CO2 emissions through a broad range of solutions for energy and beyond. Energy efficiency first principle should be one of the key measure to reach the 2050 targets of decarbonisation. In this area, consumer will play an active role in the green transition by taking informed decisions about their consumption pattern for heating, cooling, transport… Digitalisation of services and products will also help a better and a more accurate use of energy. Consumer will be more and more guided by the information procured by online IT tools and applications. Further requirements to make those information easy for users and reliable including criteria to ensure the transparency or reliability of such tools could be necessary. The share of energy from renewable sources - for both electricity and gas - is growing across the EU and more and more consumers are showing a rising interest for such products. Whilst renewable electricity is already widely produced and distributed in Europe, renewable gas is a vector for decarbonisation and the valorisation of farmlands. The cross-sectoral circular economy takes on its full meaning by allowing the use of agricultural residues for energy production. It is therefore of utmost importance to ensure a reliable and trustworthy information offering a conclusive proof of the source of energy. Labelling of unit of energy and certification of generation installation is the starting point of a secured system which should be harmonised across Europe. To avoid greenwashing and proliferation of sustainability labels, ENGIE supports guarantees of origin system developed in cooperation with NRA in a minimum harmonisation instrument. Energy markets are now almost liberalised across Europe. To guarantee a level playing field and to leave some freedom to suppliers to develop competitive offers of products and services, ENGIE would like to highlight the importance of a well-balanced regulation in the field of consumer protection within the EU. For that reason we are considering that the impact assessment conducted by the European Commission should address part of option 1 proposal (amendment on existing EU consumer legislation CPD and CRD) to provide information requirements but also, as defined in option 2, establish specifications on more detailed information on products’ sustainability and to ensure transparency and reliability of digital tools.
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ENGIE pushes for binding renewable gas targets and green labels

5 Aug 2020
Topic — EU strategy to reduce methane emissions across the energy, agriculture, and waste sectors.
Message — ENGIE proposes binding renewable gas targets and renaming the strategy to focus on emissions. They also advocate for including methane reduction costs within the scope of regulated activity.123
Why — This allows the company to recover costs through regulated tariffs and access EU subsidies.45
Impact — Consumers might pay more as methane reduction costs are integrated into regulated tariffs.6
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Response to Sustainable and Smart Mobility Strategy

16 Jul 2020

ENGIE is convinced that all solutions with a credible decarbonization potential will be necessary in the transport sector, including (green) electricity, (green)methane and (green) hydrogen. It is important to take a holistic view on cost and benefits of different options for the customer and society, and create a level playing field. An LCA or at least well-to-wheel approach is indispensable for a comparison of the real climate impact. The tailpipe approach currently used does not take into account GHG emissions along the fuel chain (production and transport of the fuel/electricity) nor those related to the vehicle cycle (vehicle/battery production, end of life). As it does not matter for the climate when and where GHG are emitted, terms like “zero tailpipe emission vehicles” are misleading. Without life cycle or well-to-wheel assessment, vehicles using biomethane and synthetic renewable gas are put at a disadvantage. Such vehicles emit CO2 at the tailpipe, which has been absorbed from air during the growth process of the biomass. This represents a “short carbon cycle” which should be considered carbon-neutral (as is the case already in EU legislation, for instance in the EU ETS). When biomethane is produced from liquid manure or bio wastes, the total GHG balance is even negative. A tailpipe approach thus “only tells half of the story”. Electricity, hydrogen and CNG/LNG have the potential to be fully decarbonized. Renewable and decarbonized electricity is available and further developing, although at different speed across Europe. The greening of gases including hydrogen is high on the agenda. In countries like Denmark, Sweden and the Netherlands, gas vehicles already use almost exclusively biogas (shares > 90%). Germany, Finland and UK are well above 50% biogas share. Different studies such as ADEME for France or Navigant for Europe show that total gas consumption (including for transport) can be fully decarbonized by 2050. A supportive regulation and financial incentives are needed to accelerate the shift, prioritizing different alternative fuels for different segments and transport modes: E-mobility is the key solution for cars and light commercial vehicles. Renewable power is also suitable for emission-free inland shipping. Progressively there could be some electrification also of heavier vehicles (buses, trucks) for peri-urban uses as well as development of hydrogen mobility. These would complement CNG vehicles, which remain the most cost-efficient and immediately available alternative to Diesel in this segment. CNG vehicles are compatible with an increasing blend or 100% biomethane, which has many positive externalities next to GHG and pollutant reduction, e.g. for agriculture, jobs, local and circular economy. When it comes to long-haul HDV (trucks, coaches and vessels), the relevant options are increasing the share of biodiesel, a switch to (bio)LNG, or green hydrogen as compressed hydrogen, liquid hydrogen, or liquid synthetic methane depending on the required range. This switch is a no regret option allowing up to 20% GHG reduction with LNG and up to 90% with bioLNG. Moreover, an LNG fleet is fully ready to accommodate green hydrogen in form of liquid synthetic methane or, with minimum retrofit, in form of ammonia. Diesel trains for which electrification is not an option could be replaced by (bio)LNG and green hydrogen. Alternative fuel mobility relies on a well-functioning energy system. Large-scale development of charging/refuelling stations has to be planned and integrated in the system avoiding negative impact on system stability and security of supply. The upcoming strategy should take into account risks and limitations in this regard and solutions have to be developed.
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Response to Revision of the EU Emission Trading System Monitoring and Reporting Regulation (MRR)

16 Jul 2020

Upfront remark: Please refer to our position paper in attachment for more detailed explanations and amendments to the text proposal! ENGIE is a global player with a diversified portfolio of activities including power production from renewables and provision of infrastructure for transport, distribution and storage of natural and increasingly renewable/decarbonized gas. We are one of the largest biomethane producers in France, with a significant project pipeline also in other EU Member States and we have high ambitions to develop green hydrogen. We clearly endorse the full recognition of the climate benefits of biomethane in the EU ETS sector through an emission factor of zero for biogas as is already the case for other forms of bioenergy, such as, for instance, solid biomass burnt in power plants. The draft proposal for a revision of the MRR could be further developed to ensure a proper recognition of biomethane in line with the principles of the internal gas market and avoiding unnecessary administrative burden for operators: Only one single methodology to recognize biomethane should be established in order to avoid market distortions and fragmentation within the internal market. This common methodology should be primarily based on the first methodology (i.e. recognition of biomass fed into the gas network on the basis of “purchase records”), as proposed in the amended Art. 39 paragraph 4, with some adjustments: • The possibility to keep using Guarantees of Origin (GOs) as the required “purchase record of biogas” as is the case in the current MRR regulation and as has been implemented by Member States should be made explicit in the text. • GOs should be enhanced to convey also the information about compliance with sustainability requirements. In a first step, this can be done by linking the information on compliance with sustainability and GHG emissions reduction criteria, which is provided through a form of sustainability certification to the GO. • It should be specified in the text that “being connected to the same gas grid” means being connected to the European interconnected gas network, which should be considered as a single logistical facility for the purpose of mass balance calculation. This specification will be more compatible with the functioning of the internal gas market and is allowed by Article 30 of Directive (EU) 2018/2001. The 2nd methodology (biomethane recognition based on a grid mix, as proposed in the amended Art. 39 paragraph 5), should be abandoned as it does not require an active choice by ETS operators to purchase biomethane and destroys the green value of biomethane. It is not compatible with the internal market and risks to create major distortions among ETS operators. It should also not be possible for Member States to refuse the recognition of biomethane used in ETS installations. Last but not least, the implementation of future developments should be prepared and reflected in the MRR. Also other decarbonized gases than biomethane, notably hydrogen and synthetic methane should be recognized properly under the EU ETS. Renewable and decarbonized hydrogen could be blended to a certain extent in gas networks and thus decarbonize the gas consumption of industrial consumer under the EU ETS. Synthetic methane (or “e-methane”), which has been produced from renewable hydrogen by adding CO2, should be considered carbon-neutral if the CO2 was captured from an EU ETS installation where it was already accounted for, or if captured from air. In line with ongoing discussions to extend the EU ETS to the transport sector, provisions in the MRR should allow to consider also the carbon-neutrality of liquified renewable fuels such as liquified biomethane or liquified synthetic methane (under conditions) which is not necessarily transported via the gas network and is a key option to decarbonize transport. Discussions should start urgently on how to adapt rules and definitions to make this possible.
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Meeting with Kadri Simson (Commissioner) and

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

Meeting with Kadri Simson (Commissioner) and

7 Jul 2020 · Energy efficiency, electrification, and biomethane/hydrogen in Energy System Integration and Hydrogen Strategies; overview of ENGIE’s activities in energy transition, their positions on taxonomy and carbon pricing.

Meeting with Pascal Canfin (Member of the European Parliament) and BUSINESSEUROPE

9 Jun 2020 · Green recovery

Response to Union renewable Financing mechanism

3 Jun 2020

ENGIE strongly supports the objective of at least 32% renewables by 2030, and more globally the Union’s commitment to be fully climate-neutral by 2050. We welcome the proposed EU RES Financing Mechanism which can, if well designed, facilitate and accelerate the achievement of these objectives and foster cross-border cooperation. However, the mechanism should not become an excuse for Member States to relax efforts to pursue their targets by developing renewables on their territory and by their own means, via incentives and improved national regulatory frameworks. The robust implementation and enforcement of the Clean Energy Package and the fulfilment of the NECP commitments remain key to unlock renewables’ investments. ENGIE believes that the EU RES Financing Mechanism should seize the opportunity to promote also renewable energy solutions which contribute to sector integration. We therefore welcome the broad set-up of the mechanism which in our understanding can promote, next to renewable power, also renewable heat and renewable gases in all sectors comprising electricity, heating and cooling, transport and industry. Renewable district heating and cooling and renewable gases including gaseous or liquid biomethane, gaseous or liquid synthetic methane and renewable hydrogen, are key technologies for sector integration: Renewable gases are able to decarbonize not only the typical gas end user segments (heating, industrial processes) but also electricity production, road, rail and waterway transport. Moreover, such gases are a perfect complement to match with wind and solar electricity production, respond to the seasonal swings of demand and ensure the security of supply of the power system. In the specific cases of long haul road or maritime transport, in order to replace oil, LNG is the only available decarbonization option in the short term and it could increasingly be mixed with bioLNG. However, most renewable gases are emerging technologies which have not benefitted from large amounts of financial support in the past and which promise substantial cost reductions and technology leadership in Europe. The proposed Mechanism should therefore help to kickstart and accelerate the demonstration, pre-commercialization and commercial uptake of these gas-oriented technologies. Regarding the functioning of the mechanism, first experiences with cross-border tendering have shown that it remains challenging for different options to compete on an equal footing, as different technologies (e.g. wind and solar) or different energy carriers (e.g. renewable power and renewable gases) are exposed to different conditions in different countries or even within one country (regarding for instance, network tariffs, taxes, permitting rules, etc.). Moreover, technologies which are at different stages of maturity should not be put in direct competition as this would hinder the development of less mature but promising solutions. ENGIE therefore strongly supports technology-specific or project-specific tenders, as long as there is no real level playing field between technologies, energy carriers and sectors – which is a precondition for efficient sector integration and system optimization. Where tenders organized pursuant to this gap-filler mechanism have a broader scope in terms of technologies/sectors, it should be considered to compare them based on broader system cost rather than focusing only on the cheapest price (like e.g. LCOE or LCOH) or investment cost. Finally, for emerging technologies like green hydrogen, production support granted through the EU mechanism should be completed by targets to boost demand e.g. sector-specific objectives. ENGIE approves the importance of linking this program to other EU financing instruments. Synergies can clearly be made with the Innovation Fund, CEF, IPECI and Horizon Europe. However, these potential combinations should be explicit in the calls, and guidance should be provided to project promoters.
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Meeting with Virginijus Sinkevičius (Commissioner) and

3 Jun 2020 · To discuss the Green Recovery and Blue Economy issues relevant for the energy sector.

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

26 May 2020 · Energy policy and green deal

Meeting with Mariya Gabriel (Commissioner)

19 Feb 2020 · European Research Area, digital scientists, creative sectors and innovation in the new Horizon Europe programme

Meeting with Olivier Guersent (Director-General Financial Stability, Financial Services and Capital Markets Union)

22 Nov 2019 · Sustainable Finance

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

10 Oct 2019 · Presentation of ENGIE energy transition strategy and energy efficiency

Response to Revising the rules for free allocation in the EU Emissions Trading System

1 Jul 2019

Article 5 paragraph 1 : “That adjustment shall apply as of the year following the two calendar years used for determining the average activity level, and provided that the adjustment is at least 100 emission allowances”. It should be clarified if the 100 emission allowances threshold is to be calculated on the emission allowances of the first year for which allocation is modified, or cumulated on all subsequent years of the period. Article 5 : add a paragraph 7, stating the following : “For the period from 2021 to 2025, for the application of paragraphs 1 to 4 of this article 5, heat benchmark sub-installations non exposed to carbon leakage and district heating sub-installation should be considered together as only one sub-installation”. The purpose of this paragraph is the following : When considering the heat delivered to industrial customers, declared as heat benchmark sub-installations non exposed to carbon leakage, we have not necessarily been able to check if it was used for process or totally or partially for heating of the industrial buildings. A verifier could want to check on this point, and if it finds that the heat is in fact used for heating and not process, would displace the activity level from heat benchmark sub-installation to district heating sub-installation. This may possibly generate undue adjustment of allocations. The limitation to the period from 2021 to 2025 is justified by the fact that the calculation of emission allowances is identical for heat benchmark sub-installations non exposed to carbon leakage and district heating sub-installation on this period.
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Response to Free allocation of emission allowances

21 Nov 2018

Please see attached file (includes pictures)
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Meeting with Adam Romanowski (Cabinet of Vice-President Maroš Šefčovič)

14 Nov 2018 · Market Design Directive

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

26 Oct 2018 · Market Design

Meeting with Violeta Bulc (Commissioner) and

20 Sept 2018 · Clean mobility issues

Meeting with Juraj Nociar (Cabinet of Vice-President Maroš Šefčovič)

18 Sept 2018 · ENERGY UNION

Meeting with Dominique Ristori (Director-General Energy)

18 Jul 2018 · clean energy transition

Meeting with Dominique Ristori (Director-General Energy)

18 Jan 2018 · Clean Energy policy development

Meeting with Frans Timmermans (First Vice-President)

18 Jan 2018 · Energy Union

Meeting with Helena Braun (Cabinet of First Vice-President Frans Timmermans), Riccardo Maggi (Cabinet of First Vice-President Frans Timmermans)

18 Jan 2018 · Energy transition Sustainability: challenges for European compagnies and EU

Meeting with Juraj Nociar (Cabinet of Vice-President Maroš Šefčovič)

9 Nov 2017 · Energy Union

Meeting with Jocelyn Fajardo (Cabinet of Commissioner Violeta Bulc)

9 Nov 2017 · Meeting with Pierre Mongin, Secrétaire Général d’ENGIE

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

9 Nov 2017 · Clean Energy Package as well as CO2 pricing

Meeting with Miguel Arias Cañete (Commissioner) and IBERDROLA

17 Jul 2017 · Winter Package

Meeting with Maroš Šefčovič (Vice-President) and

21 Jun 2017 · Nordstream2

Meeting with Denis Cajo (Cabinet of Vice-President Neven Mimica)

8 Jun 2017 · Renewable Energy in Africa

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

2 Jun 2017 · Gas market in Hungary

Meeting with Dominique Ristori (Director-General Energy)

29 May 2017 · Energy policy

Meeting with Miguel Arias Cañete (Commissioner) and Vattenfall and

7 Feb 2017 · Decarbonization of Transport electric-vehicules

Meeting with Manuel Szapiro (Cabinet of Vice-President Maroš Šefčovič)

13 Jan 2017 · Energy Union innovation

Meeting with Miguel Arias Cañete (Commissioner) and ELECTRICITE DE FRANCE and

22 Nov 2016 · ETS reform

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

15 Nov 2016 · Electricity Market Design

Meeting with Dominique Ristori (Director-General Energy) and ENEL SpA and

27 Sept 2016 · Energy policy

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

9 Sept 2016 · Security of gas supply

Meeting with Jos Delbeke (Director-General Climate Action)

5 Sept 2016 · Revision of the EU ETS

Meeting with Manuel Szapiro (Cabinet of Vice-President Maroš Šefčovič)

25 Aug 2016 · Energy Union research Innovation and competitiveness

Meeting with Maroš Šefčovič (Vice-President) and

19 Jul 2016 · Electricity Market Design, ETS

Meeting with Miguel Arias Cañete (Commissioner) and EPIA SolarPower Europe and

24 May 2016 · Business Forum EU-ALGERIA

Meeting with Dominique Ristori (Director-General Energy)

8 Mar 2016 · Energy Union

Meeting with Miguel Arias Cañete (Commissioner) and ENEL SpA and

23 Feb 2016 · 2nd EU Energy Summit - breakfast roundtable

Meeting with Pierre Moscovici (Commissioner)

20 Jan 2016 · European economic outlook and energy infrastructure projects.

Meeting with Dominique Ristori (Director-General Energy)

24 Nov 2015 · European energy policy

Meeting with Mette Toftdal Grolleman (Cabinet of Commissioner Jonathan Hill)

21 Oct 2015 · CRR exemption of commodity dealers

Meeting with Mathieu Fichter (Cabinet of Commissioner Corina Crețu)

20 Oct 2015 · Cohesion policy in France

Meeting with Dagmara Koska (Cabinet of Vice-President Maroš Šefčovič), Manuel Szapiro (Cabinet of Vice-President Maroš Šefčovič)

12 Oct 2015 · Energy Union and Hydroconcessions

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

12 Oct 2015 · Internal Energy Market

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

12 Oct 2015 · politique énergétique - énergie renouvelable

Meeting with Dominique Ristori (Director-General Energy) and Eni S.p.A. and

6 Oct 2015 · European energy policies

Meeting with Jean-Claude Juncker (President) and

1 Oct 2015 · Meeting with Mr Etienne Davignon on political priorities of this Commission

Meeting with Miguel Arias Cañete (Commissioner) and

17 Sept 2015 · Investment in Algeria

Meeting with Miguel Arias Cañete (Commissioner) and

4 Sept 2015 · Security of supply and Energy diversification

Meeting with Dominique Ristori (Director-General Energy) and TotalEnergies SE and

4 Sept 2015 · gas and oil

Meeting with Martin Selmayr (Cabinet of President Jean-Claude Juncker)

18 Jun 2015 · Etienne Davignon - Political priorities of this Commission

Meeting with Dominique Ristori (Director-General Energy)

18 May 2015 · Energy Union

Meeting with Jean-Claude Juncker (President)

8 May 2015 · Meeting with Etienne Davignon on political priorities of this Commission

Meeting with Martin Selmayr (Cabinet of President Jean-Claude Juncker)

8 May 2015 · Meeting with Etienne Davignon on political priorities of this Commission

Meeting with Maroš Šefčovič (Vice-President) and IBERDROLA and

21 Apr 2015 · Energy Union

Meeting with Maroš Šefčovič (Vice-President) and

20 Apr 2015 · Gas storage

Meeting with Martin Selmayr (Cabinet of President Jean-Claude Juncker)

17 Apr 2015 · The macroeconomic orientation of the Juncker Commission compared to the Delors Commission

Meeting with Pierre Moscovici (Commissioner) and

20 Mar 2015 · Economie Circulaire

Meeting with Martin Selmayr (Cabinet of President Jean-Claude Juncker)

27 Feb 2015 · Current EU Issues

Meeting with Maroš Šefčovič (Vice-President) and

3 Feb 2015 · Energy Union

Meeting with Miguel Arias Cañete (Commissioner) and

14 Jan 2015 · Energy Union and Internal Energy Market

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

11 Dec 2014 · Introducing GDF SUEZ

Meeting with Dominique Ristori (Director-General Energy) and ENEL SpA and

11 Dec 2014 · European Energy Policy priorities