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Equinor ASA

EQNR

Equinor is a leading international energy company focusing on oil, gas, and renewables.

Lobbying Activity

Equinor urges clarity and technology neutrality in new Competitiveness Fund

12 Nov 2025
Topic — EU proposal for €234 billion European Competitiveness Fund for 2028-2034 industrial decarbonisation.
Message — The company requests that ECF maintain distinct legal mandates for existing programs like Horizon Europe and Innovation Fund, preserve technology neutrality including transitional solutions like CCS and blue hydrogen, and provide grant-heavy financing rather than loans for first-of-a-kind projects. They want multiannual work programs adopted before end-2027 to avoid funding gaps.1234
Why — This would allow them to secure predictable grant funding for their capital-intensive CCS and hydrogen infrastructure projects.56
Impact — Purely renewable technology providers may face more competition if transitional fossil-based solutions remain eligible.78
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Meeting with Bruno Tobback (Member of the European Parliament) and Tingvoll

4 Nov 2025 · Panel Discussion on offshore wind deployment in the North Sea

Meeting with Maroš Šefčovič (Commissioner) and

28 Oct 2025 · Priorities of the EU’s trade agenda

Equinor urges market-based approach to EU energy security framework

13 Oct 2025
Topic — Revision of EU energy security legislation for decarbonised, integrated energy systems.
Message — Equinor requests prioritising EEA cooperation, market-based frameworks over rigid EU targets, integrated infrastructure resilience, and practical supply chain diversification. They warn against excessive reporting obligations and prescriptive requirements that could hinder flexibility and deter investment.123
Why — This would reduce compliance costs and preserve commercial flexibility for Norway's gas exports.45
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Meeting with Chiara Galiffa (Cabinet of Commissioner Maroš Šefčovič) and WindEurope and

7 Oct 2025 · US and EU Trade Relations concerning tariff rates on the steel industry, specifically the wind energy sector

Equinor recommends integrating nature credits with carbon markets

30 Sept 2025
Topic — This consultation addresses the development of a roadmap for international nature credit markets.
Message — Equinor recommends building on the existing Carbon Removals and Carbon Farming Regulation framework. They suggest a single registry for both credits to maximize project development efficiency. They also request including offshore industry representatives within the relevant expert group.123
Why — A unified system would reduce administrative complexity and streamline certification for energy developers.4
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Energy trader Equinor calls for CBAM electricity rules reform

25 Sept 2025
Topic — EU methodology for calculating emissions under the carbon border adjustment mechanism.
Message — The company requests shorter reference periods for default emission factors, clearer rules for claiming actual emissions with power purchase agreements, and urgent clarification on deducting carbon prices paid in third countries. They want written confirmation of the phase-in rate for electricity imports.123
Why — This would reduce administrative costs and remove uncertainties for cross-border electricity trading.45
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Equinor urges flexible recognition of third-country carbon pricing mechanisms

25 Sept 2025
Topic — EU rules for crediting carbon prices paid abroad against CBAM obligations.
Message — Equinor requests that the methodology recognise the widest possible range of carbon pricing systems, including carbon taxes, cap and trade, and hybrid mechanisms. They want regular reviews to reflect carbon market developments and recognition of complementary pricing mechanisms like the UK's Carbon Price Support alongside its ETS.123
Why — This would reduce their CBAM compliance costs for exports from countries with carbon pricing.45
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Equinor Urges EU to Align Carbon Removal Framework with Market Realities

22 Sept 2025
Topic — New EU regulation establishing methodologies for certifying permanent carbon removal activities like DACCS and BECCS.
Message — Equinor requests extending activity periods to match installation lifetimes, revising the economic viability test to focus on feedstock sustainability rather than profitability, and clarifying eligibility for cross-border storage providers. They argue current timelines and restrictions risk excluding viable projects and fragmenting the market.123
Why — This would reduce regulatory uncertainty for Equinor's CCS investments across Europe and enable use of their Norwegian storage infrastructure.456
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Equinor urges EU to align global carbon removal standards

11 Sept 2025
Topic — The consultation establishes the EU’s global climate and energy strategy for the 2025-2029 period.
Message — Equinor requests alignment of carbon removal methodologies between the European Union and United Kingdom. They also seek clarity on using certified removals for corporate climate claims and reporting.12
Why — Standardized rules would allow Equinor to leverage its carbon capture investments and unlock international projects.34
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Equinor urges EU to prioritize cross-border CO2 transport rules

11 Sept 2025
Topic — Legislative initiative to develop competitive CO2 markets and transportation infrastructure for CCUS.
Message — The company requests priority for removing cross-border CO2 transport barriers and opposes regulating offshore transport and storage as natural monopolies. They argue onshore pipelines need regulated access, but offshore infrastructure faces competition from multiple providers and shipping options.123
Why — This would preserve commercial flexibility for their offshore CO2 infrastructure investments and storage projects.45
Impact — Smaller emitters lose stronger regulatory protections ensuring equal access to offshore CO2 infrastructure.67
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Equinor welcomes EU expansion of carbon cost compensation to chemical producers

4 Sept 2025
Topic — State aid guidelines for compensating electricity costs due to EU carbon pricing.
Message — Equinor supports expanding eligibility for indirect cost compensation to chemical industries, specifically organic chemical production including methanol and bio-methanol. They argue these national schemes are essential for European industrial competitiveness.12
Why — This would allow them to deliver competitively priced methanol to European markets.3
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Equinor Urges Integrated EU Infrastructure Planning and Permit Reform

4 Aug 2025
Topic — This consultation addresses measures to upgrade, digitalize, and expand European energy grids.
Message — Equinor requests an integrated approach to planning electricity, hydrogen, and CO2 networks. They propose ending first-come, first-served grid access and streamlining permits through one-stop shops. They also recommend a phased regulatory approach for emerging carbon capture markets.123
Why — Faster permitting and risk-reduction measures would protect the economics of Equinor's multi-billion-euro offshore projects.45
Impact — National energy consumers may face higher bills if congestion revenues are diverted from offsetting domestic tariffs.6
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Equinor urges technology neutrality and gradual procurement shifts in IDAA

8 Jul 2025
Topic — The consultation addresses EU efforts to accelerate industrial decarbonisation and boost sector competitiveness.
Message — Equinor calls for a technology-neutral framework where low-carbon options are evaluated on equivalent metrics. They advocate for a gradual introduction of sustainability criteria in public procurement to allow adaptation.12
Why — This would reduce investment risks for large carbon capture and hydrogen infrastructure projects.3
Impact — Conventional carbon-intensive manufacturers may lose market share to competitors using low-carbon labels.4
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Equinor Urges Increased Funding and Simpler Rules for Innovation Fund

8 Jul 2025
Topic — The European Commission is evaluating the performance and effectiveness of the EU Innovation Fund.
Message — Equinor argues the budget needs to be increased and the application process should be less complex. They also support introducing a guaranteed income stream for projects.123
Why — Increased grants and price guarantees would help the company secure investments for high-risk energy projects.45
Impact — Clean-tech developers lose market opportunities when high demand leads to project rejection.67
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Equinor seeks carbon removal integration and UK market linkage

8 Jul 2025
Topic — The review evaluates the EU Emissions Trading System to meet higher climate targets by 2030.
Message — Equinor seeks integration of certified carbon removals and a UK market link. They also advocate for granular benchmarks and continued free allowances.123
Why — These changes safeguard industrial competitiveness while unlocking investment for Equinor’s carbon capture projects.45
Impact — Inefficient industrial plants lose out if the EU adopts more granular product benchmarks.6
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Meeting with Joaquim Nunes De Almeida (Director Internal Market, Industry, Entrepreneurship and SMEs)

19 Jun 2025 · Decarbonisation and CCS

Meeting with Beatriz Yordi (Director Climate Action)

18 Jun 2025 · Carbon markets

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

10 Apr 2025

PART A Stakeholder experience overview. Equinor views the STEP Seal as a valuable recognition mechanism intended to unlock additional financial support for strategic projects. Our H2BE and H2M Eemshaven projects received the STEP Seal under Innovation Fund calls, demonstrating they are critical to advance a clean EU hydrogen economy (kicking-off in Belgium and the Netherlands, respectively). Both in Belgium and The Netherlands, the financial mechanisms and structured follow-up are still missing. The seal, while symbolic, has not translated into actionable support. Thus, despite STEPs recognition of the projects strategic value to EU sovereignty, Equinor recommends stronger national support to avoid unnecessary gaps between STEPs objectives and their practical implementation. Key obstacles identified: 1) Absence of financial and procedural mechanisms to operationalize the STEP Seal at Member State level. 2) Low level of coordination and support at MS level. 3) Alignment between STEP-supported sectors and evolving policies is essential (see point 3, Part B). PART B Evaluation criteria-based feedback. 1) Relevance: Both H2BE and H2M align with EU decarbonization goals. However, current policy priorities do not explicitly include low-carbon hydrogen, limiting support for scalable industrial solutions and reducing STEPs relevance. 2) Effectiveness: The STEP Seal has not yet led to tangible benefits, and developing policies remain non-technology neutral. Demand-side aid is tied to unrealistic thresholds (e.g., ~50-60% renewable hydrogen), hindering industrial adoption. 3) Coherence: Projects like H2BE and H2M are supported by current regulatory framework, e.g., the Low Carbon Fuel Standard (LCFS) Delegated Act, which recognizes low-carbon hydrogen with CCS as a valid solution. However, as policies evolve, such as the CISAF draft (New State aid Framework accompanying the Clean Industrial Deal Communication), which outlines how Member States can support STEP seal projects awarded through the Innovation Fund, they are being shaped by existing legislation (i.e., RED II Directive (EU) 2018/2001) that may not fully accommodate the potential of low-carbon hydrogen projects. This has led to questions among Member States regarding the eligibility of such projects for support. Therefore, Equinor recommends ensuring timely alignment between STEP and CISAF, prior to its definitive implementation, enabling effective support for these innovative decarbonization solutions. 4) Efficiency: Effort invested in securing the STEP Seal has not resulted in concrete support. Misalignment with national mechanisms creates inefficiencies, forcing promoters to navigate additional complexities without the intended support. 5) EU Added Value: H2BE and H2M offer significant EU-wide benefits, including energy independence and industrial transformation. However, these benefits remain unrealized without adjustments to the State Aid framework, requiring harmonized implementation and inclusive eligibility criteria to unlock STEPs potential. Part C Recommendations. 1) The European Commission should actively engage in ongoing consultations to ensure that ad hoc guidelines do not exclude STEP Seal-awarded projects from receiving support, regardless of their technological choices. Better alignment between STEPs strategic objectives and the evolving State Aid framework must be ensured. 2) Establish interim EU-level support protocols for STEP Seal holders when Member State mechanisms are absent. 3) Define a minimal service protocol at MS level, ensuring follow-up and timely connection of STEP Seals to financial instruments. 4) Enable mechanisms for project promoters to directly communicate with STEP Taskforce when national channels are inactive.
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Meeting with Ditte Juul-Joergensen (Director-General Energy) and WindEurope and

8 Apr 2025 · Wind energy, electrification, competitiveness, permitting, grids

Meeting with Kurt Vandenberghe (Director-General Climate Action)

7 Apr 2025 · exchange on how EU climate policies can enable the adaptation of key sectors in Europe, including the transition to a low carbon economy

Meeting with Chiara Galiffa (Cabinet of Commissioner Maroš Šefčovič), Jan Hendrik Dopheide (Cabinet of Commissioner Maroš Šefčovič)

19 Mar 2025 · Renewable energy industry in the US and European supplier industry

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

19 Mar 2025 · clean industrial deal and energy

Meeting with Vesa Terävä (Head of Unit Secretariat-General)

19 Mar 2025 · Equinor explained its views on renewables roll-out, CCS and hydrogen deployment.

Meeting with Hilde Vautmans (Member of the European Parliament)

12 Mar 2025 · security north sea

Meeting with Vytenis Povilas Andriukaitis (Member of the European Parliament)

12 Mar 2025 · EU Policy

Meeting with Andrea Wechsler (Member of the European Parliament)

11 Mar 2025 · EU Energy and industry policy

Meeting with Dan Jørgensen (Commissioner) and

10 Mar 2025 · Energy situation in US and Europe

Meeting with Jutta Paulus (Member of the European Parliament, Shadow rapporteur) and EPIA SolarPower Europe and

7 Mar 2025 · Security of Energy Supply

Response to Delegated act on primarily used components under the Net-Zero Industry Act

20 Feb 2025

Equinor welcomes the opportunity to provide feedback to the secondary legislation of the Net-Zero Industry Act (EU 2024/1753). The consulted implementing acts and delegated act are key to clarify the conditions for developers and operators of net-zero technology projects. Equinor is an international energy company headquartered in Norway. Our ambition is to be a leading company in the energy transition, by making energy sustainable and available to all. We are the single largest individual supplier of energy to Europe, a world-leading offshore operator, and an international pioneer in renewables and low-carbon solutions. Today, in an increasingly unpredictable world, the energy we deliver provides a vital and stabilising contribution to Europes energy security. In our commitment to become a net-zero energy company by 2050, low carbon solutions such as hydrogen and carbon capture and storage (CCS), along with renewable energy generation, play a critical role, while offering a huge potential to European industries for cutting their emissions and preserving their competitiveness. We provide comments covering two net-zero technologies: CSS and hydrogen. Please refer to the cover letter attached in which we outline our key messages and the annex with our detailed text recommendations with corresponding justifications.
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Response to Implementing Act on non-price criteria in renewable energy auctions

20 Feb 2025

Equinor welcomes the opportunity to provide feedback on the secondary legislation of the Net-Zero Industry Act (EU 2024/1753). Equinor is an international energy company headquartered in Norway. Our ambition is to be a leading company in the energy transition, by making energy sustainable and available to all. We are the single largest individual supplier of energy to Europe, a world-leading offshore operator, and an international pioneer in renewables and low-carbon solutions. Today, in an increasingly unpredictable world, the energy we deliver provides a vital and stabilising contribution to Europes energy security. In our commitment to become a net-zero energy company by 2050, low carbon solutions such as hydrogen and carbon capture and storage (CCS), along with renewable energy generation, play a critical role, while offering a huge potential to European industries for cutting their emissions and preserving their competitiveness. The consulted implementing acts and delegated act are key to clarify the conditions for developers and operators of net-zero technology projects. We provided comments covering three net-zero technologies: on and offshore wind and electrolysers. Please refer to the cover letter attached in which we outline our key messages and the annex with our detailed text recommendations with corresponding justifications.
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Response to List of net-zero technology final products and their main specific components

20 Feb 2025

Equinor welcomes the opportunity to provide feedback on the secondary legislation of the Net-Zero Industry Act (EU 2024/1753). Equinor is an international energy company headquartered in Norway. Our ambition is to be a leading company in the energy transition, by making energy sustainable and available to all. We are the single largest individual supplier of energy to Europe, a world-leading offshore operator, and an international pioneer in renewables and low-carbon solutions. Today, in an increasingly unpredictable world, the energy we deliver provides a vital and stabilising contribution to Europes energy security. In our commitment to become a net-zero energy company by 2050, low carbon solutions such as hydrogen and carbon capture and storage (CCS), along with renewable energy generation, play a critical role, while offering a huge potential to European industries for cutting their emissions and preserving their competitiveness. The consulted implementing acts and delegated act are key to clarify the conditions for developers and operators of net-zero technology projects. We provided comments covering two net-zero technologies: on and offshore wind. Please refer to the cover letter attached in which we outline our key messages and the annex with our detailed text recommendations with corresponding justifications.
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Meeting with Yannis Maniatis (Member of the European Parliament)

11 Feb 2025 · Introductory Meeting

Meeting with Dārta Tentere (Cabinet of Commissioner Maroš Šefčovič)

16 Jan 2025 · Economic Security

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

5 Dec 2024 · To discuss European wind industry

Equinor urges EU to protect gas infrastructure and market stability

26 Nov 2024
Topic — A fitness check evaluating the EU legislative framework for ensuring energy security.
Message — Equinor recommends that natural gas networks be properly maintained and developed where necessary. They support funding policies that emphasize technology neutrality and caution against intervening in price setting.123
Why — Equinor safeguards its natural gas business while securing subsidies for its renewable energy transition.45
Impact — Environmental groups lose if the EU delays the decommissioning of fossil fuel infrastructure.6
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Meeting with Niels Flemming Hansen (Member of the European Parliament)

21 Nov 2024 · Energy infrastructure

Meeting with Eszter Lakos (Member of the European Parliament) and NOVE

18 Nov 2024 · EU energy policy

Meeting with Hildegard Bentele (Member of the European Parliament)

18 Nov 2024 · Energy Policy

Equinor Urges Reform of EU Low-Carbon Fuel Rules to Unlock Investment

25 Oct 2024
Topic — Consultation on a new methodology for assessing life cycle greenhouse gas emissions of low-carbon fuels.
Message — Equinor requests that the Commission consistently allow for the use of certified greenhouse gas intensity values instead of only relying on default values. They also call for a grandfathering rule for projects taking final investment decisions before 2030 to ensure regulatory certainty.12
Why — This would prevent their projects from being unfairly disqualified as low-carbon due to inaccurate default emission values.34
Impact — Environmentally conscious producers lose out when a lack of certified data fails to reward their actual emission reductions.5
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Meeting with Sigrid Friis (Member of the European Parliament)

16 Oct 2024 · upcoming Commissioner-Designate hearings and shared interests in energy security and green transition

Meeting with Bruno Gonçalves (Member of the European Parliament) and CIP - Confederação Empresarial de Portugal

11 Sept 2024 · ITRE policies

Meeting with Ondřej Krutílek (Member of the European Parliament)

17 Jul 2024 · EU climate and energy policies (2024-2029)

Meeting with Aleksandra Baranska (Cabinet of Vice-President Maroš Šefčovič), Dino Toljan (Cabinet of Vice-President Maroš Šefčovič)

15 May 2024 · Role of CCUS in the green transition

Meeting with Maroš Šefčovič (Executive Vice-President) and

16 Apr 2024 · IOGP Roundtable

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

14 Mar 2024 · Energy market

Equinor calls for technology-specific auctions and UK recognition

1 Mar 2024
Topic — EU guidance on using qualitative criteria in renewable energy auctions.
Message — Equinor recommends treating floating and bottom-fixed wind as distinct technologies with specific auctions. They argue pre-qualification must require offshore-specific experience, including projects in the United Kingdom.123
Why — Recognizing UK experience helps Equinor leverage its North Sea portfolio to win tenders.45
Impact — Onshore developers and newer entrants are sidelined by strict offshore-only experience requirements.6
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Meeting with Maroš Šefčovič (Executive Vice-President) and

5 Feb 2024 · High-Level roundtable with Suppliers

Meeting with Maroš Šefčovič (Executive Vice-President) and

9 Jan 2024 · Hydrogen

Response to Persistent organic pollutants – Annex I amendment

22 Dec 2023

Equinor is a broad international energy company that aims to be a leader in the energy transition and a net-zero company by 2050. Our efforts in providing new low-carbon solutions and technologies also have the potential to assist other economic actors reduce their own emissions, and therefore contribute towards the EUs climate neutrality ambition. With respect to the draft delegated regulation on Persistent organic pollutants, aimed at updating the criteria related to Perfluorooctane sulfonic acid and its derivatives (PFOS), currently listed in the so-called PFOS entry under Annex I to Regulation (EU) 2019/1021, we would like to share the following: The revised UTC (unintentional trace contaminant) on 1 mg/kg for PFOS in new substances, mixtures and articles put on the market is in general supported. However, while feasible for new installations, implementing this UTC level for firefighting foams on existing oil and gas installations may cause adverse economic consequences. On existing installations where PFOS has been substituted in firefighting foam (first by PFAS based foams and later fluoro-free foams), the storage tank and distribution pipelines are contaminated with PFOS. Experience has shown complete cleaning to this UTC level is impossible without prolonged stop of production, and possibly a decommissioning of the installation would be required. Therefore, for stockpiles as described in Regulation (EU) 2019/1021, an UTC of 10 mg/kg PFOS would be a realistic upper limit.
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Meeting with Adam Romanowski (Cabinet of Vice-President Maroš Šefčovič)

6 Nov 2023 · energy

Equinor urges EU to prioritize fast, low-cost CCS projects

31 Aug 2023
Topic — EU strategy for carbon capture, utilisation and storage deployment to achieve 2050 climate neutrality.
Message — The company requests support for projects deployable quickly and cost-efficiently, without predefining which industries can use CCS. They argue policies should facilitate all value chain parts and avoid restricting technology deployment based on ideology.123
Why — This would allow Equinor to develop North Sea storage infrastructure and expand its CO2 transport capacity to 15-30 Mtpa by 2035.45
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Equinor calls for flexible deadlines for EU carbon storage

27 Jun 2023
Topic — The Net Zero Industry Act proposal aims to scale up green technology production.
Message — Equinor requests a value chain approach covering capture and transport, not just storage. They also want the flexibility to use carbon storage sites across the entire European Economic Area.12
Why — This would allow Equinor to leverage its existing Norwegian infrastructure to meet EU requirements.3
Impact — Environmental goals could suffer if companies are permitted to delay mandatory carbon injection deadlines.45
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Meeting with Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans) and ExxonMobil Petroleum Chemical and

25 Apr 2023 · Energy, environmental and digital challenges of our time

Equinor urges clarity on carbon removal certification definitions and eligibility

20 Mar 2023
Topic — EU framework for certifying carbon removals from ecosystems and industrial solutions.
Message — Equinor requests precise definitions that separate removals from reductions, clarification on which solutions qualify, and flexibility to include emerging technologies. They want all CDR options eligible and clear treatment of cross-border storage.1234
Why — This would ensure their diverse carbon removal technologies and cross-border projects qualify for certification.56
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Meeting with Maroš Šefčovič (Executive Vice-President) and

10 Mar 2023 · EU Energy Platform

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 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 Ditte Juul-Joergensen (Director-General Energy)

9 Nov 2022 · Security of supply and the EU Energy Platform

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

7 Nov 2022 · Clean energy transition and RePower, including gas diversification, CCUS, hydrogen and renewable power investments

Meeting with Kadri Simson (Commissioner) and

27 Oct 2022 · Levels of Equinor's gas supply, security of supply risks, energy transition, hydrogen projects.

Meeting with Bjoern Seibert (Cabinet of President Ursula von der Leyen)

19 Oct 2022 · Energy situation in Europe

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

19 Oct 2022 · Energy situation in Europe.

Meeting with Kadri Simson (Commissioner) and

10 Oct 2022 · Investment opportunities in Algeria for EU companies.

Meeting with Martin Hojsík (Member of the European Parliament, Shadow rapporteur)

5 Oct 2022 · Methane Regulation

Meeting with Bjoern Seibert (Cabinet of President Ursula von der Leyen)

2 Oct 2022 · - Energy - Security of supply - pricing and decarbonization

Meeting with Jens Geier (Member of the European Parliament, Shadow rapporteur) and NOVE

5 Sept 2022 · Vorschlag einer Verordnung über die Verringerung von Methanemissionen im Energiesektor

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

5 Aug 2022 · EU - Norway cooperation on gas, CCUS and hydrogen

Meeting with Arunas Ribokas (Cabinet of Commissioner Virginijus Sinkevičius)

13 Jul 2022 · To discuss the state of play of implementation of the EU Arctic Strategy

Meeting with Esther De Lange (Member of the European Parliament)

5 Jul 2022 · Green Deal

Meeting with Pascal Canfin (Member of the European Parliament)

21 Jun 2022 · Green Deal

Equinor urges removal of 2035 fossil carbon feedstock deadline

17 Jun 2022
Topic — This consultation defines the methodology for assessing greenhouse gas savings from recycled fuels.
Message — Equinor asks the Commission to delete or extend the 2035 deadline for fossil feedstock. They argue that capital-intensive projects require longer investment cycles and clear rules for direct air capture.1
Why — This protects their long-term capital investments in complex industrial carbon reduction projects.2
Impact — Environmental efforts lose if large-scale emission reduction projects are abandoned due to uncertainty.3
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Equinor urges EU to support CCS alongside nature-based carbon removals

29 Apr 2022
Topic — New EU regulation on certifying carbon removals from ecosystems and industrial solutions.
Message — The organization requests that both emission reductions and removals be supported, including CCS technology from fossil sources. They argue reduction technologies should not be deferred and recommend including reduction credits in a future EU carbon market compatible with the EU ETS.12
Why — This would enable them to monetize their existing CCS technology and infrastructure investments.34
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Meeting with Seán Kelly (Member of the European Parliament) and European University Institute

26 Apr 2022 · Fit for 55 Package

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

4 Apr 2022

Equinor is the largest gas producer on the Norwegian Continental Shelf (NCS), and the second-largest gas supplier in Europe. The combined gas volumes from Equinor and the SDFI (the Norwegian state’s gas volumes) constitute more than 20% of the gas market in Europe. Equinor’s total methane intensity for all our operated activities is 0.02%, one tenth of the OGCI average of 0.2% . The methane intensity of the Norwegian gas delivered to Europe, from production to where the gas enters the EU is less than 0.02%. The International Methane Emission Observatory (IMEO) concluded in its 2021 report that Equinor’s methane emission reporting for assets in Norway is at gold standard. Independent research of oil and gas installation on the NCS demonstrated excellent alignment between site-level measurements and the operator reported emissions, derived from predominantly source-based quantification methods. The aircraft measurement campaign was executed as part of the Climate and Clean Air Coalition (CCAC) Methane Science Studies Programme and the results were published November 2021. The existing good regulatory and industry practise in Norway was also confirmed in the latest IEA Methane tracker report (February 2022). Equinor supports the European Commission’s effort to: (i) advance the availability, quality, and reliability of methane emission data; (ii) ensure that operational routines are in place to minimise emissions; and (iii) reduce imported methane emission from international operators. The proposal can be improved in several respects, which are outlined the attached document.
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Meeting with Morten Petersen (Member of the European Parliament)

9 Mar 2022 · Hydrogen and decarbonised gas market package and Methane Emmissions Regulation

Meeting with Kadri Simson (Commissioner) and

23 Feb 2022 · Industrial decarbonisation, hydrogen market and sustainable carbon cycles.

Meeting with Valdis Dombrovskis (Executive Vice-President)

23 Feb 2022 · Oil and gas supply, carbon capture storage, low carbon energy, including blue hydrogen.

Meeting with Adina-Ioana Vălean (Commissioner) and

22 Feb 2022 · Maritime fuels, liquid hydrogen projects, blue ammonia projects and CCS technologies

Meeting with Kadri Simson (Commissioner) and

4 Feb 2022 · Brief discussion on TAP’s current capacities and future expansion options for the shipment of gas to Europe.

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

18 Nov 2021

Please find our feedback in the attached file.
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Meeting with Arunas Ribokas (Cabinet of Commissioner Virginijus Sinkevičius)

28 Oct 2021 · The implementation of the EU offshore energy strategy and reform of the renewables energy directive; Equinor’s contribution to a sustainable blue economy as well as hybrid offshore wind opportunities in Europe; EU Arctic Strategy Communication

Equinor urges EU to embrace technology-based carbon removal solutions

7 Oct 2021
Topic — EU initiative to certify carbon removals and promote climate-friendly farming practices.
Message — Equinor requests the Commission maintain technology neutrality and include both nature-based and technology-based solutions in the certification framework. They emphasize that achieving net-zero by 2050 requires carbon reductions and removals at unprecedented scale, with support for carbon capture and storage technologies.123
Why — This would validate their existing carbon capture investments and create markets for their technology-based removal solutions.45
Impact — Nature-based solution providers lose if technology-based approaches receive equal or preferential treatment in the certification scheme.6
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Response to Revision of EU rules on Gas

10 Mar 2021

We thank you for the opportunity to provide feedback to the combined evaluation roadmap/inception impact assessment on the Hydrogen and Gas Markets Decarbonisation Package . Please find Equinor's feedback in the attached document.
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Response to Revision of the guidelines for trans-European Energy infrastructure

5 Mar 2021

We welcome the opportunity to provide feedback on the revised TEN-E Regulation proposal. Please find our full contribution attached. We recommend for the revised TEN-E Regulation to: Maintain the PCI status of active existing projects. It is not clear what would happen to the Northern Lights PCI under the new TEN-E Regulation proposal. Changing the regulatory conditions for existing PCIs could hamper cooperation with project promoters and affiliates, which could negatively affect project planning. We therefore recommend that the regulatory treatment of the existing PCIs that involve third countries is not changed. Prioritise both PCIs and PMIs for CO2 transport. Given the vast CO2 storage potential in the EU’s immediate neighbouring areas, including the Norwegian Continental Shelf, the TEN-E rules should encourage cost-optimal deployment of CO2 transport and storage infrastructure for the benefit of European industries getting access to the most competitive CCS solutions. Therefore, it is important that the revised TEN-E Regulation ensures that both the EU-only PCIs and those that concern third countries are prioritised and treated equally on the basis of merit for the EU’s energy system. Prioritise both PCIs and PMIs for offshore wind and hydrogen and include EU's partners in regional offshore wind and hydrogen infrastructure planning. Energy infrastructure projects under the TEN-E regulation that involve non-EU countries should not be downgraded to second-class status as this could hamper the EU’s offshore wind and hydrogen ambitions. We recommend for the EU’s regional groups for offshore grid development to be extended to non-EU countries with significant potential for joint offshore wind projects. The same is needed for hydrogen infrastructure planning, as low carbon and renewable hydrogen imports from the EU’s neighbours could be relevant for scaling up hydrogen supply in Europe. Include CO2 shipping in the cross-border CO2 networks thematic area. The reasons for its exclusion provided in the TEN-E Regulation Impact Assessment fall short of objectively justifying why alternative CO2 transport infrastructure could not qualify for CEF support. Shipping solutions add flexibility and are an essential part of the scale-up of a European CO2 transport and storage network as CO2 transport pipelines are not economical for small CO2 volumes. The exclusion of shipping effectively creates double standards for different CO2 transport options, i.e. pipeline vs non-pipeline transport solutions. CEF funding support for cross-border CO2 transport is of fundamental importance for addressing the market failure of insufficient carbon pricing to incentivise investments in GHG emissions reduction. By excluding shipping from the scope, the TEN-E Regulation would allow this regulatory barrier to persist. The Commission has previously argued that CO2 shipping could be covered under the TEN-T Regulation. However, the review process is not aligned with the ongoing TEN-E Regulation and provides little clarity over the scope of the revised TEN-T Regulation and how it would change with regard to CO2 transport. The lack of policy visibility complicates project planning for the existing PCIs and encumbers their communication with project partners. Clarify the purpose of a plan for CO2 transport PCIs. The revised TEN-E Regulation proposal puts forward an obligation for member states to present a plan for the development of cross-border CO2 transport and storage infrastructure to the European Commission. It could be more purposeful to instead include CO2 networks under the Ten-Year Network Development Plans, as has been suggested for hydrogen infrastructure.
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Response to Modernising the EU’s batteries legislation

1 Mar 2021

[ See document attached for full response] Equinor supports the European Green Deal objectives and welcomes the proposal to review the European Batteries Directive, with the aim of ensuring a sustainable and competitive value chain for batteries and of promoting a strong and innovative EU market for batteries. Equinor pursues the ambition to become a net-zero energy company by 2050 and remains committed to providing solutions that help the EU achieve its 2050 climate neutrality. The proposal for a new Battery Regulation is timely and highly relevant. Promoting circularity, recyclability, the ethical and more efficient use of resources and transparency towards consumers becomes essential as the demand for batteries continues growing in Europe. We welcome the ambition to make the requirements mandatory for all batteries placed on the EU market, as it is crucial that a level playing field for European batteries is ensured. However, there are a number of points where we believe clarifications or improvements are needed: - Responsibilities - The battery value chain is complex and encompasses multiple different actors, that is why it is fundamental that certain questions regarding the responsibilities of the different actors are clarified, mainly responsibilities related to the Battery Management System, the collection of batteries, the achievement of recycling targets , the second life of batteries and general clarification on what obligations rest on producers and what on those actors integrating cells into packs or other products. - Carbon Footprint Declaration - For which we strongly recommend that the calculation will be based on life-cycle assessment principles and that primary data is allowed to be used throughout the value chain. - Levels of Recovered Materials and Recovery Targets - We fail to understand what the rationale behind these specific targets is and would appreciate an explanation on what was the basis for the choice, and we recommend to assess some of the potential unintentional consequences that setting those targets could have on meeting future demand. - Reporting and Harmonization - We recommend for the future regulation to be streamlined from an information and reporting perspective, aligned with non-financial reporting requirements, and that it is coherent with other existing legislation relevant for the manufacturing of batteries. [ See document attached for full response]
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Meeting with Christiane Canenbley (Cabinet of Executive Vice-President Margrethe Vestager), Michele Piergiovanni (Cabinet of Executive Vice-President Margrethe Vestager) and

25 Jan 2021 · Commission’s priorities for digital and industrial policy in 2021

Meeting with Stefano Grassi (Cabinet of Commissioner Kadri Simson), Thor-Sten Vertmann (Cabinet of Commissioner Kadri Simson)

21 Jan 2021 · Blue hydrogen solutions in steel industry decarbonisation

Response to Climate change mitigation and adaptation taxonomy

14 Dec 2020

[See attached document for full response] Equinor supports the development of an EU-wide taxonomy that will set out a common language to define environmentally sustainable economic activities, helping investors and businesses mobilise and reorient investments towards more sustainable technologies and projects. Equinor pursues the ambition to become a net-zero energy company by 2050 and remains committed to providing solutions that help the EU achieve its 2050 climate neutrality. As a major European energy supplier and a broad energy company with considerable investment plans in low carbon solutions, Equinor takes interest in contributing to a well-designed EU Taxonomy. Our main recommendations: • The principle of Technology Neutrality should be retained. All sources and technologies that allow life-cycle GHG emissions from the generation of electricity and heat/cool to be below 100gCO2e/kWh should be eligible as environmentally sustainable permanently. • Carbon Capture and Storage (CCS) was one of the technologies specifically included under Article10 of the Taxonomy Regulation as substantially contributing to climate change mitigation, but we note with regret that the draft Delegated Act does not sufficiently support the urgent need to advance CCS in Europe. We strongly encourage the Commission to incorporate capture and permanent storage of CO2, both to reduce anthropogenic emissions and to remove CO2 from the atmosphere, into the Delegated Regulation as an activity that substantially contributes to climate change mitigation. • The proposed definition for transport of CO2 only encompasses the construction and operation of CO2 pipelines, while liquid CO2 can also be transported cost-efficiently in other modalities such as by ship, rail or truck, providing flexibility to reach multiple carbon emission points. We urge the Commission to expand the definition and include “Construction and operation of all CO2 transport modalities, including pipelines, ships, trucks, rail and barges”. • We support the inclusion of a threshold for the manufacture of hydrogen that is technology neutral and that focuses on GHG emission reductions, but we fail to understand the scientific rationale behind the proposed threshold of “life cycle GHG emissions savings requirement of 80% relative to a fossil fuel comparator of 94g CO2e/MJ [2.256 tCO2eq/tH2]” and would appreciate a clarification and an impact assessment from the Commission. • Regarding the manufacture of hydrogen, we strongly recommend the inclusion of both the manufacturing of renewable and low-carbon hydrogen technologies as enabling activities. • We second that the construction and operation of hydrogen storage facilities is considered as environmentally sustainable and suggest including the facilities that store blends of natural gas and hydrogen temporarily as a transitional activity. • TSC proposed for the manufacture of anhydrous ammonia should be aligned with the threshold proposed for the manufacture of hydrogen. • The 'Do No Significant Harm’ to climate change mitigation threshold for the electricity generation from gaseous and liquid fuels should not be set at a lower level than BAT. • Vessels are used extensively in the oil and gas sector and technology developed by the industry, which is at the forefront of technology demonstration for shipping decarbonisation, can be widely spread in the maritime sector. That is why we believe that excluding ships running on low carbon fuels that are used for the transport of fossil fuels could dissuade the sector from investing in reducing its emissions and from innovating. • Achievable timelines are needed to implement the EU Taxonomy in an effective manner. That is why we encourage the Commission to give companies enough time to reasonably adjust to the new reporting obligations, considering the changes in companies’ reporting processes that will be needed, without forgetting the additional challenges caused by the Covid-19 crisis.
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Response to Revision of the Energy and Environmental Aid Guidelines (EEAG)

10 Dec 2020

Equinor welcomes the opportunity to respond to this consultation and the intention of the European Commission to revise the current Guidelines on State Aid for environmental protection and energy 2014-2020 by the end of 2021. Equinor supports an increased EU climate ambition and the European Commission’s efforts to put the European Green Deal at the heart of the post-pandemic economy recovery. The EEAG State Aid Guidelines have the potential to further accelerate the decarbonisation of the energy system by allowing Member States to offer proportional state funding for low-carbon technologies, including CCS, as well as low-carbon and renewables-based hydrogen. The Guidelines have played and will continue to play a key role in enabling the development of offshore wind projects and in supporting the scale-up of offshore wind technologies through technology-specific auctions. Equinor is becoming an increasingly broader energy company with operations spanning across the gas, oil, offshore wind and solar markets. Equinor is today part of several offshore wind, CCS and hydrogen (both low-carbon and renewables-based) projects in Europe. These projects are closely tied to the European energy network and require partly state funding to be realised. To contribute to an accelerated energy transition, Equinor relies on well-functioning energy markets, where state aid rules play a key role in addressing market failure. We support the European Commission’s intention to widen the scope of the current EEAG by organizing the updated rules around broader policy objectives, including the 2050 climate neutrality and the environmental protection goals outlined in the European Green Deal, the protection of security of supply and the prevention of industry relocation risks due to energy related charges. The alignment of the updated EEAG with these priority objectives will enable further technological and market innovations in the future. At current we believe the EEAG are not sufficiently tailored for state-aid to be directed towards large-scale low-carbon gas projects (including for hydrogen), a view well reflected in both the Energy System Integration and Hydrogen Strategies presented by the European Commission. Furthermore, the EEAG should be revised in order to support the new ambitious targets for the deployment of offshore wind set out by the Offshore Renewable Energy Strategy. The revised EEAG should include a dedicated section on hydrogen and low-carbon gases. Following a technology-neutral approach, the definitions of low-carbon and renewables-based hydrogen to be introduced in the revised EEAG should be based on life-cycle emissions criteria. We also consider that the current definition of CO2 energy infrastructure under the current EEAG should be further extended to also include include transport of CO2 by waterborne solutions and other means of transport in addition to pipelines, such as rail or truck. Equinor has a strategic ambition to become a global offshore wind major and a leader in developing floating offshore wind. We actively seek new offshore wind opportunities across Europe. With the right regulatory framework in place, we believe that a target of 300 GW of offshore wind by 2050 is feasible. Key to success will be that EEAG continue to allow for proportional and targeted state aid, facilitating the deployment of offshore wind technologies and accelerating their industrial scale-up in a cost-effective way. It is our view that the use of revenue stabilization mechanisms by Member States will still be required to stimulate new investments in capacity. In order to turn the current EEAG State Aid Guidelines into a fully fit-for-purpose framework that enables a cost-effective reduction of greenhouse gases in the energy system and the deployment of decarbonized energy, we recommend to address a number of topics in the areas of hydrogen, CCS and offshore wind. These topics are outlined and further explained in the attached document.
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Meeting with Marius Vascega (Cabinet of Commissioner Virginijus Sinkevičius)

10 Nov 2020 · Offshore Renewable Energy Strategy and the role of Marine Spatial Planning

Meeting with Alina-Stefania Ujupan (Cabinet of Executive Vice-President Margrethe Vestager), Penelope Papandropoulos (Cabinet of Executive Vice-President Margrethe Vestager)

7 Oct 2020 · Advancing projects and carbon removal technologies in support of the Green Deal

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

8 Sept 2020

[Please see attachment for full response] Equinor is committed to conducting its business in an ethical, socially responsible and transparent manner and aims to demonstrate leadership in transparent reporting. That is why every year we publish our Sustainability Report, in accordance with the Global Reporting Initiative (GRI) Standards, and following guidance from the Task Force on Climate-related Financial Disclosures (TCFD), including an explicit TCFD-aligned cross-reference table that discloses the company’s governance, risk management, strategy and metrics related to climate change. Moreover, since 2015 we have stress-tested our project portfolio against the International Energy Agency scenarios and published the results in our Annual Report. Equinor has received recognition for its performance and disclosures from the Climate Disclosure Project (CDP) and the Institutional Investors Group on Climate Change, among others. We support the development of methodologies and indicators that will help determine the extent to which companies’ economic activities can be considered environmentally sustainable according to the EU Taxonomy. Considering the wide range of financial and non-financial reporting obligations to which large undertakings are already subject, we recommend that the following aspects are considered: - A Coherent Taxonomy – In order to facilitate the reporting on taxonomy-aligned activities, it is important that the technical criteria set by the different delegated acts are coherent across all such acts and avoid ambiguities, and most importantly, that they take into account current and future European regulation. The link between the Taxonomy and other EU legislation – such as the NFRD – should be strictly defined by the delegated acts. - Harmonisation and standardisation – The delegated act should aim at integrating reporting standards and metrics as much as possible, including international ones, and hence avoid punishing undertakings that already strive to be leaders in environmental transparency and reporting. - Substance over form – The dynamic evolution of technology and market and operational circumstances need to be taken into consideration. We therefore recommend that the technical criteria are based on actual lifecycle emissions performance, rather than prescribing rigid categories and preselecting technologies. Furthermore, it should be considered that new reporting requirements will likely lead to increased costs related to the collection, calculation and disclosure of accurate information. It is therefore important that companies are able to provide their contributions in a cost-efficient manner, maintaining the flexible reporting model of the current NFRD. - Flexible timeline – the current ambitioned timeline risks being challenging to achieve: the delegated regulation on taxonomy-related disclosure obligation will be published only in mid-2021 and companies will be expected to report on the financial year 2021 in early 2022. In order to ensure the quality of the reporting, we encourage the Commission to give companies enough time to reasonably adjust to the new reporting obligations, considering the necessary changes in companies’ reporting processes and the additional challenges caused by the Covid-19 crisis. An extended timeline, or at least a phased-in approach with one or two first pilot years, would allow for changes to be made in a cost-efficient, compliant and meaningful manner. - Guidelines – we encourage the development of clear guidelines that would help companies apply the technical screening criteria and disclose their taxonomy-aligned activities. The guidelines should anticipate potential reporting difficulties, for instance how to report on activities that fall into multiple categories or on complex ownership and operational arrangements, such as joint operating agreements.
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Response to Revision of the EU Emission Trading System Accreditation and Verification Regulation (AVR)

9 Jul 2020

Please find our full consultation response in the attachment. We appreciate the opportunity to provide views on the rules for the verification of data and the accreditation for the EU ETS phase 4 trading period. The revision of the Implementing Regulation 2018/2067/EU provides a timely opportunity to include digital visits as an option for verifiers under certain circumstances. There are a number of safety- and quality-assurance-related reasons in favour of digital visits, reaffirmed in the context of COVID-19. In our view, the current rules are too rigid to provide the verifier with the optionality to carry out digital visits as a valid alternative to physical site visits, thereby overburdening the verification and validation process on the part of both the installation and the verifier. Against the backdrop of the COVID-19 pandemic, competent authorities have had limited possibilities to approve waivers for physical site verifications, which in our view increases the health and safety risk on both the verifier as well as the installation part. Digital site visits can be a good alternative to physical visits, which is why they should be added to the scope of the Regulation under specific circumstances. Our experience during phase 3 shows that in certain offshore installations where the activity level and in turn the associated emissions are low in certain years. There is a short time-window, where the physical verification on site is possible, albeit with difficult access to the site. We believe that in such cases, the verifier should be able to decide whether the physical site visit should take place or whether it should be replaced by a digital site visit. In our view, digital site visits should be included in the scope of the Regulation, in particular: 1) when physical site visits pose a risk to the health and safety principles; 2)for low-activity sites with few emissions; 3) for difficult-to-access offshore sites; 4) when modifications to the monitoring plan are not of physical nature but rather concern the handling of data. During phase 3, digital technologies have advanced enough to facilitate live-stream video visits of sites, including for offshore installations. Digital live-stream visits can therefore be used in cases where physical visits are difficult to conduct or pose certain risks. In particular, this applies to difficult-to-access sites of limited size, such as the offshore installations. Equinor is already making use of digital site visits for offshore sites. In our view, digital site visits could be included as a type of simplified site visit, outlined in Art. 31 and Art. 32 of the Regulation. The verifier has to make a risk assessment, subject to approval of the competent authority. Within the scope of these provisions, the competent authority should be allowed to approve a digital site visit should the conditions and the alternative risks favour it. In sites where digital visits can be a valid replacement, physical site visits should only be mandatory during the first verification visit and after longer intervals without visiting the site (e.g. 5 year-periods). In case of modifications to the monitoring plan or monitoring methodology plan (Art. 32(3(b)) which only affect the data handling in onshore offices, there should be no need for physical site visit offshore. Conditions to fulfil for digital site visits First, a definition of digital site visits should be provided in Art. 3 of the Regulation. Digital site visits should be conditioned by live-stream video access to the site. The verifier should be granted access to the site plans ahead of the digital site visit, with the site equipment including meters marked. Furthermore, the verifier should be allowed to guide the digital site visit and conduct real-time interviews with the participants. Fulfilling these conditions will allow the verifier to carry out reliable digital site visits.
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Response to Strategy for smart sector integration

8 Jun 2020

Equinor herewith submits its consultation response in relation to the Energy System Integration Strategy. Enclosed you will find our detailed contribution in which we concentrate on 4 of the proposed questions and contains the following key messages: • Reaching Europe’s 2050 climate neutrality ambition necessitates a massive deployment of clean molecules on top of further electrification. To incentivise the necessary investments in GHG abatement technologies investors need to see a conducive policy framework and strengthened market signals. • A European standard classifying renewable and decarbonised gases based on a lifecycle GHG emissions assessment is essential. • Including GHG content as a mandatory field on guarantees/certificates of origin enables consumer choice and serves as a passport to support the interchangeability of energy vectors from clean molecules to clean electrons and back on the basis of transparent GHG accounting. • Sectoral demand-side measures are needed to stimulate the uptake of clean energy vectors. • Industrial clusters are ideal incubators enabling immediate synergies and sizeable CO2 reductions, but industrial-sized demonstration projects require clear support through e.g. the Environmental and Energy State Aid Guidelines and other EU financing mechanisms. It could also be valuable for member states to explore how the IPCEI framework can used to advance such industrial clusters. • The Gas Directive can serve as a template to develop the legislative framework for clean hydrogen. • TEN-E Regulation should have CCS and clean hydrogen as a new thematic area. • The EU ETS & CCS Directives should recognise maritime CO2 transportation solutions. • The development of a European methane regulation is an important component in the development of clean hydrogen value chains. We invite you to read the attached full consultation response.
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Equinor Urges EU to Include Gas-Based Hydrogen in Strategy

8 Jun 2020
Topic — EU consultation on clean hydrogen's role in reaching climate neutrality by 2050.
Message — Equinor argues for a hydrogen definition based on emissions savings rather than origin. They believe funding should include both renewable and carbon-capture enabled hydrogen.12
Why — The company would be able to utilize its existing gas infrastructure for hydrogen.3
Impact — Renewable energy developers face tougher competition for subsidies against cheaper gas-based alternatives.4
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Response to Revision of the guidelines for trans-European Energy infrastructure

8 Jun 2020

Please refer to Equinor’s full Roadmap feedback in the attachment. We appreciate the opportunity to contribute to the revision of the Trans-European Networks for Energy Regulation, our key recommendations are summarised below. 1. PCI selection. The sustainability dimension should be incorporated on the basis of GHG emissions reduction potential applied in a non-discriminate manner to all technologies and network development plans, as is the case for decarbonisation projects under the Innovation Fund. 2. Thematic focus. The new TEN-E rules should facilitate dedicated hydrogen infrastructure workstreams. These cooperative workstreams should cluster hydrogen-ready member states; promote the development of clean hydrogen infrastructure projects; and address standardisation and safety issues in a timely manner. 3. Role of natural gas. The just transition principle implies that member states and regions should be allowed to adjust to the clean energy transition at a just and sustainable pace. In cases where a coal-to-gas shift can significantly contribute to emissions reduction, adequate policy and support measures should be endorsed by the EU. At the same time, it is important to make any new gas infrastructure developments hydrogen-ready. 4. Definition of sustainable gas. The sustainability dimension of gas as defined in the TEN-E Regulation should not be limited to gas produced from renewable sources only. Art 4(b)(iv) of the Regulation states that the sustainability criteria for projects of common interest in gas relates to ‘enhancing deployment of renewable gas’. Non-renewable low-carbon gases should be added to the scope to recognise their potential for the gas sector decarbonisation. 5. CO2 transport network definition. A CO2 transport network should not be limited to pipelines but encompass maritime, road, railway and other transport that can be part of a shared CO2 transport network. It is particularly relevant during the pilot project and scale-up phases of CCS deployment in Europe, where pipeline construction might not be feasible or economic. 6. Role of CCS and clean hydrogen. CCS and clean hydrogen technologies will play a pivotal role in decarbonising the EU’s energy system. The TEN-E Regulation should reinforce the governance system around infrastructure planning for CCS and hydrogen. In line with the TYNDP framework, member states should be asked to list and report planned CCS and hydrogen interconnection projects at the national level in order to facilitate network planning and long-term visibility of low carbon infrastructure development across Europe. 7. Clean hydrogen production in the TEN-E. The TEN-E Regulation should not include hydrogen production facilities in the scope of hydrogen network definition as this could distort the role of TSOs in a liberalised European energy market. However, if used as a last-resort measure for balancing purposes in the event that commercial entities do not take up such activities, regulated investments into clean hydrogen production facilities should respect the following principles: 1) the TEN-E framework should adopt a technology-neutral approach with regard to clean hydrogen production PCIs, encompassing both power-to-gas as well as SMR/ATR technologies; 2) investment costs for system balancing purposes should be shared adequately between the power and gas system users; and 3) the investment framework should not undermine the market liberalisation rules, i.e. hydrogen production and storage services should be carried out in full compliance with unbundling rules. 8. Synergies between the TEN-E and TEN-T. The TEN-T Regulation can help to scale the use of clean hydrogen or ammonia in the transport and in particular, the maritime sector. At the same time, clear boundaries between the TEN-E and TEN-T sections on hydrogen should be established on the basis of hydrogen use.
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Response to Union renewable Financing mechanism

3 Jun 2020

[Please see attachment for full response] Equinor considers that the proposed RES Financing Mechanism (RFM) will be an important tool to ensure that the EU meets its renewable energy target. Equinor has ambitious plans to increase its production capacity from renewable projects by 4 to 6 GW by 2026, mainly based on the current project portfolio. Towards 2035, Equinor expects to increase installed renewables capacity further to 12 to 16 GW, dependent on availability of attractive project opportunities. A large share of our investments will happen in Europe. To be an effective gap-filler, the mechanism should combine and leverage EU and national financing. A key factor of success of the mechanism will be that it delivers renewable investments beyond what national instruments will deliver on their own. Investors should be able to see clearly how the mechanism interacts with other funding sources. To boost development of offshore wind, alongside the massive deployment of onshore renewables needed, the mechanism should follow these principles: • It should encourage and facilitate landlocked countries’ access to offshore wind resources in waters of coastal countries willing to provide for such access. • It should open up for developing both bottom fixed and floating offshore wind through technology specific tenders based on revenue stabilization mechanisms. • On tender design, in case of bids with the same price and for demonstration projects, it should be clarified what assessment criteria should be taken into consideration when selecting the winner. [Please see attachment for full response]
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Response to Climate Law

30 Apr 2020

Please refer to the document attached for a full version of the feedback. Equinor supports the Paris Agreement and a net zero target for society. In February 2020 we presented our new Climate Roadmap, with the ambitions of reducing the net carbon intensity of energy produced by at least 50% by 2050, growing renewable energy capacity tenfold by 2026, strengthening our industry leading position in carbon-efficient production and aiming to reach carbon neutral global operations by 2030. The European Commission’s proposal for a European Climate Law is an important milestone towards a pathway to achieve substantial decarbonisation of the EU’s economy. 1) The 2050 Long-Term Strategy should be updated to reflect any enhanced climate targets with more than two scenarios projecting climate neutrality. A strategy update should encompass a diverse range of technological and natural solutions that can contribute towards achieving climate neutrality, encompassing their associated cost estimates. 2) A review of the EU’s legislative framework for the 2030 GHG emissions reduction target should prioritise the development of enabling conditions for the gas sector decarbonisation, based on cost-competitiveness and availability of energy carriers. It is crucial that a competitive price on carbon as well as streamlined accounting of carbon emissions mitigation and removal are effectively used to support the transition to low carbon energy. 3) To be credible to civil society and investors alike, the target-setting mechanism proposed in the Climate Neutrality Law should fully abide with EU laws and ensure institutions play their full role in accordance with their Treaty obligations. 4) Credible life-cycle emission analysis form a solid basis for decarbonisation policies as it allows to determine optimal use of energy and resources coupled with effective reductions in net GHG emissions. Policies for low carbon technologies should avoid perverse effects of efficiency loss between clean energy vectors and suboptimal outcomes in terms of GHG emissions reduction compared to alternative applications. 5) Once emissions from the easy-to-decarbonize parts of Europe’s economy have been reduced, origin-based sectorial targets (such as for renewable energy) and incentives will likely come to their limits in driving further reductions in GHG emissions. Policies and trajectories will increasingly need to reflect non-renewable decarbonisation solutions. In the decade leading to 2030, large-scale deployment of enabling technologies to demonstrate their viability in the long-term, including CCS and CCS-enabled clean hydrogen solutions, must be a priority for the EU’s decarbonisation policy. 6) All factors listed in Art. 3(3) must be considered in the context of promoting specific low carbon technologies when setting a trajectory for achieving climate neutrality. In particular: 6.1) Focus on cost-effectiveness and economic efficiency serve to guarantee that real GHG emissions savings as well as optimal use of resources are the main driving factors for endorsing specific decarbonisation technologies. 6.2) Maintaining and enhancing Europe’s economic competitiveness implies the EU’s efforts during this decade should focus on scaling up the most promising low carbon technologies to be available to Europe’s industries. 6.3) The investment needs & technology scale-up and cost-reduction opportunities should be taken into account when designing the European Commission’s GHG emissions reduction pathways, policies and support mechanisms as well as the recommendations made to member states on the basis of NECPs. 6.4) The just transition element implies that member states and regions should be allowed to adjust to the clean energy transition at a sustainable pace. A one-size-fits-all approach could come to impact energy system and economic resilience negatively. It will be important to support each region on the basis of its policy planning and investment capacities
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Response to Climate change mitigation and adaptation taxonomy

27 Apr 2020

[Please see attachment for full response] Equinor welcomes the EU’s ambition to develop a taxonomy that will set out a common language to define environmentally sustainable economic activities, helping investors and businesses mobilise and reorient investments towards more sustainable technologies. We support the EU’s ambition to become climate neutral by 2050 and believe that providing clarity to the financial sector is a crucial step towards achieving that goal. We also welcome the final compromise text of the Taxonomy Regulation agreed by the co-legislators and the progress made by the Technical Expert Group and we appreciate this opportunity to provide further input. As a broad European energy company with considerable investments in low carbon solutions, Equinor takes interest in contributing to a sound EU taxonomy. To become an effective and widely applied tool, the taxonomy should follow some key principles: • It should be technology-neutral, which implies that the EU should endorse an approach to sustainable investments that stimulates all activities that have a significant impact in terms of climate change mitigation. • In order to encourage reporting on sustainable activities, the taxonomy should have easy-to-follow rules for reporting. • The taxonomy should aim for international alignment and coordination. As an international energy company, we recommend that the EU works with international institutions and jurisdictions to standardise the application and deployment. • It is important for the functioning of the market to ensure that the taxonomy does not result in unintended marked distortions. [ Please see attachment for full response and references]
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Meeting with Kadri Simson (Commissioner) and

23 Mar 2020 · Security of operations under current circumstances (covid-19), oil market developments, off-shore wind and hydrogen

Response to Climate Law

6 Feb 2020

We welcome the EU’s ambition to realise the long-term carbon neutrality objective through socially-fair and cost-efficient policies. We believe that the Paris Agreement is a necessary global cooperation mechanism for action on climate change and support EU efforts to reinforce international cooperation in a 2030 and 2050 timeframe. A European Climate Law will serve both as basis for a carbon-neutral European economy as well as an inspiration for climate-neutrality ambitions in other countries. It is important that the Climate Law enshrine a clear definition of climate neutrality, including how the EU’s total GHG emissions are measured (i.e. total amount of emissions generated, consumed and offset). A 2050 climate neutrality objective will require the EU to work on realistic and cost-efficient policies to transform Europe’s energy system. In this regard, the European Commission should update its Long-Term Strategy, in which only two scenarios out of eight are 1.5°C-aligned. In the new Strategy, 1.5°C-compatible decarbonisation pathways should consider all low carbon technologies on an equal basis, considering their life-cycle emissions performance and therefore, the real climate change mitigation potential. As outlined in the roadmap, every sector has a role to play in achieving the climate-neutrality objective. However, for all sectors to play their role policies should give economic actors wide access to a wide range of decarbonisation technologies and solutions. To safeguard long term competitiveness each sector should be given enough leeway to choose the most effective and cost-efficient pathways of decarbonisation. Furthermore, a climate-neutrality objective should provide policy and market predictability to enable sizeable decarbonisation investments. This is best done in basing policies on life-cycle emissions analysis that accounts for resource and cost-efficiencies. This includes the use or repurposing of existing energy infrastructure. The European Climate Law should serve as basis for harmonised decarbonisation policies across different sectors. In this respect, the European Commission should work on clear and consistent rules to integrate and mainstream innovative low-carbon solutions, such as CCS or hydrogen, which have cross-sectorial applicability. Finally, the EU needs to further foster carbon pricing to encourage investments in the clean energy transition. In complement to current mechanisms, the European Commission should consider a system to account for negative carbon emissions so as to encourage investments and development of natural or technological carbon removal projects. Such a system would have to include a clear and comprehensive definition of negative emission solutions. Achieving climate-neutrality will necessitate collective action and bold ambitions from the private sector. As a broad European energy company, Equinor is committed to act and have recently announced plans for GHG emission reductions in Norway and internationally. We fully support the EU’s climate ambition and strongly believe that it is crucial that the EU encourages climate action through comprehensive, inclusive and cost-efficient policies.
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Meeting with Ann Mettler (Director-General Inspire, Debate, Engage and Accelerate Action)

10 Oct 2019 · Energy Transition

Response to Evaluation of the effectiveness and policy coherence of the guidelines for trans-European Energy infrastructure

10 Jul 2019

We have outlined two issues that should be considered in the future review of the TEN-E Regulation that pertain to CO2 shipping infrastructure as well as hydrogen and low carbon gases. 1. Infrastructure funding for CO2 shipping is currently excluded from the TEN-E Regulation and the scope of CEF funding The TEN-E Regulation defines the scope of the Connecting Europe Facility (CEF) funding for cross-border energy projects. Annex II (4) sets out the parts of cross-border CCS projects that could be funded under the CEF Regulation, concerning specifically cross-border pipelines for transport of carbon dioxide, liquefaction and buffer storage facilities as well as adjacent equipment for safe operation. However, the defined scope does not include ship infrastructure, which implies that shipping costs cannot be funded through the CEF. The current legislative setup risks creating unfair treatment of ship-based CO2 transport projects vis-à-vis pipeline projects. Several new cross-border CO2 projects in Europe that are currently applying to receive a PCI status rely on the shipping solution for CO2 transport to permanent storage. The fact that these projects could not receive funding for ship infrastructure under the CEF could impede the development of a cross-border CO2 transport network for several reasons. Investing in ship infrastructure could make CO2 transport network expansion more feasible for emitters from various coastal parts of Europe to start with smaller CO2 volumes, allowing for a gradual maturation of demand for CO2 transport and storage. This would in turn contribute to reducing the overall CO2 transport costs, thereby making CCS more viable for emitters across Europe. Therefore, a shipping solution can support the industrial start-up of CO2 capture, transport and storage and it will be essential for scaling up and achieving cost-reductions across the full CCS value chain. In our understanding, the CEF rules should not differentiate between the two CO2 transport methods and allow them compete / complement one another on an equal basis. CO2 -transport by ship should be made fully eligible for CEF funding for works the same way that CO2 pipeline transport solutions are. Ships and pipelines together provide the robustness, flexibility and cost-effectiveness to the CO2 transport system. Equal treatment of ships and pipelines is necessary to avoid distortion of competition for development of a European CO2 network. 2. Hydrogen and low carbon gases should be included in the scope of the TEN-E Regulation Neither hydrogen nor low-carbon gases in general are covered by the TEN-E Regulation as a result of which, they cannot qualify as Projects of Common Interest. We believe that low-carbon gas infrastructure should be included in the scope of the TEN-E rules alongside power, gas, oil and CCS networks as means to reflect the relevant market developments and most importantly support the EU’s decarbonisation efforts. This inclusion should be mirrored in the CEF Regulation as well as the other relevant EU legislation such as the Environmental and Energy State Aid Guidelines. The TEN-E rules should encourage member states to prioritise low-carbon energy infrastructure and generation adequacy projects, where GHG emission abatement potential is the major criteria for granting state aid. At the same time, prioritising low carbon gas infrastructure investment projects would help to retrofit the conventional gas infrastructure into a future proof hydrogen-ready network. The definition of hydrogen / low-carbon gases should be based on life-cycle emissions criteria to enable the scale-up of the most promising technologies to foster energy system decarbonisation in the EU. We are strongly in favour of a technology-neutral approach that would create a level-playing field for low-carbon technologies. Please see the attached document for a full feedback.
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Meeting with Jolana Mungengova (Cabinet of Vice-President Cecilia Malmström)

7 May 2019 · Conference on TRUST AND SECURITY IN THE DIGITAL ERA

Response to Commission Delegated Regulation establishing the Innovation Fund

11 Jan 2019

Please find Equinor´s feedback in the enclosed document.
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27 Jun 2018 · Carbon Capture and Storage (CCS) and Long-Term Strategy (LTS)

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12 Apr 2018 · Renewable Policy

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4 Apr 2018 · Neighbourhood and Enlargement negotiations

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7 Mar 2018 · FP9

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

25 Jan 2018 · Gas markets

Meeting with Miguel Arias Cañete (Commissioner)

9 Nov 2017 · Energy Union, decarbonisation challenges, the role of CCS

Meeting with Bernd Biervert (Cabinet of Vice-President Maroš Šefčovič)

18 Sept 2017 · EU-Norway energy relations

Meeting with Dominique Ristori (Director-General Energy)

1 Sept 2017 · energy policy development

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30 Aug 2017 · Follow-up on Energy Research issues

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16 Jun 2017 · Developing energy sector in Algeria

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23 Mar 2017 · North Sea

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4 Jan 2017 · Energy policy

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24 May 2016 · Business Forum EU-ALGERIA

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12 Apr 2016 · UK referendum

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

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16 Feb 2016 · Package supply security and in particular the LNG strategy, EU-Norway relations in the field of energy

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2 Feb 2016 · Energy Union

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3 Dec 2015 · Business Europe CEO day

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3 Dec 2015 · Business Europe CEO day

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3 Dec 2015 · Business Europe CEO day

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3 Dec 2015 · Business Europe CEO day

Meeting with Dominique Ristori (Director-General Energy)

19 Oct 2015 · European energy policy

Meeting with Miguel Arias Cañete (Commissioner) and

17 Sept 2015 · Investment in Algeria

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

17 Sept 2015 · European energy policies

Meeting with Pierre Schellekens (Cabinet of Vice-President Miguel Arias Cañete)

11 Sept 2015 · Energy Union

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4 Sept 2015 · gas and oil

Meeting with Miguel Arias Cañete (Commissioner) and

4 Sept 2015 · Security of supply and Energy diversification

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

2 Sept 2015 · Energy Union

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9 Jun 2015 · Cybersecurity

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28 Apr 2015 · Energy Union

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28 Apr 2015 · Energy Union

Meeting with Maroš Šefčovič (Vice-President) and

20 Apr 2015 · Gas storage

Meeting with Peter Van Kemseke (Cabinet of Vice-President Maroš Šefčovič)

12 Mar 2015 · Energy Union follow-up

Meeting with Robert Madelin (Director-General Communications Networks, Content and Technology) and BASF SE and

12 Feb 2015 · Digital Single Market, Innovation

Meeting with Dominique Ristori (Director-General Energy)

27 Jan 2015 · European Energy Policy priorities

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