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Eurelectric

Eurelectric represents the European electricity industry, promoting electricity's role in advancing society and competitiveness.

Lobbying Activity

Meeting with Ana Vasconcelos (Member of the European Parliament, Shadow rapporteur for opinion) and Transport and Environment (European Federation for Transport and Environment) and

26 Jan 2026 · Performance Regulation

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

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

Eurelectric Demands Technology Neutrality and Streamlined Rules for SMRs

4 Dec 2025
Topic — A consultation regarding the future deployment of small modular nuclear reactors across Europe.
Message — They demand technology-neutral treatment and reduced lead-times for regulatory and state aid reviews. They also advocate for harmonized licensing and a standardized fleet approach across Europe.12
Why — Faster permitting and standardized designs would significantly lower investment risks and project costs.34
Impact — Fossil fuel heating providers face competition as SMRs replace carbon-intensive district heating.5
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Meeting with Kurt Vandenberghe (Director-General Climate Action)

26 Nov 2025 · European post-2030 framework

Meeting with Anne-Maud Orlinski (Cabinet of Commissioner Dan Jørgensen)

25 Nov 2025 · Electrification Action Plan

Eurelectric calls for electrification targets in EU budget framework

12 Nov 2025
Topic — New EU regulation on tracking budget expenditure and performance across funding programmes.
Message — The organization requests more granular spending targets specifically on electrification and improved technology neutrality. They want simplified Do-No-Significant-Harm rules and leaner amendment pathways for National Regional Partnership Plans.1234
Why — This would ensure equal treatment for nuclear power and reduce regulatory barriers for electricity infrastructure investments.567
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Response to EU’s next long-term budget (MFF) – EU funding for competitiveness

12 Nov 2025

We welcome the proposal of the new European Competitiveness fund (ECF), and most remarkably the Clean Transition and Industrial Decarbonisation policy window. Particularly important for competitiveness are (Art. 33): electrification of industries, transport and buildings; innovation, digitalization and reinforcement of distribution grids; energy storage, demand-response; LIFE activities. We also appreciate a technology-neutral approach to financial support. In what follows, we suggest further improvements to effectively enable the power sector to support the strategic goal of decarbonisation. The proposed spending target of 43% of the overall ECF on climate-and-environment objectives should be made more precise by setting out a spending target on electrification. The ECF should support electrification in a balanced way, avoiding any discrimination of regions or sectors, inequities in distribution and competition distortion within the EU, ensuring instead a fair and level playing field for all participants. On one hand, the Industrial Decarbonisation Bank (IDB) should also boost proven technologies, ensuring commercialisation and cost drive-down. To this end, we recommend the IDB follow three key principles: an electrification-first mitigation hierarchy based on cost efficiency to decarbonise industrial processes; simple, transparent and efficient competitive-bidding calls for funding; long-term certainty for businesses through sufficient budgets and clear investment signals (we also attach our position paper on the IDB). On the other hand, the Innovation Fund (IF) should ensure higher levels of support for the development and upscaling of decarbonised solutions while ensuring efficient allocation as well as geographical and sectoral distribution. We support the Commissions emphasis on the coherence between ECF and IF while keeping them as stand-alone funds. Diluting EU Emissions Trading System revenues in the EU budget might indeed divert resources from decarbonisation. We also encourage the Commission to work with Member States to find ways to increase participation and success in areas that have not thus far had successful projects, also leveraging synergies with the Modernisation Fund. Moreover, the ECF should aim to mobilise private capital towards such EU strategic priorities as decarbonisation. Hence, the ECF should live up to its goal of addressing situations of suboptimal investments by contributing effective derisking mechanisms. For instance, the European Investment Banks counter-guarantee programme for PPAs should be extended beyond its pilot. This programme should also be improved by ensuring technology neutrality, including repowered installations and admitting existing generation in highly decarbonised areas. In keeping with recent Draghi recommendations, the Commission should signal a more risk-taking attitude, for instance through a less conservative provision for guarantees than 50%. In the same vein, an ambitious design of Tripartite Agreements for electrification should create an investment-positive environment by simultaneously encouraging a more risk-taking attitude by the Commission and a more optimistic business outlook by companies (we also attach our position paper on Tripartite Agreements). It is important to specify that financial instruments to unlock private investments should integrate, not replace, the current levels of non-repayable support. Also, we call for a coordinated policy framework to enable the EU preference without creating bottlenecks and, hence, cost overruns and project delays. Furthermore, as also the Commission indicates electrification as a priority for security, electrification-related projects bolstering resilience should be supported also under the Resilience and Security, Defence Industry, and Space policy window. Finally, we recommend early-stage transparency on the composition of the Strategic Stakeholders Board, the Investment Committee and the Advisory Board.
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Meeting with Christof Lessenich (Head of Unit Energy)

12 Nov 2025 · Eurelectric views on the upcoming White Paper on deeper electricity market integration

Eurelectric urges earmarked electrification funding in EU budget

31 Oct 2025
Topic — EU's post-2027 budget for cohesion, agriculture, and regional development.
Message — The organization requests a specific spending target on electrification and minimum earmarked funding similar to agriculture's 300 billion euros. They want business involvement in planning and simpler amendment processes to adapt to market changes.123
Why — This would secure dedicated resources for power sector investments and grid infrastructure.45
Impact — Other sectors lose funding flexibility as electrification receives protected budget allocation.6
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Response to EU’s next long-term budget (MFF) – implementing EU funding with Member States and regions

29 Oct 2025

We warmly welcome the proposed 5-fold increase of Connect Europe Facility (CEF) Energy with respect to the previous cycle. This notwithstanding, we call for a strengthened recognition of distribution grids beyond a single explicit mention in the explanatory memorandum. Until today, financial backing of distribution projects has remained limited as Smart Electricity Grid initiatives have struggled to gain visibility and traction within the Projects of Common Interest (PCI) and CEF frameworks. Historically, only 5% of CEF Energy has been a source of funding for distribution grids. We recommend inverting this trend in the new CEF phases. Distribution grids are indeed strategic for at least two pillars of the Commissions competitiveness agenda. They are strategic for the clean transition, as they deliver decarbonised electricity to end consumers. They are strategic for security of supply, as their reinforcement (e.g., stockpiling of spare parts, investments in grid security) would reduce exposure to natural and adversarial threats. The Draghi report also highlighted that every euro invested in clean power requires 90 eurocents in grid infrastructure. To recognise this strategic importance, CEF Energy should provide dedicated support to investments in distribution grids. Such support should also include grants and financing to energy-infrastructure projects in one Member State with cross-border effects. From this standpoint, investments into flexible energy storage such as pumped hydro should receive stronger support as they are strategic for ensuring a well-functioning energy market, security of supply and grid stability. Investment needs in distribution grids amount to 67 bEUR per year until 2030, namely, twice the current level (from our Grids for Speed study). Failing to meet these needs would come with the cost of missing 190 million heat pumps, 120 million EVs and 1,220 GW solar PV with missing 1,8002,060 Mton CO2eq of additional emission reduction (meaning missing decarbonisation targets by 32%37%). In addition to network tariffs, which typically finance distribution-grid investments and are paid by end-users, such investment gap should also be filled by facilitating the access of Distribution System Operators (DSOs) to capital at favourable conditions (the EU tariff framework should facilitate the integration of subsidised projects into Regulated Asset Bases in a fair way to enable the involvement of CEF funding for most EU DSOs, while considering conditions in each Member State for setting tariffs and for carrying out investments). In this regard, we stress the importance of maintaining grant funding at least to the current levels. On top of these grants, we also appreciate the Commissions proposal that CEF Energy should use the InvestEU instruments to provide competitive financing and guarantees. In keeping with Recital (25) of the Commissions proposal, we recommend that these instruments be easily accessible and affordable to DSOs to ensure distribution businesses remain attractive on capital markets. Since network investments are not only physical, but also digital, contributing systemically to an integrated EU single energy market, we recommend that CEF explicitly recognise and therefore incentivise also the uptake of optimizing digital technologies, increasing the efficiency of the existing network, as well as cybersecurity and other IT solutions. Finally, in addition to improving amounts and instruments, we also recommend streamlining the currently lengthy procedure that implies excessive duration from approval as PCI and/or Projects of Mutual Interest to participation in CEF calls and to final disbursement to DSOs. We also attach Eurelectrics position paper Electricity grids: the backbone of the EU energy system. Priorities for the grid INI of the European Parliament driving the expansion and digitalisation of electricity grids.
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Meeting with Stéphane Séjourné (Executive Vice-President) and

28 Oct 2025 · High Level Dialogue with Industry executives on the implementation of CBAM.

Meeting with Wopke Hoekstra (Commissioner) and

28 Oct 2025 · High Level Dialogue with Industry executives on the implementation of CBAM

Electricity industry urges regulation of online energy comparison platforms

24 Oct 2025
Topic — EU proposal to strengthen consumer protection against unfair digital practices.
Message — Eurelectric requests clear definitions distinguishing comparison tools from switching platforms, mandatory disclosure of commercial partnerships and sponsored content, and consistent consumer protection requirements across all comparison websites. They argue current rules create regulatory grey zones where platforms can manipulate product displays without transparency.1234
Why — This would create a level playing field preventing commission-based platforms from favoring certain electricity suppliers over members.56
Impact — Comparison platforms lose flexibility to promote sponsored offers without explicit labeling requirements.78
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Meeting with Wopke Hoekstra (Commissioner) and

16 Oct 2025 · The role of electrification in decarbonising the economy.

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

15 Oct 2025 · Electricity market design, supply chains, electrification

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

15 Oct 2025 · attached

Meeting with Mechthild Woersdoerfer (Deputy Director-General Energy)

15 Oct 2025 · Meeting with the new Presidency team

Eurelectric urges comprehensive approach to EU electricity security beyond fuel supply

13 Oct 2025
Topic — Revision of EU energy security framework for decarbonised, electrified energy system.
Message — The organization requests coordinated system planning that integrates electricity, gas and digital infrastructure with flexibility assessments. They seek market-based investment mechanisms including capacity and flexibility remuneration schemes, and efficient forward markets with stronger demand-side participation.123
Why — This would ensure adequate remuneration for flexibility services and system stability capabilities.45
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Meeting with Edoardo Turano (Head of Unit Climate Action)

9 Oct 2025 · CO2 standards for cars, vans and heavy-duty vehicles

Meeting with Bjoern Juretzki (Head of Unit Communications Networks, Content and Technology)

3 Oct 2025 · Discussion about the Data Act and its application in the electricity generation industry

Meeting with Vicente Hurtado Roa (Head of Unit Taxation and Customs Union)

2 Oct 2025 · Carbon Border Adjustment Mechanism

Eurelectric Urges National Solutions for Energy Poverty Crisis

27 Sept 2025
Topic — EU strategy to reduce poverty and implement European Pillar of Social Rights.
Message — The organization requests energy poverty be addressed through national and local frameworks rather than EU-wide rules. They argue governments should use existing tools like energy vouchers, bill discounts, and social tariffs while the EU focuses on monitoring and sharing best practices.12
Why — This would avoid new EU regulatory requirements for electricity suppliers and preserve national flexibility.34
Impact — Vulnerable consumers lose consistent EU-wide protections against energy poverty and disconnection.5
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Meeting with Jutta Paulus (Member of the European Parliament)

22 Sept 2025 · Energy Politics - Power Barometer exclusive dinner

Meeting with Paula Rey Garcia (Head of Unit Energy)

11 Sept 2025 · Pumped storage hydropower

Meeting with Giorgio Gori (Member of the European Parliament)

10 Sept 2025 · 2040 targets, electrification, infrastructure and security of supply

Meeting with Seán Kelly (Member of the European Parliament)

9 Sept 2025 · Issues faced by electricity grid companies and industry

Meeting with Radan Kanev (Member of the European Parliament) and ENGIE

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

Eurelectric urges EU to incentivise electricity grid climate resilience

4 Sept 2025
Topic — The initiative aims to set an integrated framework for managing climate risks.
Message — Eurelectric recommends amending national energy plans to explicitly include physical infrastructure resilience. They ask regulators to incentivise climate adaptation and improve crisis management for operators. They also seek targeted funding for climate modelling and emergency response technologies.123
Why — The sector would gain regulatory certainty and funding to support long-term infrastructure investments.45
Impact — Society and businesses face massive costs and reduced competitiveness due to grid vulnerabilities.6
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Meeting with Peter Liese (Member of the European Parliament)

4 Sept 2025 · Austausch

Response to European Climate Law amendment

3 Sept 2025

Eurelectric, the association representing the European electricity industry, welcomes the opportunity to provide feedback on the amendment to the European Climate Law. Please find our detailed views in the attached document.
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Meeting with Tatyana Panova (Head of Unit Financial Stability, Financial Services and Capital Markets Union) and BDEW Bundesverband der Energie- und Wasserwirtschaft e. V. and

1 Sept 2025 · JEAG position on commodity derivatives consultation

Eurelectric Urges Local Flexibility in EU Grid Modernisation Rules

30 Jul 2025
Topic — The EU consultation seeks measures to accelerate and digitalise European grid infrastructure.
Message — Eurelectric requests regulatory frameworks that respect local distribution realities instead of one-size-fits-all rules. They argue grid expansion remains essential alongside flexibility services. Operators need clear mandates before the EU imposes new performance metrics.123
Why — This approach prevents unnecessary costs and allows operators to tailor solutions to local environments.4
Impact — Consumers may face higher bills if rigid EU standards ignore local network realities.5
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Meeting with Rosalinde Van Der Vlies (Director Energy)

9 Jul 2025 · Exchange of views on Eurelectric‘s flagship project ‘Power2People 2.0’ and retail policy issues.

Meeting with Bruno Tobback (Member of the European Parliament)

24 Jun 2025 · the recent developments in the electricity markets — in particular the occurrence of negative prices in Belgium

Meeting with Beatriz Yordi (Director Climate Action)

23 Jun 2025 · EU’s climate agenda

Eurelectric urges targeted adjustments to simplify EU cybersecurity rules

20 Jun 2025
Topic — Revision of the Cybersecurity Act to enhance digital resilience and streamline legislation.
Message — They support limited fact-based changes while giving more resources to the cybersecurity agency. The industry needs time to implement existing rules before new ones are added. Aligning various laws is necessary to reduce the heavy administrative burden.123
Why — Streamlined rules and clearer procedures would reduce their compliance costs and complexity.45
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Meeting with Bruno Tobback (Member of the European Parliament) and E.ON SE

10 Jun 2025 · European Energy Policy Priorities

Eurelectric calls for simplified sustainable finance rules and data alignment

21 May 2025
Topic — This consultation reviews EU sustainable finance rules to simplify frameworks and prevent greenwashing.
Message — The association requests streamlining fund categories with clear definitions and market-linked products. They advocate for alignment with international reporting standards and corporate ESG performance metrics.12
Why — Standardized reporting would reduce the heavy administrative burden of data collection and processing.3
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Meeting with Jutta Paulus (Member of the European Parliament, Shadow rapporteur)

15 May 2025 · Speaker: Brussels Electricity Club: Energy Security

Eurelectric urges extension and simplification of EU Modernisation Fund

13 May 2025
Topic — An evaluation of the operating rules for the climate fund supporting lower-income countries.
Message — The organization calls for the fund to continue beyond 2030 and for an increase in the volume of carbon allowances. They also advocate for simplified state aid procedures and maintaining the current sectoral scope.123
Why — The electricity industry would secure long-term investment predictability and avoid losing funding for massive infrastructure projects.45
Impact — Other industrial sectors lose because the industry opposes expanding the fund's scope to include them.6
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Eurelectric Urges EU To Include Nuclear In Green Funding

12 May 2025
Topic — This consultation identifies investment needs for nuclear power across the European Union energy system.
Message — Eurelectric requests that nuclear power be recognized as a neutral net-zero energy source. They advocate for removing the exclusion of nuclear projects from EU funds.12
Why — Shifting financial risks to the public sector would lower costs for private energy investors.34
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Meeting with Dan Nica (Member of the European Parliament) and E.ON SE

11 May 2025 · Conference "Grids of the Future - Romani's role in Europe Energy Security and Competitiveness"

Meeting with Nicola Pesaresi (Head of Unit Competition)

29 Apr 2025 · Exchange of views on the new State aid rules being developed to accompany the Clean Industrial Deal.

Meeting with Joan Canton (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

9 Apr 2025 · Exchange of views on competitiveness

Meeting with Aleksandra Kordecka (Cabinet of Executive Vice-President Stéphane Séjourné), Laia Pinos Mataro (Cabinet of Executive Vice-President Stéphane Séjourné) and

7 Apr 2025 · Clean Industrial Deal, Electrification Action Plan, Affordable Energy Plan, CISAF

Meeting with Jessika Roswall (Commissioner) and

27 Mar 2025 · Roundtable “Water, Agriculture, and the Food Supply Chain”

Eurelectric seeks more flexible EU Taxonomy reporting rules

26 Mar 2025
Topic — The consultation covers amendments to simplify EU Taxonomy disclosure and environmental requirements.
Message — Eurelectric recommends making reporting templates flexible and removing burdensome operational expense disclosures. They also urge aligning capital expenditure definitions with international financial standards.123
Why — Streamlined rules would reduce administrative burdens and the cost of gathering data.45
Impact — Investors may suffer from reduced data availability and a weakened level playing field.6
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Meeting with Dan Nica (Member of the European Parliament) and BUSINESSEUROPE and

25 Mar 2025 · Debate on The role of CEE countries and Romania in strengthening the competitiveness of the European Union

Meeting with Peter Liese (Member of the European Parliament)

21 Mar 2025 · Austausch

Meeting with Peter Liese (Member of the European Parliament) and Bundesverband der Deutschen Industrie e.V. and

19 Mar 2025 · Austausch

Meeting with András Gyürk (Member of the European Parliament, Shadow rapporteur)

18 Mar 2025 · Electricity grids

Meeting with Dan Jørgensen (Commissioner) and

14 Mar 2025 · Clean Industrial Deal, Affordable Energy Action Plan and new State aid Framework (CISAF), Electrification Action Plan

Meeting with Jutta Paulus (Member of the European Parliament, Shadow rapporteur) and Climate Action Network Europe and

14 Mar 2025 · Security of Energy Supply

Meeting with András Gyürk (Member of the European Parliament, Shadow rapporteur) and Open Fiber

12 Mar 2025 · Electricity grids

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

12 Mar 2025 · EU Energy and industry policy

Meeting with Yannis Maniatis (Member of the European Parliament)

12 Mar 2025 · Introductory Meeting

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

11 Mar 2025 · Reti elettriche

Eurelectric Urges Simplified EU Procurement to Accelerate Energy Transition

7 Mar 2025
Topic — This evaluation reviews EU rules governing public contracts and sector-specific procurement processes.
Message — Eurelectric requests exempting power generation from procurement rules and raising financial thresholds to reduce bureaucracy. They also advocate for European preference criteria and simplified procedures to meet climate targets.123
Why — These changes would lower administrative costs and accelerate the deployment of low-carbon energy infrastructure.45
Impact — Non-European suppliers may face exclusion or disadvantages due to proposed local preference and data requirements.67
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Meeting with Eszter Lakos (Member of the European Parliament)

6 Mar 2025 · Energy policy

Meeting with Wopke Hoekstra (Commissioner) and

4 Mar 2025 · Discussion on the Clean Industrial Deal and the Affordable Energy Action Plan. The importance of electrification

Response to European Water Resilience Strategy

28 Feb 2025

Hydropower plays a crucial role in enhancing water resilience by mitigating the impacts of water stress and floods. Beyond its primary function of generating renewable electricity at competitive cost levels, hydropower infrastructure contributes significantly to climate mitigation and adaptation. Hydropowers Role in Water Resilience 1. Drought Mitigation Hydropower reservoirs store water that can be strategically released during droughts to maintain flow levels, sustain drinking water supplies, support industry and agriculture, and preserve ecosystem health. This storage function significantly reduces the economic losses associated with water shortages and enhances overall resilience against prolonged dry periods. 2. Flood Management Hydropower infrastructure may also contribute to mitigating flood risks by regulating river flows and reducing peak discharge during extreme rainfall events. By acting as buffers, reservoirs may help to protect downstream communities, infrastructure, and ecosystems, mitigating or minimizing damage and safeguarding lives and property from flooding. 3. Integrated Water Management Hydropower contributes to efficient and sustainable water use within an integrated system. It facilitates multi-purpose water usage, including irrigation, drinking water supply, tourism & leisure, aquaculture and navigation, without depleting the resource. This holistic approach supports water conservation and efficient reservoirs use while ensuring diverse societal needs are met. 4. Building Climate Resilience By combining renewable and flexible electricity generation with essential water management functions, hydropower infrastructure strengthens climate resilience. Its ability to eliminate or mitigate water stress while preserving ecosystems makes it an indispensable part of sustainable development and adaptation strategies in the face of climate change. Effective hydropower systems can help maintain stable aquatic environments by regulating river flow and water levels. In addition, environmental flow regulations can ensure that downstream ecosystems continue to thrive, providing critical habitats for fish and other wildlife, which are essential for ecosystem resilience. 5. Enabling More Wind and Solar Power on the Grid Hydropower provides critical flexibility to the energy mix, allowing greater integration of wind and solar power while ensuring grid stability. By optimizing the energy mix, hydropower contributes to the effective management of water resources, ensuring a balance between energy security and environmental sustainability. Key Messages from the Hydropower Sector for the EU Water Resilience Strategy i. Apply Scientific and Data-Based Methodologies to Assess Hydropowers Impact and Benefits o Policies for hydropower should be driven by empirical data and robust methodologies to assess its role in water resilience. ii. Recognise Hydropowers Role in Climate Adaptation and River Basin Management o Hydropowers contribution to renewable electricity generation and water management must be acknowledged under various regulatory frameworks, including River Basin Management Plans, National Energy and Climate Plans (NECPs), and the EU Floods Directive. iii. Unlock Investment Potential in the Hydropower Sector with a Supportive Framework o Hydropower plants should receive fair remuneration for the full range of services and benefits they provide, beyond power generation, to ensure their long-term viability and continued contribution to water resilience.
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Meeting with Pilar Del Castillo Vera (Member of the European Parliament, Shadow rapporteur for opinion) and STEAG GmbH

25 Feb 2025 · Energy Policy

Response to List of net-zero technology final products and their main specific components

20 Feb 2025

A summary can be found below, and a more comprehensive explanation and list amendments in the attached pdf. . Summary: As the EU-level industry association for the electricity sector, we appreciate the opportunity to contribute to the consultation on the implementing act of the NZIA defining the main specific components (Art. 29(2)). This list lays the foundation of the resilience criterion in public procurement procedures (Art 25(7)) and RES Auctions (Art 26(2)). In the context of this consultation, Eurelectric members can be both the contracting entities procuring net zero technologies, and/or bidders in public procurement tenders or RES Auctions. Eurelectric welcomes the efforts of the European Commission with the long-term aim of increasing manufacturing capacity in Europe. This necessary end-goal is a means of reaching 2030, 2040 and 2050 decarbonisation targets, while fostering sovereignty and technological development in the Union. Nevertheless, it remains key that the measures are balanced and align with the two leading principles of the EU to strive for simplification and affordable energy. While the resilience criteria could support the contracting entities choosing local products in a long-term perspective, it risks being counter-productive in the short term. The industrys opportunity for efficient procurements and auctions has consequences for the pace at which the sector can enable the energy transition. We see a risk that applying the resilience criterion overly stringent could risk further straining supply chain issues in the coming years, potentially increasing the price and delivery times, in a time where a nearly doubling of grid investments is needed and customer affordability is key. Our five recommendations for the Implementing act and its application: 1. We recommend the European Commission create an implementing act as per Art 29(2) with a list of Tier 1 level products, rather than the resilience criteria applying to Tier 2-level products. This would alleviate the sector from the highest administrative costs. In Annex 2, suggested amendments to the list can be found. 2. The resilience criterion should be applied after at least 12 months after the EU Commissions trade assessment has been published. As the Implementing Act is currently written, actors on the market will receive a maximum of 5 months from the trade assessment publication to analyse their supply chains and adjust procurement and auction procedures. 3. The trade assessment should be formed transparently and evidence-based, providing opportunities for stakeholders to contribute. 4. Where possible, the provisions in Article 25 should align with the provisions in Article 26 provisions. As many actors are subject to non-price criteria (NPCs) in both RES auctions and public procurement, an alignment will facilitate compliance. 5. The EU Commission should notify the National Regulatory Authority to consider the possible impact of the increased costs of equipment in each country's tariff plans for Distribution System Operators. Any cost increase arising from the resilience criterion should be considered in the Regulatory Asset Base (RAB) of DSOs.
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Meeting with Giorgio Gori (Member of the European Parliament, Rapporteur)

17 Feb 2025 · Exchange on priorities and resolution on energy-intensive industries

Meeting with Wopke Hoekstra (Commissioner) and

12 Feb 2025 · Dialogue on the future of the automotive sector - Thematic Working Group on 'Clean Transition and Decarbonisation'

Meeting with Christophe Grudler (Member of the European Parliament)

5 Feb 2025 · Politique énergétique européenne

Meeting with Dan Jørgensen (Commissioner) and

30 Jan 2025 · Affordable Energy action Plan

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

28 Jan 2025 · INI Report on grids

Meeting with Borys Budka (Member of the European Parliament, Committee chair)

23 Jan 2025 · Electrification, Industrial competitiveness

Meeting with Jutta Paulus (Member of the European Parliament)

22 Jan 2025 · EU energy policy

Meeting with Seán Kelly (Member of the European Parliament)

21 Jan 2025 · European electricity industry

Meeting with Joachim Balke (Head of Unit Energy)

21 Jan 2025 · Exchange on Network Planning with DSO Experts Note: Dr. Franz and his colleague Mr. Ohrem attended via Teams

Meeting with Angelika Winzig (Member of the European Parliament)

21 Jan 2025 · Meeting with representatives of Eurelectric

Meeting with Jutta Paulus (Member of the European Parliament) and EU DSO Entity and

15 Jan 2025 · Energy Breakfast

Meeting with Bruno Tobback (Member of the European Parliament, Shadow rapporteur) and EU DSO Entity and GEODE - The voice of local energy distributors across Europe

15 Jan 2025 · Event on The role of electricity distribution grids in the green transition

Meeting with Emma Wiesner (Member of the European Parliament) and GEODE - The voice of local energy distributors across Europe

15 Jan 2025 · EUs energipolitik

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament, Shadow rapporteur) and EU DSO Entity and GEODE - The voice of local energy distributors across Europe

15 Jan 2025 · Energy Breakfast

Meeting with András Gyürk (Member of the European Parliament, Shadow rapporteur) and MVM Energetika Ltd.

13 Jan 2025 · Electricity grids

Meeting with Kurt Vandenberghe (Director-General Climate Action)

10 Dec 2024 · industrial competitiveness

Meeting with Radan Kanev (Member of the European Parliament)

10 Dec 2024 · Delivering a successful Clean Industrial Deal

Meeting with Kurt Vandenberghe (Director-General Climate Action) and Transport and Environment (European Federation for Transport and Environment) and

29 Nov 2024 · Recommendations for an Electrification Action plan in Europe

Eurelectric urges new strategy focused on homegrown electrification

26 Nov 2024
Topic — The EU is evaluating its energy security framework following the recent energy crisis.
Message — The association proposes a 'Security of Supply 2.0' strategy centered on home-grown electrification. They want broader system assessments including flexibility, cybersecurity, and resilience to extreme climate events.123
Why — This framework provides industry members with investment certainty for new power infrastructure.4
Impact — Non-EU fossil fuel suppliers lose market power as Europe seeks energy independence.5
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Meeting with Christian Ehler (Member of the European Parliament)

19 Nov 2024 · EU Energiepolitik

Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

5 Nov 2024 · Discussion on industrial competitiveness and electrification.

Meeting with Kurt Vandenberghe (Director-General Climate Action)

5 Nov 2024 · To discuss industrial competitiveness and electrification, as well as energy security

Response to Greenhouse gas emissions savings methodology for low-carbon fuels

25 Oct 2024

Please find response from Eurelectric.
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Meeting with Lena Schilling (Member of the European Parliament)

22 Oct 2024 · Hydro power

Meeting with Radan Kanev (Member of the European Parliament)

30 Sept 2024 · EU Energy Policy

Meeting with Bruno Tobback (Member of the European Parliament)

24 Sept 2024 · Prioriteiten voor het Europees energiebeleid

Meeting with András Gyürk (Member of the European Parliament)

18 Sept 2024 · Discussion on EU electrification policies

Meeting with Jens Geier (Member of the European Parliament)

18 Sept 2024 · Expectations on the Commission and the EP on Future legislation on Energy

Meeting with Sigrid Friis (Member of the European Parliament)

18 Sept 2024 · Upcoming mandate

Meeting with Nicolás González Casares (Member of the European Parliament)

17 Sept 2024 · Electricity market design

Meeting with Barbara Bonte (Member of the European Parliament)

17 Sept 2024 · Energy Union

Meeting with Jana Nagyová (Member of the European Parliament)

17 Sept 2024 · Meeting with Eurelectric

Meeting with Anna Stürgkh (Member of the European Parliament)

12 Sept 2024 · Energy Transition and the Role of Hydropower

Eurelectric urges market-based instruments for battery carbon footprint calculations

28 May 2024
Topic — The consultation sets rules for calculating and verifying electric vehicle battery carbon footprints.
Message — Eurelectric proposes adding market-based instruments like Power Purchasing Agreements to the methodology. They want to avoid relying solely on national average electricity grid calculations.12
Why — This creates new revenue routes for clean energy investments within the electricity sector.3
Impact — Regulatory authorities face higher complexity compared to using simple national grid averages.4
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Meeting with Peter Van Kemseke (Cabinet of President Ursula von der Leyen)

15 May 2024 · on electricity sector

Meeting with Kadri Simson (Commissioner) and

24 Apr 2024 · Expansion and digitalisation of electricity grids in Europe.

Response to Recommendation to promote the development of innovative forms of solar energy deployment

2 Apr 2024

Please find Eurelectric's response in the document attached
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Meeting with Kurt Vandenberghe (Director-General Climate Action)

13 Mar 2024 · To discuss matters related to 2040 and priorities for the next mandate

Meeting with Margrethe Vestager (Executive Vice-President) and

6 Mar 2024 · Challenges and opportunities of the clean transition of the electricity sector

Response to Commission Recommendation and guidance on design elements of renewable energy auctions

1 Mar 2024

Please find Eurelectric response in the document attached. Executive summary: Eurelectric, representing more than 3500 European utilities active in power generation, distribution and supply would like to raise the following key considerations: 1. Careful implementation of non-price criteria (NPCs): (i) A harmonised and predictable application that allows to learn from experience i.e., implementing act and pilot auctions; (ii) Technology specific application - for solar, onshore, offshore wind and even floating offshore wind, hydropower or geothermal. In general, well designed NCPs will provide greater value value in those tenders that allocate a scarce resource, such as seabed leasing, avoiding uncapped negative bidding. (iii) Simple and focused criteria to avoid over-complexity for developers and for national authorities during the assessment process: one auction, one major targeted objective; resilience where there is production capacity and when the bidder has visibility on the suppliers; use internationally agreed methodologies and develop methodologies for those metrics not standardised yet. (iv) Legal certainty- the criteria need to be objective, measurable and non-discriminatory to avoid legal challenges and subsequent delays. It shall be ensured that the bidders hold up against their pledges and commitments as long as these are in their control and do not reduce competition. (v) Harmonisation - a catalogue of measures, methodologies from the Commission with some degree of flexibility to adapt to local markets. On the offshore wind side, seabed lease and auctions should abide by the same rules (art 20) and not be treated differently. 2. Avoiding uncapped negative bidding is good for the transition, the supply chain and the customers. Member States should explore alternatives, such as capping payment concessions and considering non-price factors like track record, deliverability, financial robustness, and other credentials to determine concession winners. 3. Incentivising project completion indexation and penalties. Price indexation at least during construction is crucial, covering risks that would otherwise be factored into bids, leading to cost savings for electricity consumers. Reasonable penalties may also deter non-completion, with exemptions for force majeure and third-party events. But the negative implications should be factored in and alternatives such as a bonus for delivering the project earlier could also be considered. 4. Bid ceilings to be assessed and updated regularly: consulted upfront with market experts, indexed, aligned with the costs of technology and reflecting the sustainability and resilience non-price criteria (if applied) and communicated well in advance to avoid undersubscription.
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Meeting with Maroš Šefčovič (Executive Vice-President) and

26 Feb 2024 · Clean Transition Dialogue on EGD Infrastructures

Meeting with Ditte Juul-Joergensen (Director-General Energy) and EPIA SolarPower Europe and

26 Feb 2024 · Clean Transition Dialogue on EGD Infrastructures

Response to Guidance to facilitate the designation of renewables acceleration areas

23 Feb 2024

Please see response in document attached.
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Meeting with Morten Petersen (Member of the European Parliament)

7 Feb 2024 · NZIA

Meeting with Niels Fuglsang (Member of the European Parliament)

6 Feb 2024 · Klima og grøn omstilling

Eurelectric calls for streamlined EU sustainability reporting rules

1 Dec 2023
Topic — The European Commission is seeking ways to reduce corporate reporting burdens.
Message — The organization urges the Commission to prioritize current rules and provide better guidance before introducing new obligations. They request a one-stop shop for support and want the definition of workforce restricted to direct employees. Furthermore, they ask to limit due diligence requirements to the upstream supply chain.123
Why — Narrowing reporting and due diligence scopes would significantly reduce administrative and monitoring costs.45
Impact — Contractors and downstream communities lose protections if reporting and due diligence scopes are narrowed.67
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Meeting with Maroš Šefčovič (Executive Vice-President) and

30 Nov 2023 · Clean Transition Dialogue on Energy Intensive Industries

Response to Network Code on Cybersecurity

17 Nov 2023

Eurelectric welcomes the ongoing efforts to enhance cybersecurity and appreciates this opportunity to respond to the delegated regulation of the European Commission. Implementation timescales: Overall, we find the implementation horizon too long. In its current version, the NCCS could take between 7 to 10 years until it is fully implemented, leaving the European electricity grid more vulnerable to cyber-attacks in the meantime. For instance, in the scenario where all deadlines are met, a critical-impact entity will only be obliged to demonstrate compliance with the common electricity cybersecurity framework 10 years after the entry into force of the NCCS. We welcome Article 33 creating a mapping matrix to provide the information of which controls in European and international standards would be equivalent to the controls proposed in Article 27. However, It is unnecessary to wait 36 months for the results and it should be changes to 6 months. In addition, we propose in Article 47 to also create a provisional mapping matrix for the provisional cybersecurity controls, instead of only a list of European and international standards to provide guidance. The timeline incoherence between two interdependent requirements should be rectified. The first requirement is for national entities to create a list of national legislation for cybersecurity purposes. The second requirement is for ENTSO-E and EU DSO to develop a provisional list of European and international standards and controls needed for national legislation. The second requirement has a shorter deadline, even though it is secondary to the first requirement. Information sharing: Article 37(3) states that Each critical-impact and high-impact entity shall share relevant information related to a reportable cybersecurity incident with its CSIRT and its competent authority..., which stipulates double reporting. Communication between CSIRTs and national authorities should be coordinated, but the reporting at entity level should be concentrated in one common mechanism or reporting platform. Article 37(8) also stipulates that the notification of a significant incident within the scope of NIS2 Directive shall constitute reporting of information under paragraph 3 of this Article., which contributes to the argument that the existing reporting lines should be considered and avoid duplication in the reporting process. The references to the NIS2 Directive are problematic since the directive has not been implemented yet in the member states which could cause several overlaps. Therefore, NC CS should stress national competent authorities and CSIRTS to streamline the regulatory frameworks. Additionally, To manage control, and comply with new cybersecurity requirements, coordination must take place between both the EU and the national authorities by requirements such as the upcoming NIS-2 and CER Directives, as well as this new regulatory framework. We fear double regulation and more bureaucracy. Cybersecurity risk assessment methodologies: In Article 17(2) there is an obligation to include threat scenarios linked to attacks on the supply chain in the risk methodology at Union level. Perhaps other type of threat, potentially more serious, should also be highlighted. There are no references to international standards in the area of risk management (e.g. ISO 27005, ISO 31000, NIST CSF, ENISA requirements). It would be useful to make it clear which guidelines, in terms of established good practices, you have based your risk management proposals on. Scope: There is an incoherence between the Article 31(2) and 25(3.a) and the referral to other processes is quite generic and should be eliminated. Entities should clearly understand what the minimum scope of their cybersecurity management system shall include and references to other articles should be limited. Moreover, the scope depends on further work determining the thresholds.
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Meeting with Kurt Vandenberghe (Director-General Climate Action)

16 Nov 2023 · Delivering the RePowerEU targets

Meeting with Maroš Šefčovič (Executive Vice-President) and

16 Nov 2023 · Green Deal

Eurelectric warns soil monitoring rules could damage site valuations

3 Nov 2023
Topic — This proposal aims to monitor, protect, and restore healthy soil across the EU.
Message — Eurelectric suggests raising the threshold for identifying sites as potentially contaminated to prevent valuation losses. They also propose limiting investigation requirements to instances where there is clear evidence of pollution.12
Why — This would help energy firms protect asset values and avoid high operational costs.345
Impact — Environmental agencies and local communities would have less information about potential soil risks.6
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Meeting with Kadri Simson (Commissioner) and

23 Oct 2023 · Roundtable meeting with 10 Secretary Generals and CEOs of the Electrification Alliance on the revised Renewable Energy Directive (revised REDII), electricity market design, grids and storage.

Meeting with Kadri Simson (Commissioner)

10 Jul 2023 · Electricity Market Design.

Eurelectric urges global alignment on sustainability reporting standards

7 Jul 2023
Topic — Consultation on the first set of European Sustainability Reporting Standards for companies.
Message — Eurelectric requests clearer definitions and alignment with international standards to ensure comparability. They suggest protecting business secrets and reducing reporting requirements for non-employees.12
Why — Harmonizing standards with international frameworks would significantly lower administrative costs for utility firms.3
Impact — External stakeholders lose transparency when companies withhold data to protect commercial secrets.4
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Meeting with Patrizia Toia (Member of the European Parliament, Shadow rapporteur)

29 Jun 2023 · REMIT

Meeting with Miapetra Kumpula-Natri (Member of the European Parliament)

27 Jun 2023 · Meeting on the electricity market reform

Response to 2040 Climate Target Plan

23 Jun 2023

Eurelectric, the association representing the interests of the European electricity industry, welcomes the stakeholder consultation on an EU 2040 climate target and fully supports the efforts to meet the objectives of the European Climate Law, in line with the 1.5 °C ambition set by the Paris Agreement. Earlier this month, Eurelectric unveiled a landmark study highlighting three scenarios for Europe to achieve net zero. Looking towards 2030, 2040 and 2050, Decarbonisation Speedways confirms the key role of clean electrification in accelerating Europes path to climate neutrality and underlines its potential in lowering households energy bills. Europes success hinges, however, on critical enablers including the electricity market reform, permitting, grids, and industrial competitiveness. Climate action, energy independence and reindustrialisation call for an ambitious, yet realistic well-balanced decarbonisation strategy for Europe. By 2050, 70% of fossil-fuel-based final energy demand in Europes transport, buildings and industry must be decarbonised. The study underlines that clean and renewable power is the cost-efficient solution to curb emissions and reduce energy use thanks to its superior energy efficiency. Transport will score the highest efficiency gains, with at least a 53% reduction in energy use in 2050 compared to 2015. Decarbonisation Speedways shows that electricity capacity will have to triple by 2040, together with a ten-fold expansion in renewables and a stable basis of firm capacity to match around 4,600 TWh of final electricity demand by 2040. Delivering on such daunting numbers calls for enabling policies. The EU has highly ambitious targets for 2030. The step change we achieve already this decade will determine our success in delivering any target we set for 2040. That is why we must get laser-focused on making progress on the ground now. This means ensuring investors confidence, reaching warp speed in permitting for power generation and grid infrastructure, defending competitiveness and modernising our grids to manage a bigger more complex system. Massive investments in power generation and infrastructure are essential to a successful energy transition. With properly designed policies, consumers could save 175 billion per year in avoided fuel imports and enjoy cheaper energy bills. Lowered emissions and energy use, air quality, biodiversity preservation, job creation and competitiveness would also benefit Europe and lower costs for the economy. The incentive to act has never been higher. Eurelectric calls on policymakers to adopt the necessary enablers for the industry to deliver on climate neutrality with ambition and realism. Please find attached the full Decarbonisation Speedways report, which presents granular information on the assessed scenarios towards climate neutrality. In includes data and insights into: - Electrification rates of end-use sectors and the subsequent decarbonisation potential in buildings, transport, light and heavy industries - Energy demand - Energy efficiency gains - Energy production by source and electrification rates in EU countries - Growth factors in clean and renewable sources of generation - The role of decarbonised gases in the power sector - Pillars and enablers to achieve accelerated decarbonisation of the power sector (including on total investment needs CAPEX & OPEX - in generation capacities and distribution networks) - Benefits of electrification and decarbonisation - Abatement - Contribution of CCS - Flexibility needs; challenges & opportunities; Eurelectric remains available to further discuss the details of the study.
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Meeting with Ditte Juul-Joergensen (Director-General Energy)

20 Jun 2023 · Energy market

Meeting with Kadri Simson (Commissioner) and

20 Jun 2023 · Presentation of new report on smart electrification.

Meeting with Emma Wiesner (Member of the European Parliament)

20 Jun 2023 · Talare: Eurelectric Power Summit

Meeting with Niels Fuglsang (Member of the European Parliament)

15 Jun 2023 · Electricity Market Design Reform

Meeting with Martin Hojsík (Member of the European Parliament) and Euroheat and Power and Innargi A/S

3 May 2023 · Geothermal energy, district heating

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

27 Apr 2023 · Electricity market design and REMIT (meeting held by the APA responsible)

Meeting with Christophe Grudler (Member of the European Parliament, Shadow rapporteur)

26 Apr 2023 · EMD, NZIA, CRMA

Meeting with Kadri Simson (Commissioner) and

3 Apr 2023 · Discussion on how to strengthen the EU-US cooperation to increase the deployment of renewables.

Meeting with Morten Petersen (Member of the European Parliament, Shadow rapporteur) and Schneider Electric

29 Mar 2023 · Energy Market Directive

Eurelectric urges higher EU targets for industrial carbon removals

15 Mar 2023
Topic — The European Commission is proposing a new regulatory framework for certifying sustainable carbon removals.
Message — Eurelectric encourages the European Commission to increase the level of ambition of 5 Mt CO2 industrial carbon removals. They recommend clearly defined ownership and certification by independent private entities.123
Why — Clear certification and higher targets would provide essential signals to attract industrial technology investors.45
Impact — Carbon removal developers lose immediate access to the ETS to protect market integrity.67
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Meeting with Seán Kelly (Member of the European Parliament, Shadow rapporteur)

8 Mar 2023 · The Energy Performance of Buildings Directive

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

8 Mar 2023 · Corporate Sustainability Due Diligence

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

8 Mar 2023 · Electricity market design reform

Meeting with Margrethe Vestager (Executive Vice-President) and

1 Mar 2023 · Meeting to discuss the reform of the electricity market design

Meeting with Morten Petersen (Member of the European Parliament)

28 Feb 2023 · Energy Market Directive

Meeting with Alexander Bernhuber (Member of the European Parliament) and Landwirtschaftskammer Österreich and Umweltdachverband

10 Feb 2023 · Nature Restoration Law - Stakeholder Dialog

Meeting with Kadri Simson (Commissioner) and

9 Feb 2023 · Electricity market design.

Meeting with Frans Timmermans (Executive Vice-President)

1 Feb 2023 · Electricity market functioning, long-term decarbonisation goals and electricity market design reform

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

1 Feb 2023 · Market Design

Meeting with Niels Fuglsang (Member of the European Parliament) and Ørsted A/S

24 Jan 2023 · Energy

Meeting with Ditte Juul-Joergensen (Director-General Energy) and Bureau Européen des Unions de Consommateurs and

20 Jan 2023 · U.S.-EU Task Force: Best practices in Energy Savings and Flexibility Other participants: Cleantech-Cluster Energy, ELVIA, EU DSO Entity, California Energy Commission, ASE, AEE, ComEd, Octopus Energy, OPower, Uplight

Meeting with Elena Montani (Cabinet of Commissioner Virginijus Sinkevičius) and EDP SA

19 Jan 2023 · Questions around the co-existence of biodiversity enhancement and renewable energy deployment.

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans), Riccardo Maggi (Cabinet of Executive Vice-President Frans Timmermans) and EDP SA

19 Jan 2023 · Questions around the co-existence of biodiversity enhancement and renewable energy deployment

Meeting with Cristian-Silviu Buşoi (Member of the European Parliament, Committee chair)

18 Jan 2023 · Electricity Market Design, Renewable Energy Directive, Energy Performance of Buildings Directive

Meeting with Ciarán Cuffe (Member of the European Parliament, Rapporteur)

18 Jan 2023 · EPBD; Electricity market reform

Meeting with Morten Petersen (Member of the European Parliament, Shadow rapporteur)

17 Jan 2023 · Energy Performance of Buildings

Meeting with Ville Niinistö (Member of the European Parliament)

17 Jan 2023 · EMD, RED & EPBD

Meeting with Kadri Simson (Commissioner) and

9 Jan 2023 · Introductory meeting - views on electricity market design reform.

Meeting with Peter Liese (Member of the European Parliament, Rapporteur) and BUSINESSEUROPE and

20 Dec 2022 · ETS

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

7 Dec 2022 · Current political challenges

Meeting with Miapetra Kumpula-Natri (Member of the European Parliament)

22 Nov 2022 · Meeting on Energy Matters

Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur) and EUROPEAN TRADE UNION CONFEDERATION and

7 Nov 2022 · Corporate Sustainability Due Diligence

Meeting with Ditte Juul-Joergensen (Director-General Energy) and Bureau Européen des Unions de Consommateurs and

17 Oct 2022 · US-EU Task Force Convening: energy efficiency and energy savings. The California Energy Commission, ACEEE, ASE, Advanced Energy Economy, Arcadia, ComEd, Octopus Energy, OhmConnect, OPower, Uplight and the Covenant of Mayors also participated.

Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans), Helena Braun (Cabinet of Executive Vice-President Frans Timmermans), Riccardo Maggi (Cabinet of Executive Vice-President Frans Timmermans) and EDP - Energias de Portugal, SA

14 Sept 2022 · Energy Crisis response and Repower EU

Response to Requirements for access to electricity metering and consumption data

5 Sept 2022

Dear Ms Filiou, We thank the European Commission for giving Eurelectric the opportunity to provide feedback on the proposed Implementing Regulation regarding metering data access and interoperability. We would like to raise the following high level concerns, in addition to the more detailed 22 line by line comments in the attached Word document. • We are concerned about the mandatory implementation of the proposed reference model, with many aspects as currently drafted coming into force within 20 days. The reference model should be used for mapping of national practices to achieve interoperability and not to harmonise national practices, following the negotiations of the Clean Energy Package. We understand Member States have not seen this model prior to the publication of this draft, and furthermore we propose an implementation period of no less than 24 months to allow all Member States to implement any specific requirements. • The proposed reference model has been based off the retail market for household and small and medium enterprise (SME) customers, but the IR refers to “final customers,” which could be interpreted to include large industrial customers as well. The consumer protection rules in the retail markets for household and SME customers are significantly different from the consumer protection rule for large industrial customers. We would propose that the language scoping the proposed reference model be clarified to include only household and SME customers. The spirit of directive 2019/944, for example recitals 54, 55 and 56, is providing Smart Metering and access to Smart Metering data to consumers. The data exchange between large industrial customers and high voltage network operators is already well established and requiring similar approach to this data exchange as to residential consumers metering data could create unnecessary bureaucracy. • Since metering and consumption data is related specifically to distributed energy and the connection between final customers and the grid, we feel that it is unnecessary to include ENTSO-E in collecting the reports and making the data practices available. We find this is outside of the scope of their responsibilities. • The IR will significantly impact the work of system operators, and they have been well-included in the operation of the IR, but it will also significantly impact the operations of energy suppliers, and we feel that suppliers and service providers should be on equal footing regarding the advice relating to and the implementation of the IR. • The wording consent versus permission should be carefully considered in the context of other horizontal EU Data legislation such as GDPR, the Data Act and the Data Governance Act. More specific line by line suggested amendments to the draft legal text, including reasoning for the proposed changes, are included in the attached Word file. Kind Regards, Caoimhin O Briain Caoimhín Ó BRIAIN — Senior Advisor - Distribution & Market Facilitation M +353 870537207 — cobriain@eurelectric.org Eurelectric aisbl — Boulevard de l’Impératrice, 66, 1000 Brussels, Belgium
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Meeting with Stelios Kympouropoulos (Member of the European Parliament, Shadow rapporteur)

5 Sept 2022 · phase out of f-gases and switchgears

Eurelectric calls for nature restoration to support renewable energy

22 Aug 2022
Topic — Proposed EU regulation setting legally binding targets to restore degraded ecosystems and biodiversity.
Message — Eurelectric requests that National Restoration Plans align with "renewables go-to areas" to ensure energy projects are not blocked. They advocate for using existing water and habitat definitions to maintain regulatory consistency. They also propose focusing river restoration exclusively on obsolete barriers with no economic purpose.123
Why — The proposed alignment would prevent restoration targets from hindering renewable energy investments and existing hydropower operations.45
Impact — Environmental groups may find it harder to restore rivers if more barriers are protected by economic labels.67
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Meeting with Ditte Juul-Joergensen (Director-General Energy)

19 Jul 2022 · Discussion about electricity market design.

Response to EU rules on industrial emissions - revision

23 Jun 2022

Find enclosed the comments from the Union of the Electricity Industry concerning the European Commission's proposal for the revision of the Industrial Emissions Directive.
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Meeting with Kurt Vandenberghe (Cabinet of President Ursula von der Leyen) and ELECTRICITE DE FRANCE

15 Jun 2022 · Energy market design

Meeting with Ciarán Cuffe (Member of the European Parliament, Rapporteur)

14 Jun 2022 · EPBD

Meeting with Seán Kelly (Member of the European Parliament, Shadow rapporteur)

14 Jun 2022 · The Energy Performance of Buildings Directive

Meeting with Jerzy Buzek (Member of the European Parliament, Rapporteur) and EPIA SolarPower Europe and

2 Jun 2022 · Meeting on gas and hydrogen regulation

Response to Sustainable corporate governance

23 May 2022

Support a level playing field and avoid national fragmentation: Overall, Eurelectric welcomes the Commission's initiative and perceives it as a much-needed step towards a sustainable corporate governance framework. It is of particular importance that a coherent EU framework is not further delayed, as divergent national initiatives have already emerged. Fragmentation of the EU internal market must be avoided, as this is a regulatory area that needs a common structure not only in the EU but beyond. Companies that integrate sustainability into their operations should not be exposed to unfair competition from companies (EU or third country) which do not take on this responsibility. Ensure legal certainty and a reasonable administrative burden: Coordination with international standards like OECD guidelines and UNGPs is important. However, the wording of these standards is target-oriented and does not contain explicit provisions that could be directly incorporated into legislation. Therefore, there is a need for clarification that provides a clear indication of the obligations imposed on companies. Install concrete definitions for successful implementation: The proposal in its current version still has several ambiguities regarding the obligations and responsibilities of companies and therefore requires further refinement to achieve greater harmonisation. Consider a two-tier model for direct and indirect suppliers, which also includes SMEs: To ensure feasibility and a realistic possibility of achieving the objectives of the Directive, Eurelectric suggests replacing the “value chain” with “supply chain" and to consider a two-tier model regarding responsibilities, distinguishing between broader and controllable due diligence requirements for direct suppliers and limited requirements for indirect suppliers. Focus on integrity, human rights and environmental due diligence: Although it is of high importance that the EU moves forward ambitiously in climate policy, the focus of the proposal should be on human rights, good business conduct and environmental due diligence. Furthermore, the current proposal lacks concrete information on how companies can secure and prove that the targets etc. in their business model and strategy are in line with the CSDD. Avoid the inclusion of civil liability: The introduction of comprehensive civil liability rules applying to the provisions of the Directive can lead to considerable legal uncertainty and the risk of excessive litigation for companies with complex supply chains. It is therefore important that both liability and sanctions are limited to where the company is directly linked to potentially adverse impacts. The enforcement mechanism should rely only on sanctions and administrative enforcement. Address the unclear functionality regarding directors’ duties: In principle, Eurelectric supports the idea that directors are encouraged to consider the consequences of their decisions regarding human rights, climate and the environment, however, the wording in the Commission's proposal to introduce obligations for directors receives little support from the sector and appears inappropriate. On the one hand, there is no clear delineation between corporate governance and due diligence; on the other hand, the provisions' implementation raises questions, such as its relationship to existing company law and the due diligence included therein. To distinguish between corporate governance and due diligence, it would therefore be appropriate to clarify the content, taking into account previous comments from the sector. Cohere with other legislation: Eurelectric supports efforts to establish coherence with other legislation, such as the currently debated Corporate Sustainability Reporting Directive (CSRD) and the EU Taxonomy, as the due diligence proposal is closely related to them. Eurelectric is ready to contribute knowledge and expertise!
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Meeting with Kurt Vandenberghe (Cabinet of President Ursula von der Leyen)

22 Feb 2022 · Energy communication

Meeting with Barbara Glowacka (Cabinet of Commissioner Kadri Simson)

29 Nov 2021 · The revision of the TEN E Regulation.

Meeting with Caroline Nagtegaal (Member of the European Parliament, Shadow rapporteur) and Transport and Environment (European Federation for Transport and Environment) and

24 Nov 2021 · AFIR

Response to Carbon Border Adjustment Mechanism

18 Nov 2021

Eurelectric, the sector association which represents the common interests of the electricity industry at pan-European level, thanks the European Commission for the possibility to comment on the proposal for a regulation on the Carbon Border Adjustment Mechanism (CBAM). Eurelectric’s reaction to the CBAM proposal is explained in the uploaded reaction paper. In sum, Eurelectric's key messages are: 1. Base default values on 10% worst performers. The Commission’s proposal to use default values based on average CO2 emissions of the price-setting source might not be sufficiently penalising if this source is not a worst performer. Instead, specific default values should be based on the 10 per cent of worst performers from the exporting country or its exporting sub-region from the outset, which would incentivise electricity exporters to provide actual data in order to lower the CBAM charge incurred. 2. Account for indirect CO2 emissions in simple and complex goods. The fact that indirect CO2 emissions in simple and complex goods are not accounted for incentivises the imports of goods produced with CO2-intensive electricity sources, which can create significant risks for the environmental integrity of the fit-for-55 package, as well as competitive distortions between EU producers and third countries. Through close cooperation with Eurelectric and others, data on indirect CO2 emissions present in complex goods imports could hopefully be properly accounted for and charged once the CBAM fully enters into force. 3. Avoid double protection. For sectors where a CBAM is in place, free allocation should be removed. Eurelectric therefore welcomes the Commission proposal to phase out free allowances for CBAM sectors in this regard. The current CBAM design however does not provide coverage to the EU’s exporting sectors, which Eurelectric hopes can be addressed in some shape or form. 4. Include hydrogen imports into the CBAM. Though hydrogen imports are currently limited, it is anticipated that this will increase significantly in the near future. For hydrogen and its derivatives (e.g. ammonia) that are imported, the EU should ensure that this is as decarbonised as possible. Eurelectric proposes to include hydrogen and its derivative sectors in the first CBAM design, both their direct and indirect emissions. This should be coordinated with the introduction of a harmonised certification system that can distinguish different forms of hydrogen. 5. Manage administrative complexity for importers of electricity and EU member states. To limit administrative complexity for entities/importers of goods that will be included in the CBAM, all provisions should be carefully examined (e.g. the 80% CBAM certificate registry rule) and then simplified as much as possible, which in turn increases the chance of compliance. The possible creation of CBAMs in other parts of the world should also be anticipated and where possible coordinated. Furthermore, standards need to be unified and transparency ensured in the functioning of the CBAM to not create excessive administrative burdens for the Member States.
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Response to Review of Directive 2012/27/EU on energy efficiency

17 Nov 2021

Eurelectric, the European electricity industry association, welcomes the chance of expressing its views on the Commission’s proposal for a more ambitious Energy Efficiency Directive. Our full feedback is attached. However, for the ease of the readers, our main comments and reactions are included hereby: • Energy Efficiency First Principle: We welcome the fact that it is enshrined in the EED as a compulsory test in relevant legislative, investment, and planning decisions as long as it always ensures full compliance with the EU’s climate targets, incl. GHG emission reductions. EEFP should be understood as an overarching principle to be applied in conjunction and compliance with other policy objectives in a system approach paying attention to security of supply and the transition to climate neutrality. • Energy Efficiency Target We support an upward revision of the target. The target architecture and the enhanced monitoring role of the Commission should go hand in hand with additional support and guidance for Member States to implement the measures needed to reach the higher ambition. We warn caution on the specific level of ambition of targets’ increase, which can be challenging for some to match. • Energy saving obligations: The energy savings obligation of annual reduction applied to Member States from 2024, (i.e. from 0.8% to 1.5%) is too high. Especially in combination with the necessary tightening of the eligibility of the measures, as detailed by Annex V. • Primary Energy Factor: We welcome the fact that the EU PEF of 2.1 is proposed as a default number. The PEF value for electricity should be dynamic and forward looking, taking into consideration both the lifespan of the measure and the future energy mix. The possibility of national deviations from the default PEF value is seen positively. It should however be considered as a provision that promotes a downward revision of national PEFs. • Eligibility of the use of fossil fuel combustion technology for savings obligations: We are supportive of the gradual phase-out of the use of fossil fuels as indicated in Annex V; however, the deadline of 2024 is premature. We look forward to engaging with the policymakers and other stakeholders to advance these timely discussions.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

15 Nov 2021

Eurelectric supports the increased 2030 EU RES target of at least 40%. The key role of renewable electricity is recognised through different amendments, for example, MSs setting up RES-E frameworks, the issuance of GOs for every MWh of renewable energy produced upon request from producer independently of benefitting or not from a support scheme, the enhanced requirement for promoting PPAs, better coordination in offshore planning, labelling of industrial products, the promotion of charging infrastructure able to interact with the grid. The amended REDII proposes a new architecture of sub-targets which poses the risk of transforming this directive into a very complex piece of legislation. Further clarification is needed on the interactions between the different sub-targets, and it should be ensured that renewable electricity can count for the Heating and Cooling (H&C), District Heating and Cooling (DHC) and industry targets. Regarding transport, the way renewable electricity is accounted for concerning battery electric mobility is welcomed and should be complemented where technically possible with additional flexibilities backed by robust verification/traceability to avoid double counting. The shift to an emissions-based target coupled with the new obligation of implementing a fuel-neutral credit mechanism needs to be further clarified. The credit mechanism should also cover, where possible, private and semi-public charging points, and it should be possible for it to be applied to other types of transport. Getting the enabling framework right is crucial to achieving the increased RES ambition: more needs to be done on speeding up permitting procedures, supporting RES-based electrification, including through making full use of article 15 in the existing Energy Taxation Directive, and cooperation on joint RES projects should be incentivised without adverse impacts on market-based investments and made available for projects developed under international consortia or joint ventures. Facilitating the system integration of renewable electricity is welcome but disclosing the RES-E and GHG content of the electricity supply is a complex exercise and should be recognised as such, through an optional rather than mandatory provision. A stable rulebook for sustainability and GHG savings criteria for bioenergy should be ensured. Priority should be given to the implementation of existing criteria in REDII and data gathering to gain further insights into biomass markets. Please find attached Eurelectric's reaction paper on the proposed amendments to the REDII, part of the "Fit for 55" package.
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Response to Revision of the CO2 emission standards for cars and vans

8 Nov 2021

The European electricity industry, represented by Eurelectric, welcomes the publication of this Commission's initiative to tackle the emissions from road transport. With the proposed CO2 emission performance standards for cars and vans, the European Commission has shown a real commitment to reach carbon neutrality by 2050. The proposal would ensure that the 2019 Regulation is updated to be fit for the 55% GHG reduction by 2030 target. Additionally, the European Commission has come forward with a strong and welcomed target of 100% CO2 emission reductions by 2035, substantially phasing out the polluting internal combustion engine (ICE) and detailing a cost-effective path to transport decarbonisation. This proposal is mostly in line with Eurelectric’s positions. Eurelectric fully supports the newly proposed emission reduction targets for cars and vans, aiming at 2035 as the date for the phase-out of the internal combustion engine (ICE). Nonetheless, improvements are possible to make sure that e-mobility experiences the acceleration it needs, namely: - To sustain these higher ambitions, Eurelectric suggests putting the automotive industry on a clear linear path for CO2 reductions until 2035, with frequent and precise targets. - Eurelectric proposes the reconsideration of the currently existing benchmark for sales of zero- and low-emission vehicles (ZLEVs). First, it should now focus on zero-emission vehicles (ZEVs), hence excluding highly polluting plug-in hybrid electric vehicles (PHEVs). Also, it should be progressively increased to reach a 100% share of ZEVs to be sold in 2035. More information is available in the attached position paper.
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Response to Updating the EU Emissions Trading System

8 Nov 2021

Please find below a summary of the views of the power sectors on the proposal of the European Commission on the ETS. For more details, please see the document enclosed. • Increase the ambition in the EU ETS. We welcome several of the Commission’s proposals to strengthen the EU ETS in line with the increased 2030 climate target, including the increased linear reduction factor (LRF) to 4.2% in combination with a one-off reduction of 117 million allowances as of 1 January 2024. We also welcome keeping the Market Stability Reserve (MSR) intake rate at 24% and increasing the Modernisation Fund with an additional 2.5% of the cap to further support the energy transition in lower-income Member States. The additional 2.5% cap should be calculated on the entire 2021-2030 period (just like the increased LRF). • Lower the Market Stability Reserve (MSR) thresholds. The introduction of a buffer zone between the total number of allowances in circulation (TNAC) and the MSR’s upper threshold (833 million) is welcome, but its upper level of 1,096 million would weaken the effectiveness of the MSR (ceteris paribus). To address this, both the MSR’s buffer zone upper level (1,096 million) and the upper threshold for hedging (833 million) should be lowered to properly reflect an increasingly decarbonised economy and gradually declining hedging requirements. The exact levels should be determined through analysis to ensure a smooth market functioning. • Reform the EU ETS product benchmarks as soon as possible. We welcome the Commission’s intention to revise the scope of the benchmarks for hydrogen and heat to avoid installations with decarbonised processes falling out of the ETS and to remove references to specific feedstocks and production processes. In the case of district heating and cooling, the revision should reflect different starting points and prevent a disproportionate increase of heating prices. The benchmark reform will speed up the adoption of newer, cleaner technologies. Such reform should happen as soon as possible and not wait until the start of the second half of Phase IV. • Make the Modernisation Fund future-proof. Gas-based projects could be financed, provided that i) they are carried out as part of a credible decarbonisation plan in accordance with the 2030 climate target and the EU’s 2050 net-zero GHG emission target, ii) they are able to be upgraded for new decarbonisation technologies in the future and iii) electrification is not technologically nor commercially feasible at reasonable cost. • Support the development of a European carbon market. The introduction of a Carbon Border Adjustment Mechanism (CBAM) for electricity is welcome, but ultimately its end goal should be to encourage neighbouring markets to develop their own carbon markets and link them to the EU ETS. Building on the successful link with the Swiss ETS, further linkages would support a larger, more stable carbon market and enable a level playing field with electricity generated at the other end of interconnectors.
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Meeting with Frans Timmermans (Executive Vice-President)

11 Oct 2021 · Courtesy meeting with the new President of Eurelectric

Response to Action plan on the digitalisation of the energy sector

10 Sept 2021

The electricity industry, represented by Eurelectric, welcomes the publication of the Roadmap for the Action Plan on the digitalisation of the energy sector. The digitalisation of the energy sector contributes to economic growth and job creation, to boosting competitiveness and innovation, and to drive the development of innovative solutions leading to new sustainable energy products and services for European citizens. Eurelectric urges the Commission to focus its Action Plan on electricity, given the growing importance of electrification needed to reach the 2030 and 2050 climate and energy objectives. Prioritising direct electrification is crucial to enable the decarbonisation of emerging and established industries, as well as the development of smarter, cleaner, and more integrated energy systems. In addition, digitalisation - by redrawing boundaries and redefining relationships between consumers and utilities - enables the technological development and commercialisation of crucial flexibility, demand-side, storage solutions and services. To foster the digitalisation and the sector integration of energy carriers, the Action Plan must foster active participation of end-users across energy systems. However, following actions are essential to support the electricity industry on its path towards digitalisation: • Developing a European data-sharing infrastructure (aligned with the interoperability requirements and procedures of Art.23/24 of the Electricity Directive) empowering network operators to ensure consistent and neutral data management practices. Furthermore, timely data availability is essential to harness the full potential of digitalisation. • Avoiding compulsory data sharing schemes that may lead to unfair competition: as recommended in the EU Strategy for data, to develop competitive markets for digital energy services, the sharing of privately held data should be done on a voluntary basis. • Promoting the deployment of advanced metering infrastructure providing accurate consumption and generation data. • Removing barriers to the development of digital tools enabling flexibility and local grid-balancing services, including requirements for the collection of non-personal data as defined in the ePrivacy Regulation. • Ensuring a coherent and homogeneous implementation of the AI Regulation in the energy sector. • Ensuring the cybersecurity and resilience of digital supply chains, aligned with the requirements and procedures of Art.51 of the Cybersecurity Act. • Enhancing and ensuring a coherent and harmonised Cybersecurity legal framework for all stakeholders of the energy system - along with the development of the proposed NIS-2 Directive and the planned Network Code on cybersecurity of cross border electricity flows – to address the risk of cascading effects induced by growing interconnections of energy systems, supporting cyber assets, and related data. • Facilitating the development and deployment of interoperability measures and European cloud offerings enhancing the scaling up and uptake of digital climate-neutral piloted solutions. To this regard, the SWIPO codes of conduct must be sustained to increase trust in European cloud offerings. • Encouraging research ventures between the scientific community and the power industry harnessing the full potential of open data platforms and licenses. • Promoting best practices and experiences from R&I projects developing new digital tools and services to facilitate active participation of actors across energy networks. • Addressing social challenges highlighted by the Digital Economy and Society Index, in particular: citizens' trust in data-driven energy services, acceptance of new technologies, data protection and privacy concerns, digital divides, and lack of adequate skills.
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Response to Gas SoS – risk groups amendment

10 Aug 2021

Regional cooperation is an essential dimension for safeguarding the security of supply inside the European energy markets. With their continuous integration but also the increased interdependency between gas & electricity sectors, solidarity mechanisms are key to anticipate supply disruption risks and minimise their potential negative collateral effects. With the Regulation (EU) 2017/1938 concerning measures to safeguard the security of gas supply, the solidarity provisions to be implemented by the Member States must handle such risks and contribute to strengthening the resilience of the gas system across Europe. Eurelectric fully supports regional cooperation in order to address the security of gas supply issues, through the establishment of regional risk groups as well as the implementation of National Preventive Action Plans and Emergency Plans. Eurelectric welcomes the Delegated Regulation proposed by the Commission, as a revision of the 2017 Regulation, to update the composition of the regional risk groups, amended in view of the United Kingdom’s departure from the European Union and of new or upcoming gas infrastructures to enter in operation by 2023. For this purpose, the European Commission should set a relevant and comprehensive set of regional groups to make sure that the size is appropriate to deal with the various regional challenges. We notice that the proposed update leads to potentially quite large groups (e.g. Ukrainian and Belarus risk groups), with numerous countries involved, which may be a source of additional burden for those countries in the work process of the risk assessments to be performed. Moreover, we would like to specifically remind the importance of dialogue and cross-border cooperation among involved stakeholders, within their national scope but also with neighbouring countries or countries of the regional risk group. This is especially key for infrastructures recently commissioned for which involved stakeholders should get a broader, regional view or conduct in terms of data exchange and transparency, for both daily operations and hazards management. For this purpose, the regional TSO and NRA collaboration within these groups needs to be strengthened.
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Response to Revision of Non-Financial Reporting Directive

14 Jul 2021

Eurelectric welcomes the European Commission's proposal for a Corporate Sustainability Reporting Directive (CSRD) and appreciates the possibility of providing short feedback. Please find attached, Eurelectric's contribution to the consultation.
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Meeting with Ditte Juul-Joergensen (Director-General Energy)

4 Jul 2021 · Electrification and current policy priorities in the context of the European Green Deal.

Response to Delegated Act on the Ancillary Activity Exemption

24 Jun 2021

The “MiFID II quick-fix” (Directive (EU) 2021/338) amended the Ancillary Activity Exemption (“AAE”) of Article 2 (1) (j) and (4) of the Markets in Financial Instruments Directive (Directive 2014/65/EU, “MiFID II”). The amended AAE exempts persons (non-financial firms) dealing on their own account or providing investment services to clients in commodity derivatives, emission allowances or derivatives thereof, provided this is an ancillary activity to their main business on a group basis and the main business is not the provision of investment services within the meaning of MiFID II or banking activities under Directive 2013/36/EU. The current Commission Delegated Regulation 2017/592 (“RTS 20”), which will be replaced by a new delegated regulation of the EU Commission, establishes quantitative tests which define what constitutes an ancillary activity. These tests are the Market Size Test and the Main Business Test, the latter consisting of an alternative Trading Test and Capital Employed Test (see Articles 2 and 3 of RTS 20). In this context, the EU Commission published for public consultation its draft delegated regulation of 27 May 2021 for the implementation of the AAE (“draft EC DA”). Eurelectric, as a member of the Joint Energy Associations Group (JEAG), fully supports this draft EC DA for the reasons explained in the attached document.
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Meeting with Kurt Vandenberghe (Cabinet of President Ursula von der Leyen)

23 Jun 2021 · Fit for 55

Meeting with Thierry Breton (Commissioner) and

23 Jun 2021 · Discussion on the preparation of the Fit for 55 package, as well as on the implementation of the updated industrial strategy.

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

2 Jun 2021

Eurelectric welcomes the opportunity to provide feedback to the European Commission (EC)’s public consultation about the draft EU Taxonomy Art. 8 Delegated Act (DA). Detailed comments in the attached paper. Sustainable finance is a key building block of a European decarbonisation roadmap. The EU Taxonomy must enable the whole electricity sector to contribute to the targets as a diversity of generation assets will be needed in the transition to a carbon-neutral economy. Eurelectric supports a target of at least 55% GHG emissions reduction by 2030. The electricity industry is committed to delivering a carbon-neutral power supply for Europe well before 2050. Reaching this carbon-neutral power system while meeting an increase in electricity demand that is unprecedented in recent times will require significant investment. The approach to sustainable finance should enable achieving the long-term decarbonisation objective of carbon-neutrality. The entry into force of the EU Taxonomy DA on Art. 8 must take place gradually. The electricity industry is committed to implementing the EU Taxonomy. Nevertheless, it should be considered that the new disclosure requirements will inevitably disrupt companies’ current accounting and reporting systems and require internal changes. Furthermore, they are based on regulations that have recently been adopted (the Climate DA) or are still due to be adopted (the Complementary DA & the Environmental DA). Thus, we welcome the phased-in approach proposed by the EC reflecting the complexity of adapting to new disclosure requirements and formats. Due to the very complex requirements and very short time to prepare properly, we urge the EC to extend any taxonomy requirement by one year, starting with a phased-in approach. Reporting and format requirements should allow for some flexibility to reflect the specificities of different companies and their activities and to ensure continuity with current global standards. While coherence in reporting is essential to ensure comparability of data, it is important to consider that the EU Taxonomy applies to a variety of companies and activities. Thus, the reporting requirements should ensure flexibility for companies to better adapt to the new obligations and deliver a set of data that would be useful and relevant to all stakeholders. Particularly, flexibility is essential for reporting format requirements to allow companies to continue using widely applied global standards and allow for a level-playing field between European companies and third-country businesses, especially regarding company-specific information. Reporting requirements should not be too granular with limited added value, unnecessary complexity, and disproportionate additional reporting costs. In this regard, KPIs should focus on one environmental objective. For investors, it should be sufficient to see if the activity is Taxonomy-aligned. Hence, it should be made clear that companies should not assess their activities against all objectives, i.e. companies should be able to select the most relevant objective for their business. Thus, only the main environmental objective that has been duly chosen to assess significant contribution should be disclosed. Ensuring coherence with the European reporting framework: the reporting standards and requirements as set out in the EU Taxonomy draft DA shall be in coherence with CSRD, including the harmonised reporting standards to be developed by the EFRAG, the EU Green Bond Standard and the SFRD. More guidance on the KPIs and the methodology should be provided to the industry. To ensure that the implementation of the EU Taxonomy, especially from the reporting and disclosure perspectives can take place smoothly, we call for the EC to consider further guidance on certain elements related to KPIs and the methodology. In this context, Eurelectric would be happy to further contribute with practical insights, especially regarding the KPIs and the methodology.
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Meeting with Frans Timmermans (Executive Vice-President)

25 May 2021 · Keynote speech at Eurelectric Power Summit

Meeting with Thierry Breton (Commissioner) and ENEL SpA and

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

Meeting with Nicolas Schmit (Commissioner) and

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

Response to Guidance on REDII forest biomass sustainability criteria

28 Apr 2021

Eurelectric supports the use of forest industry by-products and wood residues for energy production, as the use of sustainable woody biomass can make a meaningful contribution to climate change mitigation. We acknowledge the concerns that an increased EU biomass demand could also have negative impact on carbon sink and biodiversity. Robust and harmonised implementation of the new sustainability criteria for forest biomass by Member States and economic operators is crucial. However, the now published draft of the guidance goes beyond the regulation on the directive itself. The draft widens the regulation to areas the directive does not handle and should thus be carefully assessed again as a whole. All the parts which do not only specify the directive but takes the regulation further should be removed from the guidance or altered to meet the level of the directive. The possible strengthening of the current criteria should not be matter of secondary legislation but discussed and decided by the co-legislator. The sustainability criteria (in REDII) for biomass are well taking into consideration national requirements for ensuring the sustainability of forest biomass. This country or harvesting area risk- based approach is highly appropriate and it should be respected. We believe the suggested guidance does not, in practice, allow to use the country-based approach as widely as was meant to originally. This is not a matter of sustainability itself, but a matter of the mechanisms and systems operators can use to demonstrate compliance to national authorities. Eurelectric is concerned that the draft leaves a heavy weight burden for the operators to prove the sustainability even in cases when it is clear the biomass is produced according to the criteria. We are highly concerned on the effect this will have specially on the small locally operating companies. Bearing in mind the issues above, we believe that changes to the guidance are needed to improve the document and make the execution of sustainability criteria possible for the operators, in the given time limits. The guidance should not try to add on regulation on the criteria on country-level (art. 29 6a.) The directive is clear on how the criteria shall be considered in the national legislation. When some of the criteria are noted in the national legislation, it is sufficient (according to the directive). If some of the criteria are not regulated in national laws, it could be concluded that the criteria have not been taken into consideration and that specific criteria must be proved in some other way by the operator. The adequate required level of monitoring is also regulated in implemented national laws and therefore the operators should not be obligated to assess the level by themselves. The guidance should be restricted to clarify the criteria on sourcing area-level (art. 29 6b) by giving advice on good practices on how to fulfil the requirements (voluntary certificates, existing reporting systems etc.) and not widen the criteria set in the directive. Some parts of the guidance are defined contrary to how they are defined in the directive and some of the definitions would also need some fixing to be clear. More detailed comments are available in the uploaded file
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Meeting with Daniel Mes (Cabinet of Executive Vice-President Frans Timmermans)

13 Apr 2021 · Zero emission urban vehicle fleets

Response to Modification of the General Block Exemption Regulation for the Green Deal and the Industrial and Digital Strategies

2 Apr 2021

The revision of GBER should go hand in hand with the revision of the Energy and Environmental Aid Guidelines (EEAG)considering the new principles established under the European Green Deal as well as the Industrial and Digital Strategies. State aid has a role to play when there are well-identified structural market failures, making market signals sufficient to achieve Green Deal’s objectives. EEAG should be the reference tool to define the framework allowing Member States’ support, while the GBER should remain complementary for specific projects. Eurelectric invites the Commission to consider the following points when revising the GBER: 1) Increase exemption notification thresholds for: - investment aid for environmental protection (currently aid up to €15 million euro per undertaking per investment project) - Specific threshold applying to the different types of investment aid related to Section 7 of the GBER (mentioned at Article 4 (s) to (x)) - Large aid schemes for renewable energy exceeding €150 million per year and granted on competitive bidding process basis. The main motivation is to reduce processing time of state aid application files by EC. Fast-track procedures should be set up to speed up the deployment of projects and meet decarbonisation targets. In return, a sufficient level of transparency is required for projects exempted from notification requirement to ensure compliance with EEAG principles. 2) Increase the limit of the combined budget of all schemes falling under Art. 42 GBER in the Member State concerned. 3) Flexibility to modify authorized schemes should be offered to deploy more efficient solutions in terms of emission reduction and costs aligned with the EU Green Deal objectives. Notification should be exempted if new schemes proved to be more efficient from an environmental and economic point of view. It could be offered on a voluntary basis exclusively to the successful bidders of previous authorized schemes. 4) Eligible costs - Costs considered eligible by the GBER should cover capital expenditures and operational expenditures since projects benefiting to environment and the energy transition are facing very different risks during their lifetime. 5) Concepts of investment aid and operating aid including cost structure (CAPEX, variable OPEX, fixed OPEX) should be further clarified and aligned with EEAG definitions. 6) Clarify the rules for the cumulation of aids (Art. 8) 7) Aid intensity - Adopt a funding gap approach for most of technologies by means of auction as most appropriate way to discover the funding gap which remains to cover. The currently permissible grounds for derogating from competitive aid should be maintained in some cases where the allocation of support at auctions may yield sub-optimal results. Where it is not possible to apply, the “aid intensity approach” shall remain the method of quantifying. -The revised EEAG and GBER should maintain the aid intensity bonus currently foreseen for assisted areas. It is important for EEAG and GBER to consider the different starting points of Member States in the decarbonisation. - Increase aid intensity threshold for large companies. - Increase aid intensity threshold from 25% to 50% for support to research and innovation projects under “experimental development category” (Art 25). Current rate is too low compared to other EU funding programmes for activities with same TRL (70% for H2020, 50% for CEF, 60% Innovation Fund, 55% for LIFE). 8)Broaden definition of energy infrastructures (Art. 48 GBER) to evolution of technologies, increasing electrification and digitalisation of the power system. 9) Introduce dedicated categories for : o Charging electric vehicles infrastructure o Hydrogen generation produced from renewable and low carbon sources. Renewable or low carbon hydrogen generation facilities especially from electrolysis of water could be key to decarbonize sectors where direct electrification is not possible.
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Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

22 Mar 2021

The energy performance of buildings is a critical issue to tackle in order to reach a climate neutral economy. With 40% of the total EU energy consumption used to heat or cool buildings, improved standard and targets are essential aspects of the task. Following the Renovation Wave Strategy, Eurelectric fully supports the revision of the Energy Performance of Building Directive (EPBD). Please find attached Eurelectric feedback to the Roadmap on the revision of the EPBD. Key messages: > Enhance the energy and climate performance of all buildings (public and private, non-residential and residential) is key to reduce their carbon-footprint towards a “near-zero energy and emission building” target. Therefore, we support an increased and more stringent ambition for buildings decarbonisation at European level. > The EPBD needs to ensure that buildings are smart and climate resilient. Alongside higher buildings renovation rates, the revision can foster synergies with other sectors, primarily the energy one. Improved energy efficiency in buildings will only be achievable by a system-wide approach to fully leverage the potential of highly efficient, smart and flexible buildings. > The integration of electricity in buildings is essential to reduce their carbon footprint, supporting the switch from old fossil-fuel based heating systems to low-carbon energy solutions. Power-based solutions are already available to improve the energy efficiency of buildings while reduce air pollution, GHG emissions and improve living conditions. > Buildings and vehicles: an underdeveloped synergy with the transport sector. Given that 80% of electric vehicles charging happens at home or at work, it is urgent to tackle the outstanding barriers and create favorable conditions for deploying charging infrastructure in all buildings, for both the new and the existing stocks > Improving the energy performance of buildings leads to lower energy bills for consumers, thereby contributing to consumer protection and the alleviation of energy poverty. > The EPBD revision should be coherently implemented within the “Fit for 55 Package”, together with the revision of other pieces of the regulatory framework, in particular the Energy Efficiency Directive (EED) and the Alternative Fuels Infrastructure Directive > As the revision of the EED and thus of the Primary Energy Factor (PEF) will start before the revision of the EPBD, it is important to make sure that the role of PEF in both texts is that of a real enabler of decarbonisation rather than a barrier. PEF calculations in the EPBD should equally treat energy from RES generated on-site and RES supplied through an energy carrier.
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Response to Revision of EU rules on Gas

10 Mar 2021

The H2/Gas Markets Decarbonisation Package is necessary to prepare the energy system for the challenges posed by the decarbonisation journey. The framework should be coherent with the energy efficiency first principle and the EU’s acquis. Moreover, a pragmatic approach should be adopted regarding the contribution of a decarbonised gas sector to a carbon-neutral Europe. Revised rules will prepare the gas market for its new dual role and set an adequate framework for the required investments. On the one hand, decarbonised molecules will be used in the hard-to-electrify sectors. On the other, gas can provide additional flexibility solutions when and where efficient for the energy system. The latter will be dominated by variable RES and require a broad panel of flexibility options for balancing needs across timeframe coming from inside and outside the power system. Our Decarbonisation Pathway Study foresees that the fossil energy supply will be gradually phased out and represent only ~5% of total energy supply by 2045. Moreover, gas will still account up to ~15% of total installed electricity generation capacity in order to secure system reliability, especially in regions that don’t have access to hydro or nuclear, depending on national specificities and the changes in their generation mix. The irreversible decline of fossil fuels (including natural gas) needed for the 2050 carbon neutrality objective requires further direct electrification and, where this isn’t feasible or efficient, the use of other energy carriers such as R&LC. Conversion of carbon-free electricity to produce R&LC gases allows the decarbonisation of the hard-to-electrify sectors and will contribute to a more integrated energy system. Therefore, synergies between sectors, technologies and regulatory frameworks should be fostered to ensure a coordinated planning and operation of the energy system. Renewable sources of energy should be promoted within RED II currently under revision, while the H2/Gas Package should enable an efficient integration of R&LC gases into the market, on both commodity and infrastructure sides. A resilient gas market, driven by the common objective of a decarbonised economy, will unlock the potential of a decentralised, digitalised and interconnected energy sector. Therefore we call to: -Develop a clear classification and sound definitions of R&LC gases, including P2G fuels, taking into account the GHG emissions relative to their full lifecycle. -Align the Gas/H2 Package with the objectives of the ESI & H2 Strategies and prepare the gas sector for deep decarbonisation by 2050. -Tackle gas quality and interoperability issues to avoid market fragmentation which may occur with the emergence of new gases. -Gradually develop a H2 market based on thorough and cost-effective scenarios reaching European and national targets, taking into account technological constraints. As suggested by the H2 Strategy, the first priority should focus on decarbonising the current H2 production and develop a sustainable & liquid H2 market. -Incentivise H2 production via electrolysis using adequate direct support and funds and a carbon allowances scheme that do not distort competition between technologies or energy carriers. -Ensure a cost-effective, unbiased and future-proof approach to energy infrastructure development, based on the energy-efficiency first principle, considering the LT target of climate neutrality and minimising the risk of stranded assets. -Ensure a level-playing field and fair competition between flexibility providers and different energy carriers, especially with the review of network charges and the application of the same tariffication principles across the electricity and gas sector for storage and conversion activities. -Align the rights of gas consumers with the framework provided by the CEP. -Clarify the definition and role of P2G installations as genuine market-based activities assets and insert them in a proper regulatory framework.
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Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis)

2 Mar 2021 · Sustainable finance taxonomy

Meeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness)

2 Mar 2021 · Sustainable Finance Taxonomy

Meeting with Kurt Vandenberghe (Cabinet of President Ursula von der Leyen)

25 Jan 2021 · European Green Deal and possible keynote speech of the President at an event organised by Eurelectric in May 2021

Response to Climate change mitigation and adaptation taxonomy

17 Dec 2020

Eurelectric supports a target of at least 55% greenhouse gas (GHG) emissions reduction by 2030. The electricity industry is committed to deliver a carbon-neutral power supply for Europe well before 2050 and is transforming the energy system to make it more and more responsive, resilient and efficient. Carbon-free direct and indirect electrification as well as the resulting energy efficiency gains will make the key contributions to the decarbonisation of transport, buildings and industry. Today, the business strategies of many electricity companies are dedicated to the achievement of a carbon-neutral generation, transmission, distribution and supply of power, in line with the objectives of the EU Taxonomy regulation. Creating such a common language for investors, assets’ managers, corporates and public authorities is crucial to support the transition towards a decarbonised economy. However, the alignment between the EU Taxonomy and companies’ priorities can still be improved while the legislation still need to be implemented and business models can still be refined to improve minor non-strategic issues. In this context, we welcome the opportunity to provide our feedback on the proposed draft delegated act. While some improvements compared to the final Technical Expert Group on Sustainable Finance (TEG)-report have been made, we believe key issues remain to be addressed in the draft delegated act. We are worried that the draft delegated act is deviating from two important points. First, it should strictly adhere to the provisions of the level 1 Taxonomy regulation. Second the delegated act must align with current EU legislation to avoid unnecessary double standards. Please consider the attached papers detailing the views of the electricity industry.
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Response to Protecting biodiversity: nature restoration targets

2 Dec 2020

Eurelectric welcomes that the European Commission will propose a new regulation to impose legally binding nature restoration targets. Beside policies aiming to protect the local environment, we will further have to reduce the pressure on our global environment, by combating climate change. The power sector is striving to achieve carbon-neutral electricity by 2045 and we need more sustainably sourced energy to lead the fight against climate change and biodiversity loss. As the European Union is considering a 2030 higher greenhouse gas (GHG) target - that could lead to a higher 2030 EU RES target - and given the importance a clean and renewable energy supply would play in the decarbonisation of energy intensive sectors, it has to be ensured that enough space is available for the necessary expansion and upgrading of existing power infrastructure and installation of new facilities, including renewable and carbon neutral generation, storage and grids, whereas compensation is possible. Eurelectric calls for a consistent approach in the new regulation to possibly impose legally binding nature restoration targets to ensure that biodiversity as well as energy and climate policies go hand in hand. Please find the full feedback from Eurelectric attached.
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Response to Updating the EU Emissions Trading System

26 Nov 2020

Eurelectric supports the ambition of net-zero greenhouse gas emissions in the European economy by 2050 and an at least 55% target of GHG emissions reduction by 2030 as proposed by the Commission. All sectors of the economy need to contribute to making the EU a climate-neutral economy. According to our Decarbonisation study (2018), this ambition is best achievable through deep electrification of transport, buildings and industry. Eurelectric supports an EU ETS geared to reaching 2030 and 2050 climate targets. The Linear Reduction Factor should be appropriately recalibrated as soon as feasible after the adoption of new targets, and the potential for rebasing should be assessed to assist price stability by closing the structural gap between supply and demand. We emphasise a swift approval of the ETS revision in order to be able to contribute to reaching the revised 2030 target. The IA needs to consider adjusting the burden-sharing between ETS and non-ETS sectors, also taking into account the LULUCF sector. Increased use of electricity is key to decarbonise all sectors, so the IA should consider the effects on electrification by a higher burden on the EU ETS. Impact of other policies on the ETS effectiveness has to be assessed, any policy overlaps with the ETS have to be mitigated. Proportionally to the new climate commitments, the ETS Directive should foster compensatory measures to mitigate associated compliance costs. In order to assess the effectiveness of carbon pricing in non-ETS sectors, the upcoming impact assessment needs to look at the number of emissions sources, respective abatement costs, effect on the overall cap and the existing national policies and taxes while reflecting national specificities. The intake rate should be maintained at 24% to avoid year-to-year step changes in the operation of the MSR. MSR hedging thresholds should be updated to reflect lower demand in an increasingly decarbonised economy. We hereby highlight a few possible impacts when considering extending the EU ETS: Heating: Inclusion of heating of buildings into the ETS offers a significant increase in the volume of emissions covered by the cap and could level the playing field between different heating technologies. Social acceptance of the related impacts should be taken into account in order to guarantee the effectiveness. The consideration of carbon pricing in the form of a carbon tax should also be part of the IA and evaluated in terms of effectiveness. Road transport is already covered by efficient policies to reduce emissions in the form of emission standards for all vehicles and renewable targets. Current price levels of the EU ETS will not deliver the needed emissions reductions in this sector. Incentives for electrification should therefore also be investigated via other carbon pricing options. Inclusion of road transport has to be considered only as complementary to the existing CO2 performance standards and existing incentive schemes. Electrification of this sector is key to achieve considerable reductions, but considering the high marginal abatement costs, changes will be driven outside the ETS. An approach to carbon taxes on transport fuels may be a revision of the Energy Taxation Directive reflecting the carbon content. Maritime: Short sea shipping and inland waterways offer greater potential for electrification or electricity-based fuels, and as a cross-border and price sensitive sector like aviation, are a suitable candidate for EU ETS inclusion, mirroring the approach taken for aviation. The IA could investigate a gradual approach for extending the scope of CO2 pricing to the Non-ETS sectors. To meet net zero targets, negative emissions allowances could be assessed. The IA should assess the synergies of various other EU energy targets to find the most cost-efficient pathway to reach the revised 2030 climate target. Please see our detailed EU ETS and effective carbon pricing position attached.
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Meeting with Kadri Simson (Commissioner) and

17 Nov 2020 · TEN-E and upcoming Fit for 55 proposals.Offshore strategy. Grid investments.

Meeting with Adina-Ioana Vălean (Commissioner) and

15 Oct 2020 · E-mobility

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

21 Sept 2020

Electricity has been decarbonising fast: 59% of the electricity mix was decarbonised in 2019, and this is expected to grow up to 81% in 2030 . While further decarbonisation of the current power mix is expected in the coming years, deployment of direct electrification should be pursued faster, further and stronger. In order to be on track with EU decarbonisation goals the level of direct electrification should be between 33 and 38% by 2030 , compared to 23% in 2020. However, the current trends in RES capacity investments (in wind and solar) are not enough in a business as usual scenario. Wind capacity needs to double vis-à-vis 2019 levels, from 192 GW to 381 GW, while solar capacity needs to triple from 132 GW to 385 GW. The recently published Energy System Integration Strategy sets the basis to create stronger links between energy carriers, infrastructures and the consumption sectors to deliver on a low-carbon European economy. The use of clean electricity into more areas such as heating and cooling, buildings, industry and transport will play a central role, coupled with the energy efficiency benefits that electrification entails as well as the use of clean gases for ‘harder-to-abate’ sectors. Eurelectric would like to draw attention to the necessity to adopt a coherent policy approach between the EU ETS and 2030 targets to ensure consistency between different policies and measures. In this context, the priority should be to leverage the revision of the Renewable Energy Directive (RED II) to support direct electrification in end-use sectors where fossil fuels remain the main fuel (transport, buildings and industry). Clean hydrogen – produced through decarbonised electricity - and other renewables gases will have a key role to play in decarbonising sectors where direct electrification is not possible, helping with bridging the gap towards EU climate neutrality and zero pollution goal. Stimulate the use of renewable electricity in transport and buildings RED II allows Member States to meet their renewable transport targets through a combination of more electric vehicles, more renewable electricity and the agreed multiplier of 4 for road transport rather than using biofuels. The Commission could go further by proposing rules incentivising the use of electricity, including renewable electricity. Regarding buildings, the review of RED II and the Energy Efficiency Directive should be consistent to avoid conflicts between RES measures and energy efficiency measures and ensure an integrated approach. Contribute to a market-based and competitive development of sustainable gases Until power-to-gas reaches maturity, sustainable gases will be used primarily when no competitive electric alternative to fossil fuels exists for some industrial processes and shipping. Therefore, Eurelectric does not support the introduction of sub-targets for renewable gas penetration. However, the penetration of renewable sources should be comprehensively lifted across all sectors with specific incentives. In this context the implementation of a trading system for renewable guarantee of origin can be a pivotal instrument. The classification of decarbonised and renewables gases (electrolytic hydrogen, synthetic methane, biogas biomethane) should be clarified with relevant and simple definitions and established by the European Commission in a clear and consistent manner. The main criteria of this classification should be the emissions of the gaseous products over its whole lifecycle - i.e. starting with the production processes and until the delivery of the gas to the end- consumer’s entry point. A carbon-neutral economy does not mean switching blindly to full electrification – decarbonised molecules would be needed where they are essential. To this end, the complementary role of sustainable gases should be determined by considering (a) the expected future cost of decarbonised & renewable gases vis-à-vis electricity and (b) their expected availability.
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Response to Review of Directive 2012/27/EU on energy efficiency

21 Sept 2020

Electricity has been decarbonising fast: 59% of the electricity mix was decarbonised in 2019, and this is expected to grow up to 81% in 2030. While further decarbonisation of the current power mix is expected in the coming years, deployment of direct electrification should be pursued faster, further and stronger. In order to be on track with EU decarbonisation goals the level of direct electrification should be between 33 and 38% by 2030, compared to 23% in 2020. However, the current trends in RES capacity investments (in wind and solar) are not enough in a business as usual scenario. Wind capacity needs to double vis-à-vis 2019 levels, from 192 GW to 381 GW, while solar capacity needs to triple from 132 GW to 385 GW. The recently published Energy System Integration Strategy sets the basis to create stronger links between energy carriers, infrastructures and the consumption sectors to deliver on a low-carbon European economy. The use of clean electricity into more areas such as heating and cooling, buildings, industry and transport will play a central role, coupled with the energy efficiency benefits that electrification entails as well as the use of clean gases for ‘harder-to-abate’ sectors. Eurelectric would like to draw attention to the necessity to adopt a coherent policy approach between the EU ETS and 2030 targets to ensure consistency between different policies and measures. In this context, the priority should be to leverage the revision of the Energy Efficiency Directive (EED) to support direct electrification in end-use sectors where fossil fuels remain the main fuel (transport, buildings and industry). Clean hydrogen – produced through decarbonised electricity - and other renewables gases will have a key role to play in decarbonising sectors where direct electrification is not possible, helping with bridging the gap towards EU climate neutrality and zero pollution goal. The undisputable merits of direct electrification can be unlocked by prioritizing the following enablers during the revision of the EED that should be compatible, enhanced by and integrated with the Renovation Wave initiative: A Primary Energy Factor that allows electrical appliances to access the market and be accounted on a level playing field Electric heat pumps constitute market-ready solutions that can be deployed and which can produce up to 4 units of heat for each unit of electricity consumed. Higher benefits can be achieved in combination with PVs, batteries and integrated energy management systems, in well insulated buildings. However, when compared to a fossil fuel based alternative, these benefits do not add up because of the way in which savings from electricity are accounted for in the EED. While the 2018 revision recognised this and lowered the PEF accordingly, an additional review is needed as a high PEF for electricity is acting as a barrier for the decarbonisation of the heating sector. (see a dedicated paper on the topic). Energy efficiency measures targeted to low-income households via dedicated instruments Eurelectric’s E-quality study shows it is possible to design EE measures in a way to compensate low-income households for regressive distributional effects of other energy policies. Effective EE solutions are those that help households to overcome the entry barrier of a lack of initial capital to invest in EE measures. Affordability and up-front costs of low-carbon solutions (EVs, PVs, batteries or heat pump) are sometimes holding back consumers from engaging in the energy transition, especially for low-income households that might benefit the most from adopting them. EE measures can be implemented to target low-income households. The financing of such measures should be based on revenues coming from policies that go beyond energy efficiency itself (i.e. EU funds, revenues generated from other climate and energy measures, JTF, etc.) and not via obligated parties (as it’s done in some EEOS with mixed results, i.e. the UK).
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Response to Commission Delegated Regulation on taxonomy-alignment of undertakings reporting non-financial information

8 Sept 2020

Sustainable finance is a building block of a European decarbonisation roadmap. The EU electricity industry is striving to achieve carbon-neutral electricity by 2045 and contributing to meet the EU climate objectives. A framework for sustainable finance should catalyse investments in long-term innovation and enable rapid deployment of the best available solutions for the decarbonisation, electrification and digitalisation of the economy. As such, the Delegated Regulation on taxonomy-related disclosures should contribute to driving investments into carbon-neutral and low-carbon energy sources. Eurelectric supports the harmonisation of the definition of environmentally sustainable economic activities at Union level by providing specifications of the requirements for entities subject to Non-Financial Reporting Directive (NFRD) on how and to what extent their activities are associated with the EU taxonomy. Yet, we are concerned by the fact that, as part of a delegated act, such specifications won’t be easily adjustable to reflect reality and future developments of the Real Economy. Also, being adopted before the application of the Taxonomy Regulation, the delegated act won’t integrate the stakeholders' experience facing the new obligations, and the overlapping timelines will create a challenge for companies adjusting to the new requirements. Therefore, we urge the European Commission to closely interact with the Real Economy as part of the delegated act's adoption process. Eurelectric agrees to take into consideration the company size subject to the obligations. SMEs will play a crucial role in the green transformation. Thus, some minimum reporting standards for more companies should be considered. Yet, disproportionate reporting obligations and additional costs should be avoided especially in the case of SMEs where these elements may induce real challenges. Importantly, coherence should be secured between the delegated act and the EU acquis to only seek for data significantly adding to the wanted transparency to be mandatory. Such coherence should apply both for sector-specific rules and the generic rules, as well as for the development of regulatory technical standards by the European Supervisory Authorities under the Regulation on sustainability-related disclosures in the financial services sector. Hence, attention should be given to avoiding any additional administrative burden, especially in terms of reporting. Therefore, we recommend taking into account the following elements: - Non-financial reporting requirements should be complemented with a sense of proportion about company’s relevant non-financial information. Non-binding guidelines issued by the EC should additionally support the undertakings in the reporting process. - It is important to respond to the growing demand for data and information from investors and other stakeholders. Thus, when assessing whether non-financial reporting practices meet certain objectives, it should be done based on the justified needs of stakeholders rather than expectations that can create additional reporting burdens for companies without real added value. - Energy companies often consist of several subsidiaries for regulatory or practical reasons. Hence, a parent company should be allowed to comply with the obligations on behalf of the group, as some of these subsidiaries may unduly fall into the NFRD scope, by fulfilling two of three criteria. The focus of investors is the whole group’s impact. Thus, for subsidiaries the comprehensive work being subject to NFRD or delegated acts does not measure up with needs and resources spent. - The delegated act should not lead to a disproportionate additional burden on the reporting companies compared to the full employment equivalent or financial expenditure involved. Hence, the administrative costs of financial and non-financial reporting obligations of companies should not increase what can be duly justified and relevant for all sectors.
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Response to Review of EU rules on fluorinated greenhouse gases

7 Sept 2020

Eurelectric welcomes the publication of the combined Evaluation Roadmap and Inception Impact Assessment on Fluorinated gases (F-gases). The European power sector supports the EU commitment to reduce the global greenhouse gas emissions towards the achievement of climate neutrality by 2050, as part of the European Green Deal objectives, and is willing to commit further efforts to reduce F-gas emissions as far as possible. The combined Evaluation Roadmap and Inception Impact Assessment emphasizes the importance of developing climate-friendly technologies that may permit further emission savings in support of reaching the European Green Deal objectives more easily. Avoiding emissions from F-gases is indeed key to reaching these objectives. In this context, distribution system operators (DSOs) are keen to consider SF6-free alternative products for electrical switchgears. Nevertheless, further development and testing is still needed to ensure the availability of cost-effective, technically feasible and reliable alternative products to SF6 on the market. The concretization of an industrial offer adapted to distribution network operators’ needs is a prerequisite to shift away from SF6 use. Alternative products must be able to ensure operational standards whereby meeting identical technical and safety requirements as SF6 products (e.g. with regard to toxicological risk). The industrial offer should establish competitive dynamics between suppliers and other market actors. In this regard, financial incentives in the short-term and stable regulatory frameworks in the medium-term could encourage and foster the progressive adoption of SF6-free products by compensating additional costs for the development and field testing of pilot projects. These would also allow National Regulatory Authorities (NRAs) to review the effectiveness of the policy measures. Eurelectric is therefore supportive of research and innovation programs (such as Horizon Europe) fostering experimentation and cooperative ventures between DSOs and equipment manufacturers, instrumental to the development and market-maturity assessments of alternative technologies. These measures will help paving the way for a widespread use of alternative technologies which could substitute SF6 switchgear in the future. Considering the average lifetime of 40 to 50 years of a switchgear, switchgears using SF6 currently installed will remain in operation for several decades. To ensure the functioning of the grid and maintain security of supply, the availability of SF6 for maintenance and repairs must be ensured over the full technical lifetime of the current fleet of SF6 switchgears. Furthermore, for some fields of applications, especially in urban areas where space is limited, it will remain difficult to replace SF6 switchgear because it offers the most compact technological switchgear solution. Eurelectric believes that further progress can be achieved in deep leakage detection by focusing efforts on not sealed, relevant emission rate equipment as well as in the management of SF6 switchgear’s end-of-life. In particular, an inventory of the fleet in operation in each Member State should be required in order to gain a clearer picture on the usage of SF6 and provide an adequate overview of the actual situation in real-life applications. To effectively contribute to the reduction of greenhouse gas emissions and to avoid manufacturing of new SF6, obligations to strictly monitor SF6 leakages and to collect SF6 at the end-of-life of a switchgear could be reinforced, calling on specialised industry actors to manage the decommissioning of SF6 –materials and equipment. Such measures will be key to facilitate a successful development and large-scale deployment of alternative solutions supporting DSOs and other industry actors in their mission to safely and reliably distribute power to citizens and communities throughout the Union, while achieving the goal of climate neutrality by 2050.
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Response to Sustainable and Smart Mobility Strategy

29 Jul 2020

Eurelectric welcomes the initiative for adopting a Strategy for a Sustainable and Smart Mobility. The European power sector endorses the proposed targets in the transport sector, as part of the European Green Deal, for advancing towards a green, digital and competitive modern economy. As concluded in Eurelectric’s Decarbonisation Pathways modelling results, electrification will possess an essential role in the transport domain for reaching Europe’s emission reduction objectives. Electrification of transport within an increasingly cleaner electricity mix is the most effective and sustainable way to decarbonise the sector, reduce its dependence on fossil fuel imports outside Europe and decrease air pollution. Being aware of the challenging emissions figures in transport, our industry reiterates the necessity to focus on future-proof investments especially in the context of the current health crisis and related recovery measures. Particularly in road transport, financing has to be fully in line with the commitment to invest in the future in order to achieve a greener, more digital and resilient as well as socially-fair Europe. This would require delivering in several key dimensions: (a) increasing the levels of clean electrification across different vehicle segments, (b) rolling out the supporting infrastructure and (c) ensuring fair competition that guarantees the free choice of consumers in the context of increased digitalisation. Based on the composition of transport-related emissions and the reality of citizens’ mobility patterns, the EU strategy first and foremost needs to address the emissions of individual mobility. Hereby, accelerating the uptake of zero-emission vehicles and the corresponding necessary infrastructure is of utmost importance (i, ii and iii). At the same time, emission standards need to reflect the EU goal to move to zero-emission mobility and significantly decrease transportation’s overall emissions (ii and vi). Such an approach provides clarity of purpose and will give a strong direction for businesses and decision-makers. The objectives of this strategy need to be also analysed from the perspective of integrating renewables. Freedom of choice for customers as well as rules for a level playing field to ensure fair competition for all market players are the main cornerstones that truly facilitate the uptake of electric mobility and the transition to zero-emission transport. Only on this basis can the desired connectivity for citizens, seamless charging all over Europe and innovation in the market be enabled. The initiative must leave space for learning and innovation while encouraging the participation of main European cities administrative bodies. Their understanding of the problems and challenges faced by their own communities is crucial to design solutions as well as it could leverage the share of learnings among cities based on their own experiences so far. This is also quite the relevant aspect for businesses, as successful initiatives implemented by other companies tend to be a very important factor considered in the decision making process of evaluating, for instance, the conversion of ICE fleets to EVs. As identified, the EU strategy needs to center holistically and with the highest priority on reaping the benefits of clean mobility for European citizens. Individual mobility and passenger car road transport is the most important lever for reducing emissions and should therefore be the focal element of the strategy. Turning the transformation of the passenger cars segment into a true European success story will pave the way for decarbonising long-haul, maritime and aviation. Therefore, incentivising the uptake of zero-emission vehicles, advancing the corresponding infrastructure, intelligent linking of transport systems based on digital platforms as well as implementing stringent emission standards that truly reflect the EU ambitions, should be the main pillars of the strategy.
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Meeting with Daniel Mes (Cabinet of Executive Vice-President Frans Timmermans)

16 Jul 2020 · Participation in panel on powering e-mobility

Response to A EU hydrogen strategy

8 Jun 2020

Carbon-free electrification and energy efficiency will make the key contributions to the decarbonisation of transport, buildings and industry. To that end, the electricity industry, represented by Eurelectric, is committed to deliver a carbon-neutral power supply for Europe well before 2050 and is transforming the energy system to make it more and more responsive, resilient and efficient. The power sector has a well-established position on the role of electricity to support the decarbonisation of several sectors in line with the results of its “Decarbonisation pathways” study released in 2018. The study presents three decarbonisation scenarios of the power sector for 2050 based on the electrification of key economic sectors: buildings, transport, and industrial processes. The findings feature high levels of direct electrification that grow from 38% to 60% with an increasing decarbonisation ambition. Moreover, hydrogen and power-to-gas would represent 6% to 14% of the final energy demand depending on the decarbonisation level. Reaching carbon neutrality by 2050 requires drastic changes in the way we generate, transport and consume energy. This ongoing shift is based on the massive deployment of renewable energy sources and the phasing-out of fossil fuels. In this context, the role of gas will profoundly evolve and should be basically determined by market forces. For more detailed information on the overall role of renewables gases, in the context of the energy sector integration, please see attached to this feedback the Eurelectric answers to the EC on smart sector integration. Eurelectric highlights that the coupling of electricity & gas systems, notably through power-to-gas, is a key link in the transition to a carbon-neutral economy, needed to complement direct electrification in "harder to abate" sectors. Given the decarbonisation challenges at hand, Eurelectric is calling the EU to maintain leadership and market-based approach in the development of key emerging technologies coming from electricity and gas sector coupling (such as electrolytic hydrogen), which will be needed to decarbonise specific segments of industrial activity and heavy-duty transport where no electric alternative to fossil fuels exist. The main “sector coupling” product is hydrogen produced via electrolysers (the most advanced and available P2G technology). Different types of hydrogen will have to compete on the basis of costs, which heavily depend on the cost of electricity for electrolysers and the costs of natural gas and CO2 storage for SMR and CCS. This hydrogen can be stored, either as hydrogen molecule or converted into synthetic methane, and provide the necessary flexibility to the energy system or/and be used by sectors that can’t be directly electrified. In a carbon neutral future, the role for hydrogen produced from decarbonised electricity, and more broadly renewable and low-carbon gases, will be determined by their competitiveness (a) vis-à-vis carbon free and renewable electricity in terms of bulk energy supply in sectors where both energy carriers are technically feasible and, (b) vis-à-vis DSR, stationary batteries, hydro pumped storage, interconnections, etc. in terms of the provision of flexibility. The future hydrogen strategy should include the details for a clear regulatory framework and market design for hydrogen. This will provide clarity on the role of hydrogen, the cost to produce it and identify the most efficient way to transport it. Moreover, electrolytic hydrogen and synthetic methane, as well as other type of renewable or decarbonised gases, require clear, relevant and simple definitions, to enable all stakeholders to handle the same tools and to speak a common language. To this goal, a classification of these gases should be established by the European Commission in a clear and consistent manner. The main criteria of this classification should be the emissions of the gaseous products over its whole lifecycle.
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Response to Strategy for smart sector integration

8 Jun 2020

The electricity sector is transforming the energy system to make it more and more responsive, resilient and efficient. The achievement of EU climate targets will require the decarbonisation of all sectors, with direct electrification and the electricity system as the most efficient drivers. Moreover, increasing interactions with energy end-users and other sectors will be key to achieve the common objective of climate-neutrality. The long-term strategy and the European Green Deal are the first steps of a shift from our current highly centralised and mainly fossil fuel-based energy system to a more decentralised, efficient and carbon-neutral energy system. Furthermore, throughout the Covid crisis, the electricity industry continued to provide around-the-clock services, proving its agility and reliability amid restrictive lockdown measures. Our sector is committed to help the EU’s recovery with shovel-ready projects that can reignite the economy, deliver immediate jobs and produce long-term environmental benefits. Electrification, due to its cost competitiveness and high efficiency, will drive the decarbonisation of the economy, as reflected by the various long-term forecasts. In addition, the power sector is committed to provide a carbon-free electricity by 2050. Therefore, the smart sector integration strategy should be built assuming as its first priority the removal of barriers to direct and indirect electrification. To allow for a cost-efficient transition in all sectors while keeping the lights on, such a system-wide shift will see a significant increase of variable generation. This will require firm, dispatchable and flexible carbon-neutral and low-carbon capacity to ensure security of supply. Moreover direct electrification solutions, complemented by indirect electrification ones, will link power and other economy sectors and help to reduce final energy demand and GHG emission as it can deliver equivalent services with less energy input in most cases. In this perspective, the additional direct and indirect electricity demand from transport, heating and industry sectors could help to better match supply and demand when coupled with storage solutions, digitalisation, smart grids, and demand side response strategy. Reaching carbon neutrality by 2050 requires drastic changes in the way we generate, transport and consume energy. This ongoing shift is based on the massive deployment of renewable energy sources and the phasing-out of fossil fuels. Eurelectric highlights that the coupling of electricity & gas systems, notably through power-to-gas, is a key link in the transition to a carbon-neutral economy, needed to complement direct electrification in "harder to abate" sectors. Moreover, different flexibility solutions (Power-to-X, demand-side response including V2G, thermal firm power generation capacity) will compete on a level-playing field. To this end, Europe needs to maintain leadership and market-based approach in the development of key emerging technologies coming from the energy system. This can be done by developing market-based economic signals for all the services provided outside natural monopolies by market parties in competition. Strong grids will be essential to support the integration of decarbonised and renewable energy carriers in all sectors of the economy, whether they are related to power, gas or heat. In addition to the development of a proper investment framework, we call to identify best links between sectors through coordinated, cost-effective and future-proof infrastructure planning tools. In a more decarbonised, decentralised and digitalised energy system, closer cooperation is required among all stakeholders (especially TSOs and DSOs) to anticipate possible evolutions of the electricity, heat and gas networks, supply & demand. For more details of Eurelectric views on successful smart sector integration, please find enclosed to this feedback our answers to the questions asked by the EC.
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Response to Commission Communication – "Renovation wave" initiative for the building sector

7 Jun 2020

The Renovation Wave (RW) initiative is a unique opportunity to tackle climate change while delivering concrete benefits to European citizens. It can create high quality jobs, improve comfort and system efficiency, and support low-income households that are the most in need of energy efficiency (EE) upgrades. Investments in EE stimulate the economy, especially the construction and renewable energy industries, generating about 9% of Europe’s GDP and directly accounting for 18 million direct jobs (European Commission). This is crucial in a context of economic recovery. Prioritize electrification of heating and cooling (H&C) in buildings at individual and district levels The RW should prioritize direct electrification of H&C in buildings, at individual building or at district level, as part of an urgent transition away from inefficient fossil-based heating solutions towards full decarbonisation by 2050. Heat pumps constitute market-ready solutions that can be deployed and which can produce up to 4 units of heat for each unit of electricity consumed. Even higher benefits can be achieved in combination with solar panels, batteries and integrated energy management systems, in well insulated buildings. While the decarbonisation will not happen at the same speed in all EU Members States (MS) due to their diverging starting points and heat markets, the RW should set the path for all EU MS. In suitable areas, the RW should adopt a holistic approach that promotes the connection to networks of high-efficient and decarbonized district heating and cooling, coupled with the installation of the necessary devices for its use. Strengthen the integration between buildings and transport The sectorial integration between buildings and transport should be enhanced through the deployment of future-proof smart charging infrastructure in residential and commercial real estate, existing or newly-built. To truly tap on the potential of integrating electric vehicles (EVs) and buildings, the RW should go beyond the minimum requirements of the Energy Performance of Buildings Directive (EPBD). The RW should promote charging infrastructure which is able to interact with the grid (i.e. smart charging infrastructure), a requirement which is not foreseen by the EPBD. Moreover, the EPBD includes rules for charging points for new buildings only, while the RW should extend the requirements to existing buildings as well. The projects are there and ready to link the Green Deal with the EU recovery, with the added value of helping both the construction and automobile sector. They only need to be implemented at large scale. Tackle the non-economic barriers to energy efficiency The RW should carefully examine the non-economic barriers that actors face when carrying EE measures. These barriers should be acknowledged and tackled thanks to new solutions, with the support of all involved stakeholders, especially the design of appropriate funding products, of tools like minimum performance certificates (uniform within the EU), and the aggregation of actions via energy suppliers and service companies. Moreover, as underlined in the EU Strategy on Smart Sector Integration, the right adjustments to the Primary Energy Factor (PEF) are needed in order to unleash the electrification potential of EU building stock. Other challenges include the landlord/tenant dilemma (landlords do not have the right incentives to do the works because the tenant is most likely to pay the energy bill), carrying out EE measures in multifamily buildings, or the lack of availability of trained installers with the right set of skills. Already implemented tools, like EEOs, need to be carefully designed and implemented. Around 20% of households in the EU are supplied at regulated prices, which are administratively set at a low level. In these cases, if EEOS are applied, effective financial mechanisms must be in place to enable regulated suppliers to meet their EE obligations.
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Response to Revision of the guidelines for trans-European Energy infrastructure

7 Jun 2020

Eurelectric welcomes the publication of the evaluation roadmap and inception impact assessment. A revision of the TEN-E regulation is necessary, going hand in hand with a broader access to EU funding (such as the CEF) as well as new investments, being fully in line with strengthened sustainability criteria. We would like to invite the Commission to read the enclosed paper and consider the following points: 1. Context The impact assessment roadmap and analysis of the challenges point towards the right direction. Eurelectric highly appreciates the outlined facts • The TEN-E is not fit for purpose to drive decarbonisation and to contribute to reach the energy targets • There is a gap as regards a cross-sectoral approach towards network planning • The increasing role of distribution grids has to be recognised • More attention should be paid to expansion offshore grids, for instance in the North and in the Baltic Sea • The interoperability of regional networks has to be ensured, taking into account islands • The PCI process has to be simplified • Current investment levels are not sufficient to decarbonize the energy system. At power grids level, investments need at least to double from 30 bn /year in 2018 to at least 60 bn/year during the next decade 2. Objectives and Policy Options • A key focus should be on projects fostering electrification and direct use of electricity supplied from renewable and low carbon sources, i.e. on the key means of decarbonisation. The transition of the entire energy system will rely notably on the wide-spread use of decarbonised electricity, mainly driven by direct electrification • A successful sector integration should prioritise the decarbonisation of other sectors via electrification, shall support the development of e-mobility and the electrification of heating & cooling Eurelectric agrees with the majority of the issues addressed in the impact assessment (IA). We would like to add the following points: • Infrastructure categories: o The IA should investigate a possible introduction of a specific PCI category for market-based tools, i.e. non-network related PCI flexibility & storage o The smart grid category should envision less restrictive criteria (remove TSO participation, cumulative criteria, include low and medium voltage, decrease the amount of users and consumption) and include new ones related to the penetration of decarbonized transport and heating o Priority corridors should include cybersecurity, resilience, EV charging networks, electrification of heating, flexibility approaches, digital technologies deployment • Selection criteria: An assessment of flexibility options should be investigated as an alternative to system expansion to facilitate the most cost efficient solution • Eligibility and criteria for CEF: Sustainability indicator needs to be included in the CBA for all infrastructures projects receiving EU’s financial assistance for works and studies • Selection procedure for PCIs: A methodology could be introduced to determine whether it would be beneficial to invest in new network infrastructure or flexibility options within a geographical zone. This should be reflected into the CBA and TYNDP • New definition of cross-border criteria is needed and could be based on the replicability potential, synergies expected for more than one member state without necessarily involving a common border • Potential synergies with other planning instruments such as TEN-T should be reflected • The most frequent reasons for delays, such as the duration of permit granting, should be a key focus in the evaluation 3. Preliminary Assessment Non-grid-project promoters have been forgotten in the section “likely economic impacts”. The project promoters are utilities (mainly for storage PCIs) that are competing on the free market. See also our position on Smart Sector Integration https://cdn.eurelectric.org/media/4478/m_an_eu_strategy_for_smart_sector_integration-2020-030-0372-01-e-h-D7BF8E9D.pdf
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Response to Union renewable Financing mechanism

3 Jun 2020

You will find enclosed Eurelectric's input on the EU's renewable financing mechanism
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Meeting with Virginijus Sinkevičius (Commissioner) and

20 May 2020 · To discuss the European Green Deal, and in particular the offshore wind strategy, in light of the climate objectives and the biodiversity strategy; hydropower and the Water Framework Directive.

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

13 May 2020 · Phone call to present Eurelectric proposals on COVID-19 crisis and its implications on the power sector.

Response to Key elements of the methodology reflecting environmental, social or governance (‘ESG’) factors

6 May 2020

Sustainable finance (SF) is a key building block of a European decarbonisation roadmap. To be an integrated part of this strategy, consistency with the EU acquis (i.e. CEP when it comes to the energy sector) and the EU long-term decarbonisation objectives should be ensured. The EU electricity industry is striving to achieve carbon-neutral electricity by 2045 and serve as a solution-maker towards the achievement of the EU climate objectives. A regulatory framework for SF should catalyse investments in long-term innovation and enable rapid deployment of the best available solution for the decarbonisation, electrification and digitalisation of the economy. Therefore, financial benchmarks reflecting environmental, social & governance (ESG) factors are strategic to directing financial and capital flows to green investments, by reflecting the contributions of single technologies to the climate target (providers of flexibility, integration of other RES, climate adaptation and mitigation, etc.). Indeed, according to our Decarbonisation Pathways study, a significant ramp-up of investments is required to reach 80-95% EU economy decarbonisation before 2050. Around 100 EUR bn average investment will be needed per year from 2020 to 2045. In this context, Eurelectric supports the EC draft delegated regulation on financial benchmarking and the objective to streamlining the framework of sustainable benchmarks. Indeed, many companies are currently facing an increasing number of green benchmarks based on different data and standards. The multiplication of available benchmarks and their substantial differences in the methodology and considered criteria make the comparability of ESG standards very difficult. It also conveys a challenging situation when it comes to managing these benchmarks. Thus, streamlining the framework on sustainable benchmarks and disclosure would contribute to aligning, to the extent possible, the existing market practices and indicators. Considering the above, the delegated regulation on financial benchmarking should take into account the following elements: - Consistency within the existing financial framework and reuse of data. The EC draft delegated relation on financial benchmarking should consider the ongoing revision of the Non-Financial Reporting Directive (NFRD) to ensure consistency in the definition of a regulatory framework for SF. Disclosure requirements under the delegated regulation on financial benchmarking should reflect the information requirements under the NFRD to ensure the reuse of data. In this regard, information becoming mandatory or de facto recommended data according to the NFRD should also be the basis for sustainable benchmarks, which would allow companies to provide the same information to fulfill the requirements of the NFRD and the financial benchmarking. - Only disclosure of generic ESG information should be mandatory. Considering that the objective of the delegated regulation on financial benchmarking is to simplify the terminology used, improve the level of comparability among benchmark and provide clarity for investors, Eurelectric strongly recommends considering the disclosure of generic information instead of sector-specific information. Indeed, sector-specific data would not be relevant and appropriate for all macro-sectors. In contrast, generic data would cover all types of corporates and sectors, while fulfilling the objective to improve meaningful comparisons between sustainable benchmarks. - Unnecessary administrative burden should be avoided. The administrative costs of financial and non-financial reporting obligations of companies should not increase. In particular, ESG disclosures requirements in the benchmark statement should not add significant additional administrative costs on companies. Indeed, comparability the ESG indicators financial benchmarks should minimize the costs for all (the corporate and the investors), instead of increasing it.
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Response to Revision of Alternative Fuels Infrastructure Directive

23 Apr 2020

Eurelectric agrees with the identified problems in this Inception Impact Assessment (IIA) and generally supports the objectives, direction and policy options put forward by the Commission. Electrification of transport within an increasingly cleaner electricity mix is the most effective, efficient and sustainable way to decarbonise the sector, reduce its dependence on fossil fuels imports from outside Europe and eliminate air pollution. This requires an improved strategy for the deployment of charging infrastructure for electric vehicles as quickly as possible, calling for the urgent revision of the Alternative Fuels Infrastructure Directive also in line with the review of the TEN-T Guidelines Regulation. The most relevant priority for the European electricity sector, especially in the context of the Green Deal and EU climate-neutrality ambitions, is the definition of “sustainable fuel” which should have a clear focus on electricity for passenger cars. Currently, there is only one definition for when infrastructure is considered clean (or ‘alternative’), referring to passenger cars, trucks and maritime sector all together. Since such approach does not fully support decarbonisation in the transport sector, Eurelectric proposes having separate definitions. When it comes to passenger cars in particular, three separate pieces of EU legislation consider zero- and low-emission vehicles to be those having CO2 emission levels lower than 50g/km. Additionally, recent European Commission decisions on state aid further defended that measures incentivising EV charging infrastructure contribute to the Green Deal goals, and at the same time outweigh any potential distortion of competition they could lead to. In this sense, we ask the Commission to show greater assertiveness in policy making, in addition to these ad-hoc decisions. Other priorities are as follows: a) revising the criteria for charging infrastructure so that the coverage is sufficient and it exists where it is most needed, also via TEN-T networks; b) seamless charging and EU-wide interoperability that can be achieved through a single market approach at the lowest cost for drivers; c) ensuring integration of renewables, especially in the Member States where power generation is of higher CO2 intensity. In particular, this integration goes hand in hand with the acceleration of smart charging and advanced services, which can transform a vehicle into a resource of system flexibility and optimise the charging process for drivers and network operators. Eurelectric and its members will continue their active engagement towards the EU institutions and national authorities in order to ensure the proper functionality of electric vehicle charging infrastructure. The European power sector is also actively communicating expertise and elaborating ideas with other stakeholders along the value chain.
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Response to EU rules on industrial emissions - revision

21 Apr 2020

You will find enclosed Eurelectric's comments to the Inception Impact Assessment for the Industrial Emissions Directive.
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Response to Climate change mitigation and adaptation taxonomy

20 Apr 2020

Scope and governance of the delegated acts (DAs) In its upcoming work to develop the Taxonomy Regulation implementing rules, we call on the EC to ensure that technical screening criteria (TSC) give a realistic picture to private investors about activities that will enable cost-efficient GHG emissions reduction. While remaining technology-neutral, the taxonomy should drive investments into carbon-neutral and low-carbon energy sources. The DAs for climate change mitigation and adaptation objectives should take into account the following elements: - Go beyond the technology-specific TSC and recognise the necessity of a system approach, as well as the contribution of transitional activities (Art. 6.1a). The possibility to evaluate technologies based on their ability to support a system with high shares of variable RES and therefore contribute to SoS should be included, and a brown-listing approach avoided. - The adoption/update of the DAs should be reality-proofed, aligned with existing EU legislation (e.g. CEP) and dynamic to allow for upcoming technologies that can become mature in the short and medium term to be assessed and, if considered as sustainable, added to the list of taxonomy accredited activities. - The SF Platform, composed by a broad and inclusive representation of experts, must ensure the consistency between the taxonomy, EU’s objectives and rules and available evidence based science (for more detail, see the letter attached). Content of the TSC for energy As mentioned by the inception impact assessment, the EC work will benefit from the recommendations delivered by the TEG in its final report last March. The TEG report recognises the decisive role that electrification will play to decarbonise the economy, supported by reliable electricity infrastructure and equipment. The attached Eurelectric paper ‘Moving forward with the EU Taxonomy’ provides detailed comments on the parts of the report on the production of electricity and related activities: - The metric proposed by the TEG for the life cycle assessment (LCA) of electricity production activities is a step forward but is not coherently applicable yet. It should be complemented with other relevant ISO standards (depending on the technology in question) and use existing international standards. - A clear signal is given to drive investments into RES technologies. The proposed LCA should be uniformly applied in form of technology-specific standard values for the upstream LCA instead of project-specific individual measurements to avoid unnecessary administrative burden. On the basis of those technology-specific LCA standard values, technologies that have sufficient evidence of being far below or far above the threshold of the EPS of 100g CO2/kWh should be exempted from the LCA. - A level playing field has to be guaranteed for all storage technologies, i.e. all electricity storage technologies should be automatically eligible under the EU Taxonomy. This should also be the case for pumped storage, which is currently the only storage technology of the TEG report that has to fulfil specific requirements. - Additional expertise is needed regarding nuclear to guide the adoption of DAs by the end of 2020. We call on the EC to swiftly appoint an expert group of scientifically qualified radiation protection specialists to finalise the assessment of nuclear energy under the Taxonomy. Any delay in the nuclear assessment risks undermining the ability of the Member States to develop a pathway towards climate neutrality. - TEG’s views on the transmission and distribution of electricity are reflecting the evolution of the power grid. We support the view to include all electricity T&D infrastructure or equipment in systems, which are on a trajectory to full decarbonisation, without any burdensome and unnecessary reporting. However, additional work is needed on the second criterion of average system grid emissions factor.
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Response to 2030 Climate Target Plan

15 Apr 2020

You will find enclosed the input from Eurelectric to this consultation.
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Meeting with Frans Timmermans (Executive Vice-President) and ELECTRICITE DE FRANCE and

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

Meeting with Kadri Simson (Commissioner) and

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

Response to Carbon Border Adjustment Mechanism

1 Apr 2020

Eurelectric represents the European power sector. The association has historically advocated for a robust carbon pricing to deliver substantial GHG emissions reduction across Europe. In the context of greater climate ambitions in the European Green Deal, Eurelectric welcomes the ongoing work of the European Commission and support its investigation for a carbon border adjustment. This debate is essential in the context of preserving both the environmental integrity of EU climate policies as well as the competitiveness of European industry. Preventing carbon leakage and its impacts The power sector already observes problems of carbon leakage. Data available show that 21 TWh of coal-based electricity has been imported to the EU in 2019. Countries along the EU external borders are the most affected by imports of electricity with high carbon content, mainly the Baltic States, Bulgaria, Croatia, Finland, Greece, Poland and Spain. In the context of greater climate ambitions, The European industry exposed to international competition could be negatively impacted. Additionally, social and employment impacts resulting from this distortion should be further assessed. The European industry must be able to compete in a level playing field in order to fully endorse decarbonisation efforts. A carbon border adjustment primary goal is to prevent environmental harm. Addressing carbon leakage would first allow European industry to implement low carbon solutions without regret. A carbon border adjustment would also induce greater mitigation efforts by indirectly incentivizing investments in carbon clean products in third countries and allowing the spread of meaningful carbon pricing. The design of a carbon border adjustment requires careful considerations There are several options for implementing a carbon border adjustment and these are not mutually exclusive. However, any type of mechanism must avoid opposition in principle from third countries and strictly respect international trade rules. Carbon border adjustment mechanisms are legally compatible with GATT and WTO rules, provided they are designed in a right way. The criteria to ensure compliance with the EU’s international commitments should be evaluated. Precedent WTO cases show that a carbon border adjustment need to be implemented in a transparent way and respect the key principles of fairness, proportionality and non-discrimination. Therefore, the European Commission should carefully assess the scope and coverage of a carbon border adjustment and ensure that the most exposed sectors are subject to this measure. A mechanism in the power sector would be easy to design because tracing carbon emissions is relatively straightforward. Different design and benchmarking methods could be needed in other energy-intensive sectors in order to limit the administrative burden of a carbon border adjustment. A careful design of this policy instrument is key to maximize positive effects and tailored methods are essential for success. Ultimately, the ideal outcome to prevent carbon leakage lies in a greater international cooperation and a more global carbon pricing. Eurelectric supports the European Commission for engaging the international community with ambitious carbon pricing policy frameworks. Additionally, Eurelectric has evaluated ways to implement carbon border adjustment with the help of its climate experts and would be happy to discuss it further.
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Response to Fast-track interservice consultation on the 'SEIP including a JTM and the JTF"

10 Mar 2020

Please see Eurelectric's position paper on the Just Transition Fund Regulation in attachment.
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Meeting with Stefano Grassi (Cabinet of Commissioner Kadri Simson), Thor-Sten Vertmann (Cabinet of Commissioner Kadri Simson)

18 Feb 2020 · Introductory meeting - electrification in the energy transition - Commissioner’s possible participation in Eurelectric’s events

Meeting with Kadri Simson (Commissioner) and

27 Jan 2020 · Decentralized energy systems, establishment of EU DSO entity

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

21 Jan 2020 · European Green Deal

Meeting with Ditte Juul-Joergensen (Director-General Energy) and EPIA SolarPower Europe and

6 Nov 2019 · Keynote speech : powering the European Green Deal

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

11 Jul 2019

The Union of the Electricity Industry - Eurelectric is the sector association which represents the common interests of the electricity industry at pan-European level, plus its affiliates and associates on several other continents. We currently have over 35 full members, representing the electricity industry in 32 European countries. We highly welcome the upcoming Evaluation of the guidelines for Trans-European Energy (TEN-E) infrastructure as we believe that TEN-E networks should support clean power generation and transition-enabling solutions, to reduce emissions and help become carbon-neutral well before mid-century. In this context, TEN-E networks should reflect not only the energy transmission but also the distribution landscape of tomorrow, including smart grids, storage, EVs, demand side management and sector coupling. Therefore, we would like to call on the Commission to consider more main stakeholder groups as already mentioned in section B of the roadmap, i.e. at least to include electric utilities - engaging in generation or in distribution of electricity - as key stakeholders. We and our members are looking forward to engaging in further discussions and to contributing to all consultations during the Evaluation of the guidelines for Trans-European Energy (TEN-E), offering our insights and expertise.
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Meeting with Mauro Raffaele Petriccione (Director-General Climate Action)

27 Feb 2019 · EU long term strategy and EC priorities 2020-2024

Response to Commission Delegated Regulation establishing the Innovation Fund

11 Jan 2019

Eurelectric welcomes the opportunity to respond to Consultation on the European Commission Delegated Regulation establishing the Innovation Fund. We believe that the Innovation Fund has an important role to play in successful delivery of the EU ETS objectives. With this in mind and having participated in stakeholder roundtables and expert group meetings on the Innovation Fund in the past, we provide the following set of views in the attached Eurelectric consultation response paper with trust that they can be useful for improving the draft delegated act further.
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Meeting with Frans Timmermans (First Vice-President)

27 Nov 2018 · Eurelectric presented the results of a study on decarbonisation

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

24 Jul 2018 · Eurelectric’s contribution to the EU Long Term Strategy

Response to Institutional investors' and asset managers' duties regarding sustainability

21 Jun 2018

Climate change should be the first priority when addressing long term sustainable development issues; therefore it is required for the financial sector to adopt a carbon neutral approach to achieve sustainable finance. Eurelectric welcome the Commission proposal that challenges the EU financial regulation with sustainable goals. 1. Investment entities should contribute to the goals of the Paris Agreement in the transition to a low carbon economy and thus consider sustainability factors defined by the United Nations Environment Programme (UNEP) but also (i) be consistent with EU issues and (ii) be relevant for the energy sector in the decision making process. 2. Regarding the policy options proposed by the European Commission, the relevant areas for investment entities to account for the sustainability factors are: investment strategy, asset allocation, risk management and governance with a periodic reporting to the Board. Moreover, investment entities should disclose how they consider sustainability factors within their investment decision-making process. Moreover, due to the urgency for climate change mitigation, MiFID end customers must be informed of this specific topic. 3. Financial products, listed or not, which (i) are used in order to hedge long-term industrial and societal risk or (ii) are linked to long-term low carbon infrastructures, should be considered as "sustainable products" for future generations. 4. Regulatory stability and preventing retroactive regulatory changes- Capital cost is intimately attached to the perceived investment risk. A sustainable electricity sector demands investors willing to commit to long-term investments. One decisive manner to reduce the perceived risk of long-term investment commitments is to ensure regulatory stability and to prevent retroactive regulatory changes. The European Commission should have decisive initiatives with this regard.
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Meeting with Joachim Balke (Cabinet of Vice-President Miguel Arias Cañete), Maria Cristina Lobillo Borrero (Cabinet of Vice-President Miguel Arias Cañete) and

19 Jun 2018 · Clean energy package and role of DSOs

Meeting with Tomas Nejdl (Cabinet of Commissioner Corina Crețu)

18 Jun 2018 · MFF post-2020

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

7 May 2018 · MFF post 2020

Meeting with Tomas Nejdl (Cabinet of Commissioner Corina Crețu)

25 Apr 2018 · MFF post-2020

Meeting with Elina Melngaile (Cabinet of Vice-President Valdis Dombrovskis)

9 Apr 2018 · Sustainable Finance, Sustainable Finance Expert Group

Meeting with Dominique Ristori (Director-General Energy)

28 Feb 2018 · European electricity sector

Response to Review of the European Supervisory Authorities

22 Jan 2018

• EURELECTRIC welcomes the possibility to provide feedback on the initiative to improve the European supervisory authorities (ESAs) on the international framework for the stability of the international financial markets. • EURELECTRIC understands the need for a supervisory authority at European level to be able to have an overview of European financial markets in all asset classes; while having a view at the international level and towards supervisory authorities in third countries. • Regarding the European securities markets authority (ESMA): o Governance: EURELECTRIC takes note of the creation of the Executive board with full-time members dedicated to a day-to-day decision process besides the Board of supervisors. However, EURELECTRIC would like to underline the need for Member States to also be involved in the governing structure. o Consultation process: EURELECTRIC sees the need for an improved involvement of stakeholders. This should be done through consultations as well as stakeholder workshops. We do not think that the set-up of consultative working groups (WGs) is sufficient for market participants to be adequately represented. In this context, there is an outspoken need for consultation in the Q&A process and in the preparation of guidelines. o Expertise: EURELECTRIC thinks that the organisation of meetings on a regular and informal basis besides the formal consultation process is beneficial. This will allow professional associations to ensure that updated expertise in all asset classes, including in commodities and emission allowances, is made available for an efficient supervision at European level. o Coordination with national supervisors: a right balance between centralised supervision at European level and relevant powers being given to the national level should be ensured, particularly on cross-border issues. o Data collection: should data be submitted directly to ESMA, it must be ensured that no additional reporting for market participants will be required. Instead, other regulatory authorities possibly needing additional data should have access to this data set and collect it from there. o Sustainability factors: market participants should be involved in the process to define the way ESMA has to take into account the environmental social governance (ESG) factors in the implementation of new regulations. Amendments proposed: EURELECTRIC has a positive view on the amendments proposed to Regulation (EU) 600/2014 (MIFIR – data reporting service providers). Replacing this article by Article 6 paragraph 28 of the ESA proposal would: - add the authorisation and supervision of data reporting service providers to the scope of Regulation (EU) No 600/2014 (MiFIR) together with direct data gathering powers for the purposes of reporting and transparency calculations; - add the three different types of data reporting service providers to the definitions in MiFIR; - empower ESMA to request information it requires for its supervisory tasks; - establish ESMA as the supervisor of data reporting service providers; - define the powers and competences ESMA should have in exercising its role as competent authority; - impose reporting requirements for the Commission on the functioning of the consolidated tape; - specify the transfer of competences from national competent authorities to ESMA. Granting those competences to ESMA would allow for a centrally managed authorisation and oversight of data. This would avoid the current situation where multiple trading venues are required to provide various competent authorities with data which are only then provided to ESMA. Such a centrally managed system should be highly beneficial to the market participants in terms of higher data transparency and market efficiency.
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Meeting with Helena Braun (Cabinet of First Vice-President Frans Timmermans)

30 Nov 2017 · Discussion on the Sustainable Development Goals

Meeting with Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen) and ENEL SpA and Finnish Energy - Energiateollisuus ry

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

Meeting with Friedrich-Nikolaus von Peter (Cabinet of Commissioner Violeta Bulc)

25 Sept 2017 · Meeting to discuss CO2 emission standards for cars and vans as well as the reform of the Clean Vehicles Directive

Meeting with Silvia Bartolini (Cabinet of Vice-President Miguel Arias Cañete)

25 Sept 2017 · Mobility Package

Meeting with Friedrich-Nikolaus von Peter (Cabinet of Commissioner Violeta Bulc)

11 Sept 2017 · Meeting with Kristian Ruby

Response to EMIR Amendment

18 Jul 2017

EURELECTRIC generally welcomes the EU Commission’s proposal for a Regulation amending EU Regulation 648/2012 (EMIR) as far as it stipulates a simplified and improved framework to meet the objectives in a more proportionate, effective and efficient manner. In the attached document, we outline our view on the most relevant issues.
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Meeting with Tomasz Husak (Cabinet of Commissioner Elżbieta Bieńkowska)

26 Apr 2017 · ETS revision

Meeting with Maroš Šefčovič (Vice-President) and

29 Mar 2017 · Clean Energy package and Electrification agenda

Meeting with Jos Delbeke (Director-General Climate Action)

13 Mar 2017 · EU ETS review

Meeting with Dominique Ristori (Director-General Energy)

9 Feb 2017 · energy policy

Meeting with Miguel Arias Cañete (Commissioner)

31 Jan 2017 · Market designe

Meeting with Dominique Ristori (Director-General Energy)

10 Jan 2017 · presentation of the Clean Energy for All Europeans package

Response to Commission Regulation establishing a guideline on electricity balancing

2 Jan 2017

The Electricity Balancing Guideline (EB GL) is an essential component of the integration of the European electricity markets. As the final stage in the electricity system, its design has important repercussions for the market functioning in the previous timeframes, providing signals and incentives. EURELECTRIC would like to welcome provisions that should be safeguarded as they are essential to a good balancing market and draw the attention to other parts that would be detrimental to that market. The most important elements are the following: • ID markets are and should remain the main tool for market participants to rebalance their positions close to real time. Therefore, we regret that the XB BAL GOT is no longer linked with the XB ID GCT. Without this link, it is possible that the balancing market closes before the ID market. This would force market parties to choose between both markets, potentially reducing the liquidity in the intraday market. • On the development of the future European exchange platform, we would welcome clarity on how the ambitious implementation timing (2 or 4 years after entry into force, depending on the products) can be combined with sufficient alignment in the balancing markets, in order to ensure that market parties face a level playing field on these platforms. This will require an ambitious approach – both from TSOs as from market participants – to implement the necessary systems as well as strong governance from NRAs to ensure sufficient alignment in market framework. • We want to stress that the standardisation of balancing products is the key for allowing cross-border exchanges. While we welcome the limited number of standard products proposed and the stakeholder involvement, we regret to see that this is process taking more time than previously expected. It is key that standard products are defined soon enough for all stakeholders to be able to be ready for the go-lives of the platforms. This point has also to be considered when setting the dates for theses platforms. • For us, it is key to ensure that the imbalance settlement price correctly reflects the real-time value of the energy by removing price caps, avoiding artificial components such as administrative scarcity pricing, or/and administrative interventions. The ambition of the EB GL that the imbalance settlement price reflects the real-time value of the energy is welcomed, as well as the abolishment of price caps and floors lower than the VoLL for balancing energy and spot markets. • If any XB capacity reservation for exchanging balancing capacity is deemed required, the mechanism should be open to participation of market participants, since they are best incentivized to find the optimal allocation between the different time-horizons, including the ID timeframe. The current approach allows TSOs to reserve XB capacity based on either a complex methodology (co-optimisation) or artificial price signals. We consider that this could compromise the optimal allocation over the different time-horizons. It also excludes the ID timeframe from the allocation, where market participants should be given more opportunities to balance their portfolio before being exposed to imbalances. • We consider that the priority is to deliver platforms in time for exchanging products on a level playing field. Clever solutions have to be put in place to cope with (i) the different ways to manage the system in different places (ii) the need for an efficient European balancing market. • On the timing for ISP harmonisation implementation, we will provide our views as part of the input to the Clean Energy Package. • The Swiss electricity network is an important part of the highly meshed interconnected grid of continental Europe; thus its consideration is essential in maintaining system security and system efficiency. More detailed comments and proposals for amendments were sent to the European Commission directly
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Meeting with Joachim Balke (Cabinet of Vice-President Miguel Arias Cañete)

17 Nov 2016 · Retail markets

Meeting with Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen)

9 Nov 2016 · EFSI in energy

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

30 Jun 2016 · Market design package

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

20 Apr 2016 · Market design and renewables

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

20 Apr 2016 · Market Design

Meeting with Dominique Ristori (Director-General Energy)

13 Apr 2016 · Energy markets

Meeting with Miguel Arias Cañete (Commissioner)

17 Mar 2016 · Electricity market design

Meeting with Miguel Arias Cañete (Commissioner) and BUSINESSEUROPE and

18 Feb 2016 · Market design

Meeting with Jos Delbeke (Director-General Climate Action)

7 Jan 2016 · follow up to Paris agreement

Meeting with Miguel Arias Cañete (Commissioner)

25 Nov 2015 · Market design and COP21

Meeting with Lee Foulger (Cabinet of Vice-President Valdis Dombrovskis) and Bundesverband der Deutschen Industrie e.V. and

12 Nov 2015 · Joint mtg energy assoc/Markets in Financial Instruments Directive II

Meeting with Věra Jourová (Commissioner) and

21 Oct 2015 · Energy union

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

10 Sept 2015 · Energy Union

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

21 May 2015 · Energy Union Governance

Meeting with Jos Delbeke (Director-General Climate Action)

7 May 2015 · ETS

Meeting with Frans Timmermans (First Vice-President) and

30 Apr 2015 · Energy Union

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

30 Apr 2015 · Meeting to present EURELECTRIC positions on energy issues

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

29 Apr 2015 · Energy Union governance

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

1 Apr 2015 · Eurolectric Market Design

Meeting with Friedrich-Nikolaus von Peter (Cabinet of Commissioner Violeta Bulc)

25 Mar 2015 · von Peter meeting Eurelectric representatives

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

4 Mar 2015 · Energy Union and Climate Action

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

4 Mar 2015 · Intro meeting

Meeting with Karl-Friedrich Falkenberg (Director-General Environment)

3 Feb 2015 · Large Combustion Plants BREF

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

29 Jan 2015 · 2030 policy framework, ETS and the MSR reform, energy efficiency

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

29 Jan 2015 · EMISSIONS TRADING - MARKET STABILITY RESERVE AND ETS REFORM, ENERGY EFFICIENCY, LARGE COMUBSTION PLANTS

Meeting with Maroš Šefčovič (Vice-President)

29 Jan 2015 · Energy Union

Meeting with Simona Constantin (Cabinet of Commissioner Věra Jourová)

26 Jan 2015 · European energy market, Consumer protection aspects

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

10 Dec 2014 · Retail Markets

Meeting with Dominique Ristori (Director-General Energy)

3 Dec 2014 · Market design