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European Geothermal Energy Council

EGEC

EGEC promotes geothermal energy use across Europe through its network of companies, research centers, and public authorities.

Lobbying Activity

European geothermal council demands removal of emission thresholds

5 Dec 2025
Topic — This consultation reviews the technical screening criteria within the EU taxonomy delegated acts.
Message — EGEC recommends deleting both the geothermal emission threshold and the LCA obligations required under the Climate Delegated Act. They call for the establishment of a single, unified Taxonomy category for geothermal heat pumps.12
Why — This would reduce administrative burdens significantly and prevent the LCA requirement from slowing down financial close.34
Impact — Environmental groups lose the environmental insight provided by project-specific assessments which would otherwise be mandatory.5
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Meeting with Jan Farský (Member of the European Parliament) and Baker Hughes Holdings and

26 Nov 2025 · Support to geothermal energy

Meeting with Martin Hojsík (Member of the European Parliament) and ENEL SpA and

26 Nov 2025 · Geothermal energy breakfast

Meeting with Monika Zsigri (Head of Unit Energy)

23 Oct 2025 · Exchange on revision of the energy security framework

Geothermal industry urges inclusion in green public procurement rules

14 Oct 2025
Topic — Setting mandatory environmental sustainability requirements for public procurement of net-zero technologies.
Message — EGEC requests integrating geothermal technologies into procurement regulations for a coherent policy framework. They propose criteria including lifecycle emissions, water management, and circularity for geothermal projects.12
Why — This would ensure fair treatment and boost the sector's competitiveness within European industrial policy.3
Impact — Omitting geothermal energy weakens the sector's market position against other strategic technologies.4
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Response to Electrification Action Plan

9 Oct 2025

We welcome the upcoming European Geothermal Strategy and Action Plan in the context of the Electrification Action Plan and the Heating and Cooling strategy. Geothermal energy provides renewable electricity, heating and cooling, as well as sustainable mineral extraction and the most efficient and least land-intensive energy storage. It is therefore at the heart of the energy transition and system integration. The International `Energy Agency stated that the EU must "Move geothermal up the energy policy agenda by making geothermal energy more prominent in national energy planning; developing dedicated goals and technology roadmaps" (IEA, Future of Geothermal Energy (2024)). It also stated the "technical potential of geothermal would be more than enough to meet all electricity and heat demand in Africa, China, Europe, South East Asia and the United States". We recommend: 1. A dedicated strategy and action plan to reflect the demands of the sector and ensure effective system integration. 2. A Geothermal Mandate and Geothermal Industrial Alliance focused on delivering meaningful action across Europe. 3. EU targets, finance and coordination to facilitate implementation and mainstreaming. 4. Sectoral agreements to drive investments in key sectors and ensure Europe is competitive, secure and supplied with affordable energy. The recommendations for both calls for evidence as well as the Geothermal Strategy and Action Plan are outlined in the attachment below.
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Geothermal industry urges more flexible EU state aid rules

3 Oct 2025
Topic — The Commission is revising rules exempting specific state aid categories from prior approval requirements.
Message — EGEC recommends the definition of 'new economic activity' reflect substance over statistical codes. They argue current rigid codes exclude projects that reorient capacity towards climate neutrality.12
Why — This would ensure geothermal projects are unambiguously eligible for state support during industrial transitions.3
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Meeting with Martin Hojsík (Member of the European Parliament)

10 Sept 2025 · Geothermal energy

Meeting with Anne Katherina Weidenbach (Cabinet of Commissioner Dan Jørgensen), Stella Kaltsouni (Cabinet of Commissioner Dan Jørgensen)

1 Sept 2025 · Clean Energy Investment Strategy

Geothermal council urges grid rewards and streamlined permitting

4 Aug 2025
Topic — The EU Grids Package aims to upgrade and digitize energy infrastructure.
Message — The council recommends that grid connections for geothermal power be integrated into a single permitting process. They also advocate for conditionality rules that favor high-efficiency appliances to reduce network congestion.12
Why — Streamlined regulations and new financial incentives would lower system costs and accelerate geothermal deployment.3
Impact — Manufacturers of inefficient heating systems lose out as regulations shift toward high-performance technologies.4
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Meeting with Kurt Vandenberghe (Director-General Climate Action)

23 Jul 2025 · to discuss the role of geothermal in decarbonising industry and agriculture

Response to European Affordable Housing Plan

4 Jun 2025

EGEC's response to the Call for Evidence on the European Affordable Housing Plan Communication attached.
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European Geothermal Energy Council demands funding for exploration costs

26 May 2025
Topic — The Commission is evaluating the operating rules of the Modernisation Fund.
Message — The council calls for geothermal energy to be prioritized through clear eligibility rules and dedicated financial support. They specifically request that exploration and drilling costs become eligible for funding to unlock large-scale projects.123
Why — This would significantly reduce high upfront capital risks and ensure long-term revenue stability.45
Impact — Natural gas providers lose out as the group opposes funding for coal-to-gas conversions.6
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Meeting with Beatrice Coda (Head of Unit Research and Innovation)

12 May 2025 · Presentation of the European Technology Innovation Platform on Geothermal Energy and its activities, its vision of the geothermal landscape of the European Geothermal sector.

Meeting with Paula Rey Garcia (Head of Unit Energy)

8 May 2025 · Electrification Action Plan and Heating and Cooling Strategy

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

20 Feb 2025

We welcome the European Commissions efforts to enhance the regulatory framework for net-zero technologies, particularly through the classification of final products and key components. However, we believe that the geothermal sector is underrepresented in the proposed list of main specific components, and further refinement is needed to ensure that geothermal technologies are adequately supported in the same way as wind, solar, hydrogen, and battery storage. Please have a look at the attachment for more information.
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Response to Delegated act on primarily used components under the Net-Zero Industry Act

20 Feb 2025

We welcome the European Commissions efforts to enhance the regulatory framework for net-zero technologies, particularly through the classification of final products and key components. However, we believe that the geothermal sector is underrepresented in the proposed list of primarily used components, and further refinement is needed to ensure that geothermal technologies are adequately supported in the same way as wind, solar, hydrogen, and battery storage. Please have a look at the attachment for more information.
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Meeting with Anne-Maud Orlinski (Cabinet of Commissioner Dan Jørgensen)

6 Feb 2025 · Exchange of views on geothermal energy and upcoming initiatives of the European Commisison

Meeting with Dan Jørgensen (Commissioner) and

30 Jan 2025 · Affordable Energy action Plan

Meeting with Michael Mcnamara (Member of the European Parliament)

16 Jan 2025 · Geothermal Action Plan

Meeting with Michal Wiezik (Member of the European Parliament)

4 Dec 2024 · Geothermal sector

Meeting with Gordan Bosanac (Member of the European Parliament)

14 Oct 2024 · Geothermal energy

Meeting with Hildegard Bentele (Member of the European Parliament)

17 Jul 2024 · Geothermal energy

Meeting with Jens Geier (Member of the European Parliament)

4 Jan 2024 · Exchange on Geothermal Energy

Meeting with Martin Hojsík (Member of the European Parliament)

5 Dec 2023 · Geothermal energy

Meeting with Martin Hojsík (Member of the European Parliament)

13 Oct 2023 · Geothermal energy, INI

Meeting with Morten Petersen (Member of the European Parliament, Shadow rapporteur) and Cleantech for Europe and

12 Oct 2023 · Ongoing Parliamentary work related to Geothermal

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

11 Oct 2023 · Meeting with European Geothermal Energy Council

Meeting with Beatrice Covassi (Member of the European Parliament) and Solar Heat Europe/ESTIF

11 Oct 2023 · Solar heat and geothermal energy

Meeting with Ville Niinistö (Member of the European Parliament, Shadow rapporteur)

22 Sept 2023 · Geothermal INI (staff level)

Meeting with Niels Fuglsang (Member of the European Parliament, Shadow rapporteur)

8 Sept 2023 · Geothermal energy

Response to Review report on the Governance Regulation of the Energy Union and Climate Action

22 Jul 2023

EGEC, the voice of the European geothermal industry, is a not-for-profit association representing the entire value-chain of the industry across 28 countries. It is included on the European Transparency Register number: 11458103335-07 Further information can be found at www.egec.org. Our views on the Governance Regulation are: Outcome focused: National Energy & Climate Plans (NECPs) should go beyond just listing planned policies and focus on addressing bottlenecks for mass deployment of geothermal, other renewables and energy savings. Therefore, the NECP template must be amended so that the measurement of investments is measured against the backcasting of the trajectory required to achieve climate neutrality by 2050. This should be applied to each end-use sector buildings, industry, agriculture and transport. Data on geothermal heat pumps and district heating & cooling systems: At present, there is a lack of granular data on geothermal heat pumps and geothermal district heating and cooling systems. NECPs and the governance regulation must ensure these solutions are fully accounted. Renewable Heating and cooling target (Renewable Energy Directive Article 23): This is now a binding target. Member States will be required to increase the share of their renewable heating and cooling by 1.1 percentage points each year. This should be programmed into the NECP template. Raw materials: The NECP template should be updated to include a measurement of critical raw materials and processes to map regions that have potentials. Hydronic heat pumps: The target to install 30,000 geothermal and air-to-water heat pumps must be included in the NECP template. This must distinguish between both technologies. Storage: The Commissions Recommendations for storage (C(2023) 1729 final) outlines the need for underground and above ground storage. Gap filler mechanism: The community tendering aspect of the Renewable Energy Directive (Article 4) is limited to renewable electricity. The EU Energy Platform is limited to collective purchasing of fossil gas. Therefore, we recommend that the gap filler mechanism is used for the collective purchasing of geothermal heat pump and district heating systems to accelerate energy security and the replacement of imported Russian gas. EU efficiencies: There is a The Commission must identify areas where a coordinated European approach, such as a European mechanism for risk mitigation, effective implementation of renewable go-to areas for permitting and infrastructure funding are required and either propose corrective measures or use the EU Energy Platform to purchase these on behalf of the community.
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Geothermal council demands ambitious binding targets for 2040

23 Jun 2023
Topic — The consultation seeks to establish an EU climate target for 2040.
Message — The council urges the EU to extend binding renewable energy targets to 2040. They propose specific targets for geothermal electricity production, heating, and lithium extraction.123
Why — Binding targets would provide regulatory certainty and attract necessary private investment.45
Impact — Fossil fuel producers face faster replacement in heating, cooling, and electricity.6
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Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski)

30 May 2023 · (Geothermal) Energy investments in RDP

EGEC Urges Priority for Geothermal in EU Heat Pump Plan

26 May 2023
Topic — An EU action plan to accelerate heat pump market growth and deployment.
Message — EGEC requests an EU-wide risk insurance scheme and digital permitting maps to streamline projects. They also seek dedicated funding for district heating and a skilled workforce via certification passports.12
Why — This would lower investment risks and administrative costs for geothermal infrastructure developers.3
Impact — The fossil fuel industry faces higher costs from the removal of tax exemptions.4
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Meeting with Martin Hojsík (Member of the European Parliament)

28 Feb 2023 · Geothermal energy

Response to Communication on revamping the SET Plan

2 Nov 2022

As EGEC, the voice of the European geothermal industry, we welcome the revision of the SET Plan and the focus the European Commission wants to put on stronger synergies between national, industrial and European actors to meet the new objectives of the European Green Deal and REPowerEU. We are convinced that an effective Integrated Strategic Energy Technology Plan is a key tool for the creation and maintenance of a vibrant open innovation ecosystem to face the latest unprecedent energy challenges. For these reasons, we would like to make some observations and recommendations that you can find in the document attached. *** EGEC views on revamping the Strategic Energy Technology (SET) Plan EGEC, the voice of the European geothermal industry, is a not-for-profit association representing the entire value-chain of the industry across 28 countries. It is included on the European Transparency Register number: 11458103335-07 . Further information can be found at www.egec.org. We welcome the revision of the SET Plan and the focus the European Commission wants to put on stronger synergies between national, industrial and European actors to meet the new objectives of the European Green Deal and REPowerEU. We are convinced that an effective Integrated Strategic Energy Technology Plan is a key tool for the creation and maintenance of a vibrant open nnovation ecosystem to face the latest unprecedent energy challenges. For these reasons, we would like to make the following observations and recommendations: 1. Clear alignment to the outcomes of the Fit for 55 and REPowerEU legislative packages: the SET Plan must focus on facilitating the outcomes of the revised legal base and targets. In particular: a. Geothermal target: it must support the target to triple the capacity of geothermal by 2030 as outlined in the EU Solar Energy Strategy (COM(2022) 221 final). b. Heat Pumps: attention must also focus on facilitating the mass deployment of geothermal and other renewable heating technologies, particularly high-efficiency geothermal and ambient heat pumps. The REPowerEU plan called for 10 million hydronic heat pumps by 2026 and 30 million by 2030 (COM(2022) 230 final). This requires prioritisation of technological development, removal of market barriers and effective awareness to ensure adequate planning to deliver detailed plans, based on locally available renewable resources. c. Alignment to the National Energy & Climate Plans (NECPs): the mission of the Implementation Plans (IPs) must be to accelerate delivery of the NECPs. Therefore, they must become politically visible by clear alignment to the targets set by the EU to focus the attention of national governments. This would facilitate targeted engagement from Member States and industry representatives to ensure effective outcomes. 2. New priorities for the Implementation Plans (IPs): beyond the established technological cross-thematic areas, the IPs must address non-technological issues related to policy & regulation and education & training, followed by social awareness, acceptance and engagement. For geothermal, an industrial strategy must be developed, including an oil&gas transition to geothermal. Moreover, the areas of R&I funding programmes, standardisation and socio-economic policies should not be overlooked. 3. Reforms to make the SET Plan operationally effective and efficient: focused and transparent collaboration between the different SET Plan entities is essential. This requires better coordination between stakeholders at national and EU level. The revamped structure of the SET Plan should be simpler, with clear roles and responsibilities for all involved actors (ETIPs, IWG components, NRCGs). In particular: a. Mission orientation: a thematic approach is required to deliver the objectives outlined in Point 1 - tripling the capacity of geothermal by 2030; 10 million heat pumps by 2026 and 30 million by 2030; and delivery of the NECPs. b. Avoid duplication: too many agencies are dealing with the same themes and often there is an overlapping of competencies. This creates redundancy and inefficiencies rather than fruitful collaboration. Therefore we suggest: I. Create a national funding agency for energy research. II. Create networks for geothermal research, innovation, education and training. III. Create conditions to increase awareness about the advantages of the geothermal technology and its potential. IV. Establish a European RES export agency. c. Effective cross-fertilisation of activities: closer and more frequent collaboration between ETIPs is required. This implies the need to address collectively cross-cutting challenges such as the rollout of renewable heating and cooling technologies, associated infrastructure, interaction between national/regional and supranational funds, support schemes and supply-chain development. 4. Increased accessibility to funding and partnership opportunities for renewable heating and cooling: the most effective means of improving the outcomes from the SET Plan requires streamlined access to funding and partnership opportunities to address emerging R&I collaboration needs. Renewable heating and cooling technologies, including thermal storage, must significantly increase in the next years (also in face of the current energy crisis), and the allocated funding should allow for the development of several actions to switch from fossil fuels to geothermal and other renewables. 5. Cross IP relevant product development: some tools, such as financial de-risking products and processes, are required by numerous workstreams and ETIPs and are key to the delivery of the targets outlined in Point 1. Therefore, the SET Plan should include an EU-wide financial de-risking scheme for renewable heating as a priority area for collaboration. The design and standardisation of the Heat Purchase Agreement (HPA) or Heat As A Service (HAAS) is also another area for collaboration as is the design of a geothermal and heat pump accelerator.
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Response to Implementing regulation on the Member States’ reporting of information foreseen in the Governance of the Energy Union

9 Aug 2022

As EU is currently negotiating an upward revision of climate and energy targets, it is ever more important that the reporting demonstrates Member States have sufficiently detailed information to implement the EU’s climate and energy targets. Moreover, granularity and detailed reporting are particularly crucial for the heating and cooling sector, and for geothermal energy technologies which represent an important segment of heating, cooling, power generation and enabling technologies such as sustainable lithium extraction to accelerate achievement of the Fit for 55% and REPowerEU targets. EGEC strongly support the requirement for Member States to report on “other relevant information included in their national plans in the matter of renewable energy and energy efficiency”. A whole system, integrated, cross sector approach to decarbonisation is necessary to attain the EU’s climate and energy targets to 2030. This is particularly relevant to the heating sector which accounts for around half of the EU’s energy consumption, mostly attributable to heating in buildings and for industrial applications e.g. food, chemicals. Furthermore, natural gas remains the predominant source of heating in the EU. Renewable energy and energy efficiency measures provide critical solutions for decarbonising heating. For example, Geothermal energy provides flexible and baseload renewable heating and cooling, and thermal energy storage, and can therefore be used to replace and save natural gas in these predominant sectors. It is therefore essential that Member States report a detailed breakdown of heating and cooling loads and energy consumption per individual sector, for example the agricultural sector, including the share of energy from fossils and renewables, per technology type. Member States should report cost of installation, operation and MWth for fossil and renewable energy systems installed in each sector. Moreover, sector specific targets for renewable energy and energy efficiency deployment, carbon emission reductions, natural gas demand reduction, and details of current and proposed policy measures, including financial subsidies. Furthermore, reporting by Member States should be sufficiently detailed to implement the approved EU gas demand reduction plan. This additional information will provide a more accurate representation of the current and potential market, which will better inform policy recommendations for targeted support, and mobilisation of the industry for increased deployment of renewable energy and energy efficiency measures in these predominant sectors, required to meet defined targets. Regarding Article 2 “Reporting on progress with respect to the decarbonisation dimension” in accordance with the formats set out in Annex II, EGEC emphasise the need for increased granularity of reporting. The share of RES per sector and the installed capacity of each renewable energy type is insufficient data on its own. In addition to the required information to be reported in Table 1 and Table 2, EGEC call for a breakdown per sector of each renewable energy type within the overall shares of energy from renewable sources, and their applications within each sector. We need to know the contribution of geothermal energy in district heating and cooling and its use to replace imported fossil gas, coal and oil in buildings and industry. Concerning Article 10 “Reporting on progress towards financing”, EGEC propose for member states to report a clear listing of current and proposed financing schemes for renewable energy technologies, clearly highlighting technology eligibility. Furthermore, details of direct and indirect fossil subsidies must be listed alongside renewable programmes. With respect to ANNEX XVI “Additional reporting obligations in the area of renewable energy”, it is essential that member states report on national governance framework and alignment with recent updated targets within EU strategies, namely Fit for 55% and RepowerEU
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EGEC demands open geological data to boost geothermal energy

21 Jun 2022
Topic — This consultation defines high-value datasets to be made available for reuse across the EU.
Message — EGEC calls for the public availability of all geological data related to reservoirs and other subsurface usage. They specifically request access to data from exploration licenses that did not result in operational projects.12
Why — This would help the industry identify geothermal resource areas for heating and cooling applications.3
Impact — Existing license holders lose their competitive advantage by being forced to share hidden exploration data.4
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Meeting with Barbara Glowacka (Cabinet of Commissioner Kadri Simson)

10 May 2022 · Geothermal in the REPowerEU package

Geothermal council urges digital data to speed up EU permitting

12 Apr 2022
Topic — EU guidance on removing administrative barriers for renewable energy projects and facilitating power purchase agreements.
Message — EGEC calls for digital geological data to create traffic light systems for approvals. They propose single contact points to centralize complex licensing for heating and power.123
Why — Streamlined procedures would significantly lower project development costs and reduce implementation timelines.45
Impact — Developers holding unused licenses would lose rights if their projects remain inactive.6
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Meeting with Nils Torvalds (Member of the European Parliament)

16 Feb 2022 · Energy Efficiency Directive

Meeting with Alin Mituța (Member of the European Parliament)

14 Feb 2022 · Discussion on the EGEC’s position paper on the Renewable Energy Directive

Meeting with Laure Chapuis (Cabinet of Commissioner Kadri Simson), Tatiana Marquez Uriarte (Cabinet of Commissioner Kadri Simson) and

22 Sept 2021 · Draft Climate, Energy and Environmental State aid Guidelines.

Meeting with Laure Chapuis (Cabinet of Commissioner Kadri Simson)

27 May 2021 · To discuss the Fit for 55 Package.

Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

22 Mar 2021

EGEC welcomes the opportunity to provide feedback to the Inception Impact Assessment of upcoming revisions to the Energy Performance of Buildings Directive. 1. Significance: It is impossible to meet the EU’s 2030 and 2050 climate neutrality targets without ensuring all heating and cooling equipment and appliances are renewable by 2025. The EPBD objective of decarbonisation of the European building stock must therefore become the core principle of the review of the text. On average, fossil applications tend to have an operational life between 25-30 years meaning that they must be phase out of the market and replaced by renewable solutions within the next five years. It also means that fossil heating and cooling appliances must be prohibited beforehand. Many Member States have already introduced these measures to allow their domestic heating industries to gain competitive advantage in renewable solutions as well as reducing carbon costs and climate damages. Austria banned new gas boilers from 2025 whilst the City of Vienna banned new gas boilers from 2020. France has banned gas boilers in new buildings from 2021, Germany has introduced a carbon mechanism and municipal initiatives to convert district heating systems to geothermal and other renewables. 2. Making the EPBD Fit for 55%: An important first step has been the inclusion of carbon emission thresholds in the EPBD assessment in 2018. This requirement must be strengthened, reinforcing the decarbonisation of the building stock via an efficient use of renewable energy sources. These must be integral to the renovation strategies and investment rates. The ongoing review must now include strict thresholds for the overall carbon footprint of buildings, barring any fossil equipment in new and deeply renovated buildings. 3. The right policies for the right buildings: Europe’s buildings are not equal. To achieve the decarbonisation of the building stock, there is a need to address the specificities of the various types of buildings, and the specific challenges of European citizens and businesses. • Tackling energy poverty with building decarbonisation: Europe’s least affluent households are already the most likely to live in poorly insulated buildings consuming the most polluting fossil fuels such as coal or fuel oil. They are also the most exposed to energy poverty, spending the highest share of their income on heating and cooling. The EPBD review must include requirements to Member States accompanying vulnerable households and local authorities in planning and financing a just decarbonisation of the building stock. • Public building exemplarity: the EPBD must now include decarbonisation requirements for public buildings from 2021. • Local heating and cooling planning is the key to an efficient decarbonisation of the European building stock 4. Policy coherence and ending ‘fuel neutrality”: Energy efficiency and building decarbonisation policies can no longer be “fuel neutral”. This means new buildings must have appliances which do not utilise fossil methane, coal and oil heating and cooling installations. The Article 4 setting “Minimum Energy Performance Requirements” must be revised accordingly. A key measure to this end is to include the definition of “Renewable heating and cooling” in the Article 2 of the EPBD, which must correspond to renewable energy sources as defined in the Renewable Energy Directive article 2 used for heating and cooling. 5. Life-cycle ratings: A specific methodology for the overall efficiency of renewable energy uses for heating and cooling should be established. This methodology should notably establish distinction between the efficiency ratings of renewable energy solutions according to temperature needs. 6. Putting an end to fossil fuel subsidies under the guise of efficiency: We recommend Article 10 is revised to exclude financial support to equipment that lock-ins fossil fuel consumption such as gas boilers.
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Response to Revision of EU rules on Gas

10 Mar 2021

We welcome the opportunity to respond to this Inception Impact Assessment (IIA). Our observations and recommendations are: • Significant competitive distortion: The Internal Market for Gas legislative basis is one of the largest and most sophisticated fossil fuel subsidy regimes in the EU. It directly favours policy design and financial support for the utilisation of fossil methane through investment in infrastructure, distribution grids, appliances and fuel consumption at the expense of geothermal energy and other renewable heating and cooling solutions. Heat accounts for half of the EU’s energy consumption. 80% of this heat comes from fossil fuels of which fossil methane is the largest source contributor. it is materially incorrect that these services can only be supplied by a mix of fossil and bio methane as well as fossil and renewable hydrogen. The justification for restricting market access to these two energy sources is not made clear nor the significant impact it has on geothermal ground-source heat pumps or geothermal district heating solutions. • Non-compliance with the treaty: Article 176 of TEFU calls for an internal energy market that ensures security of supply, interconnectivity as well as the promotion of energy efficiency, energy savings and renewable energies. The focus on an internal market for fossil methane goes against these requirements. It prevents the heat sector from delivering cost-effective, reliable and renewable heating, cooling and electricity services in Member States. We recommend a full scale review of gas market regulations with a view to creating a legislative basis for an Internal Market for heat. If ‘renewable gases’ are to have a place in the EU policy mix, they must be part of this renewable heat legislative base which provides a technology-neutral framework and level playing-field for the promotion of all renewable heating and cooling solutions. • Scope: The framing questions in this IIA limit policy options to the removal of CO2e emissions from fossil methane or the use of renewable hydrogen rather than creating a competitive, resilient and climate neutral market for the provision of heating, cooling, electricity and hydrogen. According to Eurostat, over 60% of fossil methane consumed in the EU was used to provide the service of heating and cooling in 2018. This service is also provided by geothermal and other renewable solutions. However, they lack access to the same levels of funding for infrastructure, distribution, appliance installation as well as institutional representation. They are also considerably cheaper than fossil methane. ADEME, the French environmental agency assessed the levelled cost of heating in France, in 2018 and found that the cost of a geothermal district heating system was as low as €15 per MWh compared to €51 per MWh. This cost calculation did not account for the short and long-term climate impacts of fossil methane. The design of the gas package needs to centred around the delivery of sustainable heating and cooling to ensure that it is compatible with the recent electricity market reform, which regulated a market for the service of electricity from multiple renewable and non-renewable technologies. • Policy options: There is a danger that hydrogen market development could lock out geothermal from the provision of heating and cooling services to industry, particularly those associated to greenhouse gas emissions from processes. Therefore, the objective should be the facilitation of cost-effective, resilient local and decentralised production of renewable energy solutions. Also, it is key to avoid the lock-in of hydrogen demand for industrial and transport sub-sectors which are deemed to be hard to abate.
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Response to Revision of the guidelines for trans-European Energy infrastructure

8 Mar 2021

EGEC welcomes the opportunity to give feedback on the European Commission’s proposal to amend the Trans-European Networks for Energy. • Continuation of fossil fuel subsidies: Overall, we are disappointed by the lack of alignment to the EU’s Green Deal and fit for 55% target. Whilst the rhetoric suggests that funding for fossil methane infrastructure “no longer needs support through the TEN-E policy. The planning of energy infrastructure should reflect this changing gas landscape” (Recital 11) this is not supported by an actual legislative amendment to implement this position. • Smart gas grids: The inclusion of this new subsidy for fossil methane indicates that PCI projects for local infrastructure are eligible for Connecting Europe Facility funding. This prove the case that CEF funding can be used for local fossil energy infrastructure and now must be applied to geothermal district heating and cooling systems.
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Response to Modernising the EU’s batteries legislation

1 Mar 2021

EGEC views on Modernising the EU’s Batteries legislation EGEC, the voice of the European geothermal industry, is a not-for-profit association representing the entire value-chain of the industry across 28 countries. It is included in the European Transparency Register number: 11458103335-07 Further information can be found at www.egec.org We welcome the opportunity to respond to the consultation on Modernising the EU’s Batteries legislation and wider process. Our observations and recommendations are highlighted in the document attached.
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Response to Proposal for a legislative act on methane leakage in the energy sector

26 Jan 2021

Geothermal energy provides renewable heating, cooling and baseload electricity. It has suffered from unfair competition with incumbent fossil gas, oil and coal because they have benefited from decades of public subsidies for infrastructure, appliances and consumption as well as the lack of a carbon price reflecting the true cost of their externalities. The Methane Emission Regulation is the first step in creating a level-playing field that removes the anti-competitive privileges enjoyed by fossil fuel providers. Our views and observations are: 1. We support the development of robust standards and guidelines to identify and regulate methane emissions in the fossil energy sector – gas, oil, coal, methane from anaerobic digestion. 2. Methane is the most powerful short-to-medium term greenhouse gas emission and therefore must be a priority for action given the limited timeframe to meet the Paris Agreement emission target. 3. Dr Werner Hoyer, President of the European Investment Bank, stated “Gas is over” because “without the end to the use of unabated fossil fuels, we will not be able to reach the climate targets”. The EIB will not fund gas infrastructure for heat from this year and only gas plants that apply carbon capture and storage from the outset. Meeting the EU’s 2030 and 2050 targets means shifting away from the utilisation of fossil methane in its entirety. 3. Voluntary approaches to monitoring, reporting and corrective action on methane leaks have been inadequate to date. EU regulation is required to create a single monitoring, reporting, verification and carbon pricing instrument. It is imperative for the EU to use self-regulation to drive the development of robust international standards. 4. The fossil industry must finance the permanent abatement of methane emissions. According to the International Energy Agency’s Methane Tracker 2020 (https://www.iea.org/reports/methane-tracker-2020/methane-abatement-options) 40% of this abatement can be delivered at no net-cost. 5. The upcoming legislative proposal to improve the Leak Detection and Repair (LDAR) on gas infrastructure must result in these emissions being included in the EU Emissions Trading System (EU ETS). This ensures the Polluter Pays Principle is applied and encourages rapid corrective measures. Venting and flaring must also be included in the EU ETS system to ensure harmonised action across the Single Market. 6. The Methane Regulation must be linked to the Trans-European Networks for Energy and automatically disqualify any current or future Project of Common Interest which utilises infrastructure with identified methane leaks, until such time as correct measures have been implemented. 7. Methane leaks and fugitive emissions from fossil gas production and transportation must be subject to a carbon price and therefore included in the EU ETS.
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Response to Revision of the Energy and Environmental Aid Guidelines (EEAG)

10 Dec 2020

We support the European Commission’s position to widen the scope of the guidelines for further technological and market innovations and organise the State Aid rules around EU policy objectives. Our recommendations are: 1. Alignment with the 2030 climate and energy framework and the 2050 climate zero-carbon target The current guidelines were designed to support Member States reaching their 2020 targets and now must become compliant with the 2030 climate and energy framework and the 2050 zero-carbon target. It should include the provisions laid down in the Clean Energy Package for All Europeans, and the recast of the Renewable Energy Directive (2018/2001/EU) and the Energy Efficiency Directive (2012/27/EU and 2018/2002/EU) and be rapidly amended to accommodate the revisions which are to be issued launched in 2021. 2. Widening the scope of State Aid legislation and extending support measures to: a) Geothermal lithium and sustainable extraction of critical raw materials: Lithium is a vital raw material essential for the success of the decarbonisation of the EU’s mobility, industrial strategy, technological innovation, competitiveness and prosperity. Proven reserves of geothermal lithium have been discovered in France and Germany but the full extent of reserves in other Member States has not been mapped. These plants have significant quantities of lithium hydroxylate which can be captured using innovative Direct Lithium Extraction (DLE) technology. This technology can be retrofitted to all existing geothermal plants substantially increasing domestic supplies of this vital metal. Geothermal plants with lithium deposits should be eligible for 100% State Aid support without prior notification. b) Application of thermal energy storage with renewable energy sources: Thermal energy storage is a vital domestic resource requiring greater clarity and recognition in State Aid. Under the current GBER framework thermal energy storage is not expressly mentioned, and it is unclear whether such aid measure would fall under Article 46 on district heating infrastructure or Article 48 on energy infrastructure. This new market development should be specifically addressed in the revised guidelines. 3. Levelling the playing-field for renewable district heating and cooling projects: We recommend the investment aid for energy efficient and renewable district heating and cooling projects must consist of 100% of the eligible costs, instead of 45% (under the current provisions). 100% State Aid intensity helps to level the playing field and create genuine competition between renewable and fossil heating solutions. 4. Strengthening support for technology-specific tenders The current guidelines outline technology-specific tenders as an exception. However, the notion of ‘technology-neutrality’ does not play out in practice for two reasons: a) Regulatory lock-in: EU and national regulations on the Internal Market for Gas block competition and substitution for heating and cooling services from renewable providers. b) Design lock-in:We recommend strengthening the role of technology-specific tenders 5. Ensuring well-designed and effective capacity mechanisms Spending on capacity mechanisms across the EU has nearly quadrupled. The revised guidelines must promote renewable electricity supply without distorting competition or trade in the EU Single Market. It should support EU Member States in directing its sustainable investments in the development of local, renewable, reliable and competitive capacities 6. Providing a clear methodology for defining innovative technologies 7. Continue granting financial support for renewable energy sources State Aid legislation must continue to level the playing-field with incentives and exemptions for geothermal and other renewable energy projects. Furthermore, geothermal energy is put at a significant disadvantage by a focus on the internal market for gas rather than heat.
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Response to Climate change mitigation and adaptation taxonomy

7 Dec 2020

Robust guidance directing capital flows to sustainable investments that do no harm is critical to solving the climate and economic crisis, accelerating the energy transition and ensuring sustainable development. Recognition of geothermal energy as a solution contributing to “climate change mitigation and adaptation” is an important milestone for this critical renewable energy solution to decarbonise heating, cooling, electricity as well as the sustainable supply of raw materials such as lithium. The draft Delegated Act proposes unfair technical screening emission criterion incorporating indirect emissions for geothermal energy in: • Section 4.6 (Annex 1, page 85) Electricity generation from geothermal energy; • Section 4.18 (Annex 1 page 110) Cogeneration of heat, cool and power from geothermal energy; • Section 4.22 (Annex 1 page 119) Production of heat and cool from geothermal energy. We recommend the deletion of these emission thresholds for geothermal energy because of: • The need for a consistent set of criteria across renewable energy technologies: All renewable energy technologies have indirect emissions through their respective supply-chains until the full decarbonisation of the global energy system and manufacturing processes. In the draft Delegated Act however, geothermal is not the subject of a fair treatment, having to justify life-cycle emission performance for eligibility, unlike other renewable technologies. For the sake of consistency and fair treatment between geothermal technologies and other renewables, the lifecycle emission threshold proposed in the delegated act must be removed for geothermal energy applications. Lifecycle emission assessment are a complex reporting requirement, which hampers the capacity of geothermal energy projects to access the capital flows striving for the “sustainable finance” label. This threshold adds a burden for geothermal developers, which is not justified by the reality of lifecycle emissions of geothermal plants. • The Horizon 2020 GeoENVI project (www.geoenvi.eu) developed a Life-Cycle Emission protocol based on proven environmental impacts of geothermal plants in the EU. No credible methodology based on robust EU environmental standards, existed prior to this. This standard shows that geothermal plants have the same lifecycle carbon footprint as other renewable energy sources, which is highlighted in Figure 3. Therefore, there is no justifiable basis for the lifecycle emissions threshold to be applied to geothermal energy when other renewable energy technologies are exempted from demonstrating compliance. • Geothermal heating and cooling has an even lower carbon footprint: geothermal heating and cooling projects have lifecycle emissions in a range comprised between and 9gCO2eq/kWh and 14gCO2eq/kWh , with cases as low as 5.9gCO2/kWh . This is a range far lower than that of photovoltaics, CSP or wind power, technologies that are exempted of reporting on their lifecycle emissions on a project basis for eligibility as sustainable investments. Geothermal heating and cooling projects, despite their climate mitigation performance – considering that they directly reduce GHG emissions from fossil fuels replacing fossil fuel for covering the same demand – are subject to this additional administrative burden. For the sustainable finance taxonomy to achieve its objectives of channelling capital flows towards “sustainable investments”, technologies clearly identified as such in various European policies and regulatory texts must be able to readily access. This is true for renewable energy sources defined in the Renewable Energy Directive, including the various geothermal energy technologies. For geothermal to be able to access sustainable finance on a level playing field with other renewable technologies, the additional lifecycle emission reporting requirement, which is not justified by research on geothermal and other RES carbon footprint, needs to be removed.
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Meeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness)

4 Nov 2020 · Sustainable Finance Taxonomy

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

21 Sept 2020

EGEC welcomes the opportunity to contribute to the consultation process on the revision of the Energy Efficiency Directive. For the geothermal sector, the EU targets on climate, renewable energy and energy efficiency need to be revised upwards to be aligned with the 2050 decarbonisation objectives. This for instance means 50% of renewable in heating and cooling, and a building sector where efficiency and renewables have been mainstreamed by 2030. The Energy Efficiency Directive need to be revised to reflect these imperatives. 1) The targets need to be reviewed upward to at least -55% GHG by 2030, with a consistent reassessment of the energy efficiency and renewable energy targets We argue in favour of increasing targets in a way that is consistent with at least 55% GHG emissions reduction by 2030. The energy efficiency and renewable energy targets need to be increased accordingly, and the Article 23 of the Renewable Energy Directive, whose implementation is directly linked to that of the Energy Efficiency Directive, need to be revised to become a biding provision that amounts to 50% of renewables in heating and cooling by 2030. The energy efficiency target must be increased and made binding to ensure its implementation. 2) The revision of the targets and the energy efficiency measures need to be consistent with decarbonisation: the lock out of fossil fuels must start now The period from 2030 to 2050 corresponds to the technical lifetime of a heating and cooling equipment. This means that after 2030, all renewable heating and cooling investments will need to be renewable based. To get there, the Energy Efficiency needs to accelerate renovation rate and mainstream the decarbonisation of the building stock and of the industry. 3) The Energy Efficiency Directive needs to be revised: Among the three options proposed in this consultation, EGEC argues in favour of the third. the Energy Efficiency Directive cannot continue to allow Member States to distribute subsidies to fossil fuel equipments on the pretext of marginal efficiency gains . The rules for allowing energy efficiency subsidies, notably under the Article 7a of the Directive, need to be revised to make them consistent with the decarbonisation imperative. Only equipment that is efficient and renewable should be eligible for energy efficiency support, as these are the only technologies that can be supported in the market. EED Article 14 must be reviewed as follow: “2. Member States shall adopt policies which encourage the due taking into account at local and regional levels of the potential of using efficient renewable heating and cooling systems, in particular those usinglocal renewable heating and cooling resources contributing to the annual objective in Directive 2008/2001 article 23. Account shall be taken of the potential for developing local and regional heat markets.” 4) Long term renovation strategies must see their implementation strengthened 5) Modelling of the energy system: the current EU modelling is not robust enough to assess energy efficiency and renewable energy targets in relation with a higher GHG objective • All modelling needs to be consistent with 2050 decarbonisation strategies. By 2030, many heating and cooling infrastructure, and much of the building stock will still be there to 2050. This approach allows an optimization of investments that guarantees a more cost-efficient decarbonisation. • The modelling need to reflect adopted EU policies, notably the REDII Article 23 for mainstreaming renewables in heating and cooling. Even the modelling of EUCO3232.5, representing the application of the Clean Energy Package fails to represent this measure. EU energy system modelling needs to represent existing legal provisions. • The model needs to be transparent in its assumption and the way it comes up with results. • Stakeholders need to be consulted in the modelling process
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

21 Sept 2020

We welcome the opportunity to respond to the consultation on the Renewable Energy Directive Inception Impact Assessment and wider process. Our observations and recommendations are: 1. Prioritisation: We agree that one of the central problems to address in this reform is the need for greater and rapid penetration for renewable heating and cooling technologies to address climate pollution from heat consumption. 2. Revision of the Renewable Energy target: We support increasing the RED target from 32% to 40% though are concerned that this might be too low in the context of the need to accelerate decarbonisation of heating and cooling as well as the emphasis placed on renewable hydrogen. Article 23 must now become a binding EU target to ensure half of the EU’s heating and cooling consumption is derived from renewable sources by 2030. The annual percentage point increase in the share of renewable must be changed from 1.3 to 3.1. 2. Options for the Impact Assessment: We support Option 5. It is essential to marry dedicated financial structures for investments, capacity building for project proposals as well as training professional geothermal installers. 3. Extending support schemes (Article 4): The are intended for renewable electricity. They should be extended to include support for geothermal heating, cooling and electricity. Given the need for sustainable supplies of lithium, they should be extended to geothermal lithium supplies from existing and new geothermal energy systems. Thermal energy storage systems should also be able to access support schemes. 4. Community-wide risk insurance:The Union renewable energy financing mechanism outlined in Article 33 of Regulation 2018/1999 on the Governance of the Energy Union and Climate Action should be amended accordingly to include a Union geothermal risk insurance scheme. 5. Permitting and licensing for large renewable energy projects in electricity and/or heating and cooling needs to be facilitated by the setting of one-stop-shops at the national level, and the time limit for the final decision on permitting must be 2 years from the date of application. 6. Renewable heat pumps: the Seasonal Performance Factor threshold to consider heat pumps as renewable (Annex VII) must be updated from 2.5 to 3. The associated Delegated Acts which establish the methodology to define renewable cooling, must be issued immediately for rapid implemented. 7. Decarbonisation of buildings: According to the EPBD (2018/844/EU), the EU must decarbonise its building stock by 2050, at the latest. The implementation of Article 15 of the Renewable Energy Directive must be reviewed to enable the maximisation of the share of renewables in buildings and prepare the lock-out of fossil fuel technologies from the building sector. 8. Geothermal lithium:should be included in Renewable Energy Directive as: i) Definition: Article 2 should include a definition of ‘Geothermal lithium’ as ‘the direct extraction of lithium from geothermal brines’. ii) Finance: Support schemes in Article 4 should be amended to include support for geothermal lithium iii) Multiplier accounting: Investment in geothermal lithium capacity should be accounted with a factor of 3 in the delivery of electricity, heating and transport sub-targets 9. Removal of fossil fuel subsidies: Article 7 of EPDB provides a direct subsidy for the replacement of an inefficient fossil fuel boiler with an efficient fossil fuel boiler. This must be amended to read “high-efficiency alternative systems based on renewables ,” rather than “high-efficiency alternative systems”. The Trans-European Networks for Energy (TEN-E) Regulation must be amended for transboundary geothermal heat reservoirs and basins to be able to access EU infrastructure funding from the Connecting Europe Facility. 11. Modelling of the energy system: the current EU modelling is not robust enough to assess energy efficiency and renewable energy targets. [more details in attached PDF]
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Response to Modernising the EU’s batteries legislation

9 Jul 2020

We welcome the opportunity to contribute to the process of modernising the EU’s batteries legislation, to drive the development of a sustainable batteries value chain. For EGEC, a European sustainable batteries value chain must be first and foremost compliant with the imperatives of decarbonisation and those of minimising the environmental impacts. For this reason, EGEC acknowledges the emphasis put on recycling. Geothermal energy is a renewable energy source in form of heat beneath the surface of the earth. For decades the presence of materials, such as lithium, in the geothermal brine has been know. High temperature lithium-rich brine can be pumped to the surface from a geothermal reservoir. The heat is removed from the brine for use in renewable electricity/heat and whilst raw lithium carbonate – the form of lithium used in batteries for uses such as ICT or electric vehicles – is converted into numerous products. A frantic race is on to secure the technology and the supply of geothermal lithium, with the USA, New Zealand, Japan and Latin America investing in many projects. Europe, which is also on the starting line cannot be late, as it has a tremendous resource potential and several projects already under way. The multiplicity of advantages from geothermal energy can be a factor of competitiveness for the European economy, where a single renewable resource can provide security of supply for several crucial inputs for the decarbonisation of the EU. Geothermal lithium projects are a solution to the environmental impact of the production of raw materials for batteries that provide value for local communities, notably in the form of locally sourced renewable electricity and low cost heating and cooling for industry, businesses and households. Geothermal lithium technologies are a process that is much less resource intensive than alternatives, making it a better fit for densely populated areas such as the EU, and to provide the best environmental protection possible. It is a 0-carbon process, with minimal water and land consumption. The Modernising of the EU’s battery legislation can contribute to establishing the policy architecture to deliver self-sufficiency in geothermal lithium production requires: • Target: 25% of lithium used in EU battery manufacture should come from indigenous geothermal resources by 2030. It should contribute to the -55% climate target in 2030 as either a stand-alone target or through an additional increase in the Renewable Energy Directive. • Incentivising extraction and lithium processing capacity: linkages with the TEN-E and TEN-T should be made to classify geothermal lithium and lithium processing plants as critical to European transport and energy networks to enable Projects of Common Interest classification and access to Connecting Europe Facility funding. This will facilitate establishment of the full value-chain of lithium-ion batteries in the EU. • Mapping EU resources: Funding for mapping geothermal lithium resource is a necessary first step in deploying this technology. Some Member States are already planning this through their National Energy and Climate Plans, and EU financing schemes such as the Connecting Europe Facility can fund the establishment of this basic knowledge infrastructure. • Reducing administration and licensing for geothermal lithium investments: The planning process for geothermal lithium plants must be streamlined, without undermining the robustness of the environmental standards. The Renewable Energy Directive, TEN-E and Smart Sectoral Integration legislation should address this issue.
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Response to Commission Communication – "Renovation wave" initiative for the building sector

8 Jun 2020

An effective Renovation Wave strategy should be an antidote for climate crisis by providing an inclusive and sustainable exit from the COVID-19 pandemic. We make the following observations and recommendations on the IIA and upcoming Communication: 1. The significance of heating and cooling: 85% of the energy consumed in households andresidences is used for heating and cooling. The remaining 15% is used for lighting, electrical appliances, etc.1 73% of industry energy consumption is for heating and cooling. The remaining energy consumption is used for mechanical applications powered by electricity. For service buildings 63% of the energy consumed is for heating and cooling. Renewable heating and cooling have to be central to the Renovation Wave if it is to make a meaningful contribution to the EU’s 2050 climate targets as well as measurable improvements in living standards, reductions in household energy bills, elimination of fuel (heat) poverty, regional regeneration and investment in skilled local jobs. 2. The EGEC approach, as outlined in our Renovation Wave(s) report, is to apply the proven and very successful project management approach to ensuring delivery of wide-scale energy renovation within the next 5 years. Note, this approach has been employed by the European Commission in the case of the Coal Regions in Transition platform. Here, regional governments, local communities and corporations propose solutions on how to rebuild their local economies after the closure of coal mines across the EU. This is the innovative policy approach required for a successful Renovation Wave. The EGEC approach, as outlined in our Renovation Wave(s) report, is to apply the proven and very successful project management approach to ensuring delivery of wide-scale energy renovation within the next 5 years. Note, this approach has been employed by the European Commission in the case of the Coal Regions in Transition platform. Here, regional governments, local communities and corporations propose solutions on how to rebuild their local economies after the closure of coal mines across the EU. This is the innovative policy approach required for a successful Renovation Wave. 3. Delivering large-scale decarbonisation through renewable heating and cooling in the shortest timeframe: We welcome the focus on “concrete measures” in the upcoming Communication. The pace of transformation is critical. Focus on facilitating the switch from fossil fuels in individual heat appliances and District Heating & Cooling (DHC) systems to geothermal energy is the quickest way to decarbonise 25% of the EU’s population and reducing energy bills. This is an example of the industrialisation of renewable heating and cooling. To realise this winning potential DHC systems should be recognised as Projects of Common Interest in the context of the Connecting Europe Facility (CEF) and the trans-European Networks for Energy (TEN-E). 4. Getting heat pumps and electrification terminology right: The Renewable Energy Directive, incorporating the principles of energy efficiency, introduced criteria to define the efficiency of a heat pump. There are four types of heat pumps - gas heat pumps, air heat pumps, hybrid heat pumps combining air and gas and geothermal heat pumps. Air and geothermal heat pumps are classified as providing ‘renewable heat’ if they produce more heating/cooling than the electricity they consume. This is called the Seasonal Performance Factor (SPF). This was set at 2.5 meaning any heat pump operating with an SPF at 2.5 and above is classified as renewable heat. Those below this threshold are not deemed to be energy efficient or renewable. Geothermal heat pumps are the only ones with a SPF consistently above 2.5. This is the difference between decarbonising buildings with energy efficient renewable heat or inefficient electricity. 5. Defining success: The Renovation Wave should not define success in terms of doubling the renovation rate, as outlined in the IIA.....
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Response to Revision of the guidelines for trans-European Energy infrastructure

8 Jun 2020

We welcome the opportunity to respond to the consultation on the TEN-E Inception Impact Assessment. Our observations and recommendations are: 1. Including renewable heat in the scope of TEN-E: Renewable geothermal heating and cooling district heating networks must be incorporated into the revised TEN-E framework to achieve the internal market for energy by displacing the use of harmful fossil fuels in heat production. Article 1 and Annex 1 of Regulation 347/2013 limit this Regulation to ‘priority corridors’ in electricity, fossil gas and oil as well as ‘thematic areas’ such as smart grids and CO2 networks. This has locked-out geothermal and other renewable heating solutions creating a significant distortion in the functioning of the internal market for energy overall and heat in particular. Therefore, it is crucial that TEN-E, the Connecting Europe Facility and the Projects of Common Interest finance i) geothermal energy to supply existing DHC systems, and ii) links to major energy demand centres such as schools, hospitals, social housing, which are central to the Renovation Wave. 2. Redressing the planning and governance process: The Ten-Year Network Development Plans (TYNPDs) process, through which priority corridors for electricity and fossil gas are identified, is flawed because it ignores renewable heating and cooling infrastructure requirements as well as also flexibility services. The plans are designed by ENTOS-E and ENTOS-G and then offered to input towards the end of the process. This is why the voice of the renewable heating and cooling industry and its planning needs have been neglected in the TEN-E framework. Institutional parity is required to address this gap and help design a modern, flexible, responsive, resilient, renewable heating, cooling and electricity energy system. There is no legal entity to represent the needs of the renewable heating and cooling network operators within the EU. Renewable heating and cooling network providers operate within regions but lack the infrastructure planning legislation and financial support to go beyond borders to maximise economies of scale, especially regarding trans-national heat basins and reservoirs. Therefore, an ENTSO-H is required to identify planning needs for renewable heating and cooling and its integration with electricity systems. An additional body is required to cater for flexibility services. 3. Redefinition of infrastructure: The definition of energy infrastructure in the Regulation (Article 2(1)) is sufficient to capture the infrastructure requirements for geothermal energy district heating systems and other renewable heating and cooling applications. However, the legal basis which identifies priority corridors refers back to legislation for electricity and gas, which effectively locks-out geothermal and other renewable heating and cooling solutions. This must either be deleted or the above priority corridors listed in Figure 2 must be included in the existing Annex 1. 4. Geothermal lithium: Securing stable, sustainably sourced, domestic lithium supplies are crucial to decarbonising mobility through electric vehicles and grid management services. Geothermal lithium provides a source of stable, indigenous supply produced to sound environmental standards. TEN-E and Connecting Europe should finance studies and mapping of European geothermal lithium reservoirs to maximise use of this lucrative resource as it is central to sectoral integration between renewable energy and electro-mobility. 5. Recognition of grid balancing services: Geothermal ‘baseload’ or ‘dispatchable’ electricity is able to support intermittent renewable electricity sources improving grid stability and overall system efficiencies. It represents an opportunity to fully integrate renewable energy solutions. This also lessens the requirement to import harmful and costly fossil fuel supplies together with their associated infrastructure. 6. Exclusion of project fossil fuel subsidies
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Response to A EU hydrogen strategy

8 Jun 2020

We welcome the opportunity to respond to the consultation on the EU Hydrogen Strategy Roadmap consultation. Our observations and recommendations are: 1. Terminology: A robust legal definition for ‘clean hydrogen’ is required. It should be applied only to 100% renewable energy production from electrolysis. Innovation for this electrolysis technology as well as licensing and permitting innovation for baseload and intermittent renewable electricity providers must be the central tenants of this Strategy because as they are the only means to ensure renewable hydrogen has a role to play in a 1.5 degrees-compliant world. 2. Avoid lock-in: Industrial emissions arise from different temperature requirements for heat. High-temperature heat, at 500 degrees and above, is an area where renewable hydrogen could have an impact. However, low to medium temperature needs should be delivered by increased use of renewable heat and local district heating infrastructure. This applies to many industrial sectors such as cement drying, paper & pulp and 90% of chemical products. Same applies to heating and cooling of buildings where renewable heat sources are better solutions. 3. Increasing renewable hydrogen production: Less than 1% of the hydrogen produced today is compatible with the EU’s zero-carbon 2050 target. If renewable hydrogen is to have a role in the EU’s energy system, the volume of renewable capacity dedicated to direct and indirect renewable hydrogen production must be increased proportionately. The primary goal of sectoral integration is to accelerate the pace of electricity sector decarbonisation to enable it to decarbonise others. Recommendations: i) Binding Member State renewable hydrogen electricity targets for 2030 focus on intermittent and baseload or ‘dispatchable’ capacity such as geothermal and concentrated solar power; ii) Identify the gaps, if any, in NECPs between renewable electricity and renewable hydrogen utilisation forecasts and propose increased renewable energy targets. 4. Achieve the internal energy market: The development of hydrogen must be done in a wellfunctioning market covering electricity and heating. Fair market conditions are critical to avoid establishing uncompetitive markets for hydrogen has it has done so for fossil gas. Recommendation: The market for hydrogen must be part of a wider market for renewable heat market to ensure competition and a level playing field. 5. An EU strategy: Hydrogen has benefitted through more than 20 twenty years of EU finance. The High-Level Group on Hydrogen was established in 2002, and millions of euros had been used for research and innovation from FP5 to Horizon 2020. Today, hydrogen just accounts for less than 1% of Europe’s energy consumption. The new EU strategy must take into account past experiences, especially on modelling of the energy sector and planning of energy infrastructures, which led to the lock-in fossil fuels. EU strategies must be now be developed for other renewable energy sectors which have a key role in decarbonising the energy sector and have received little support until now. Recommendations: An EU geothermal strategy must be developed to maximise this sectors significant contribution and benefit to decarbonise heating, cooling, electricity, transport, agriculture and the transport. 6. Redressing the climate imbalance between fossil and renewable hydrogen: The roadmap correctly states the “production of renewable hydrogen is still considerably more expensive than the conventional, highly carbon- intensive methods, which does not reflect the associated environmental and climate externalities”. Recommendation: The EU Hydrogen Strategy must identify a carbon price to correct for the climate and environmental impact of fossil hydrogen. 7. Supporting a clean energy industrial value chain for a massive scale-up in production and demand: Geothermal and other baseload/dispatchable electricity sources are a critical feature of the hydrogen value-chain because
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Response to Strategy for smart sector integration

5 Jun 2020

We welcome the opportunity to respond to the Inception Impact Assessment (IIA) on an EU Smart Sector Integration Strategy. Our observations and recommendations are: 1. Purpose: The aim of smart sector integration must be to accelerate the energy transition by increasing the pace of investment in the transition to a renewable heating, cooling and electricity to decarbonise buildings, transport, industry, services and agricultural emissions. This is the most cost-effective means to deliver 2030 and 2050 climate and energy targets as well as stimulating local economic growth, high-quality employment and replicable by other signatories to the Paris Agreement. 2. (Buildings) Renewable heating and cooling requires priority action: Heat accounts for half of the EU’s energy consumption. 80% of this heat comes from fossil fuels. Yet there is a significant opportunity to decarbonise 25% of the EU’s building stock within 5-7 years by switching district heating schemes to geothermal energy. Importantly, this has the added benefit of reducing household energy bills. ADEME assessed the levelised cost of heat in France and found that it was one of the cheapest means of providing high quality heat. Geothermal district heating costs were as low as €15 per MWh compared to fossil gas which cost €61 per MWh. Note, there was no carbon price applied to the fossil gas utilisation. It is important to avoid over-simplifications as there are few silver bullets for heat decarbonisation. Two key principles - energy efficiency first and renewable heat - should be applied to households and smaller buildings decarbonisation. The legal definition of renewable heat using a heat pump depends on whether it has a Seasonal Performance Factor (SPF) of 2.5 and above. This means they consume limited electricity to convert the largest source of energy into heating, cooling and/or hot water. Smart Sectoral Integration should be used to advance renewable heat and also revising the SPF number to 3 or above to ensure energy efficiency first puts the least strain on the electricity generation system. 3. (Mobility) Geothermal lithium: Mobile batteries using lithium-ion are central to decarbonisation of surface transport, aviation and maritime sectors. Access to significant reserves of lithium are critical to cost reductions and domestic production. Lithium is a byproduct of large-scale geothermal plants enabling the entire battery value-chain to be housed in the EU. To unlock this potential, targets and incentives for domestic battery processing and geothermal lithium are a key feature of the sectoral integration legislative framework. 4. Upgrading market rules for gas markets: Gas is the only fossil fuel included in multiple EU regulations. Because of this privileged position it is able to continue to benefit from numerous public subsidies for infrastructure, appliances and consumption. Article 176 of TEFU calls for an internal energy market that ensures security of supply, interconnectivity as well as the promotion of energy efficiency, energy savings and renewable energies. The focus on an internal market for fossil gas goes against these requirements. It prevents the heat sector from delivering cost-effective, reliable and renewable heating, cooling and electricity services in Member States. We recommend a full scale review of gas market regulations with a view to creating a legislative basis for an Internal Market for heat. If ‘renewable gases’ are to have a place in the EU policy mix, they must be part of this renewable heat legislative base which provides a technology-neutral framework and level playing-field for the promotion of all renewable heating and cooling solutions.
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Response to Union renewable Financing mechanism

3 Jun 2020

it needs to be reliable for delivering large amounts of new renewable capacity, notably in heating and cooling, for the provision of flexibility by renewable technologies. This financial mechanism, as an enforcement measure for the Renewable Energy Directive must reflect the measures laid out in the directive, which define the application of state aid rules for energy, without prejudice to article 107, 108 TFEU. 1) Enable technology specific tendering Technology specific tendering for renewable energy technologies is one of the core provisions of article 4 on support schemes from the Renewable Energy Directive. The European Renewable energy financing mechanism must reflect this article. Technology specific tendering, and other tendering process features such as flexibility or “availability of energy” requirements allow a more cost-effective decarbonisation on the long term. It allows to diversify the public funding portfolio, embedding more resilience in the energy system. The provision of support by the Renewable financing mechanisms must be consistent with Recital 29, Article 4 and Article 6 of the Renewable Energy Directive. Geothermal power plants for instance provide many benefits that are not captured by measures such as LCOE or cost per MW. These plants provide baseload and flexible renewable electricity and are usually also providing combined heat and power. There also is an emerging trend towards the production of strategic minerals - such as lithium - from geothermal power plants which further increases the amount of energy services provided by geothermal plants. 2) Accelerate the deployment of RES in heating and cooling, and compliance with RED Art 23 Achieving the 2030 renewable energy target means that the EU must accelerate the deployment of renewable in heating and cooling. The Renewable Energy Directive Article 23 highlights this priority with the sectoral target on renewables in heating and cooling. As a tool for the enforcement of the target, the Renewable Energy financing mechanism needs to support the deployment of renewable heating and cooling technologies at all scale. The current proposal rightfully highlights this priority. The support allocated to renewable heating and cooling technologies by the mechanisms should be consistent with the contribution of this sector to the renewable target, as heating and cooling represents nearly half the EU energy consumption, and nearly the amount of renewable energy used in Europe today. 3) Support the market uptake of innovative renewable technologies The achievement of the 2030 EU renewable energy target is dependent on the absolute amount of renewable energy produced. This means that the Renewable Energy Financing mechanism also has a role to play in bringing to market innovative renewable energy technologies that provide additional services, which allow for a greater share of renewables. The article 14 of the current proposal rightfully notes the relevance of supporting innovative technologies via this mechanism. A renewable energy system requires the emergence of innovative renewable energy technologies such as Enhanced geothermal systems, high temperature underground thermal energy storage and geothermal lithium production to cost-effectively decarbonise the entire European economy, creating many new jobs along the way. 4) The Renewable energy financing mechanisms must focus on supporting renewables The mechanism cannot finance energy projects that do not directly increase the production of renewable energy. In particular, the mechanism cannot support any project that may lead to a lock-in of fossil fuel use, for instance natural gas, as this directly contravenes with its objective. Synthetic gas projects or electrolysis of hydrogen projects cannot be supported by the Renewable energy financing mechanisms because there is no evidence that they lead to a greater deployment of renewable energy (instead of locking-in fossil fuel dependence).
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Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans), Riccardo Maggi (Cabinet of Executive Vice-President Frans Timmermans)

6 May 2020 · Decarbonising European heating sector

Response to 2030 Climate Target Plan

15 Apr 2020

We welcome this opportunity to comment on the orientation of the impact assessment concerning the EU new 2030 climate targets. Our views are: 1. Leadership: We agree with the statement that “EU leadership in 2020 is needed more than ever given that worldwide progress towards the objectives of the Paris Agreement is insufficient”. 2. Science-based targets: The EU is correct to revise the -40% by 2030 as it is not aligned to climate science. To meet the objectives of the Paris Agreement, and keep global average temperatures below 1.5 degrees Celsius, the EU must set its mitigation targets outlined by climate science. The EU will stimulate all other countries to emulate it when it sets the right targets and the correct policy framework to mitigate climate pollution and achieve sustainable, inclusive socio-economic development. The UN’s Emissions Gap Report 2019 stated emissions must be reduced by 7.6% annually to meet the Paris Agreement target. This must be the starting point for the revision of the EU’s 2030 climate targets. It is unclear how the -55% target proposed by the European Commission correlates to the target stipulated by the global scientific community. 3. Significance of increasing the contribution from renewable energy and energy efficiency targets: Energy accounts for over 75% of the EU’s climate emissions. Greater penetration of renewable heating, cooling and electricity, combined with energy efficiency targets, are central to the increased climate target. A substantial increase in these targets is required to must be central to the impact assessment for 2030. The modelling must include an assessment 50% of heat being derived from renewable energy sources by 2030. This should review their impact on emissions, avoided climate costs, reductions in household energy bills, energy costs for industry and the overall energy import cost. 4. 100% renewable energy scenario: The EU’s baseline energy model must be 100% renewables incorporating baseload renewable electricity generation and all heat from renewable energy sources. Austria, Denmark, Ireland, Lithuania, Luxemburg and Spain have already called on the Commission to include a 100% renewable energy model in their Long-Term Strategy assessment. This has significant implications for both 2030 and 2050 targets. 5. Timescale: We agree that increasing the targets is “a significant step-up of ambition in the short term” but do not agree that this would lead to a “reduced lead-time for devising and implementing additional measures”. The Renewable Energy Directive has been in place for since 2009 generating a vibrant supply-chain and industrial base located across all Member States, especially for geothermal energy. Renewable energy targets are one of the EU’s most successful industrial policies as they stimulated direct clean investment in the energy system, regional employment, competitive advantage and inclusive local growth.The 2019 recast also established a legislative base for renewable heating and cooling. This is significant as it covers almost half of the EU’s final energy consumption. 6. Limitations of the energy model: There is no recognition in the flaws of the PRIMES model, which is used to assess energy system policy options, and how these failings are to be rectified. For example, there is no visibility of the type and number of heating appliances used in buildings and industry, which account for nearly 50% of the EU’s final energy consumption. 7. Carbon pricing: The modelling should acknowledge the lack of carbon pricing for heat and should not be confined to just reviewing this through the lens of the EU ETS. Household boilers are significantly below the 20MW threshold applied in the EU’s carbon market. 8. Robust definitions are required of Energy affordability; Security, Effective and efficient internal energy market; Direct and indirect subsidies; Minimise the risk of stranded assets and Macro-economic impacts.
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