OpenLobby.EU
Explore

Finnish Energy - Energiateollisuus ry

ET

Finnish Energy represents companies that produce, transmit, and sell energy in Finland.

Lobbying Activity

Meeting with Eero Heinäluoma (Member of the European Parliament)

19 Jan 2026 · Verkkopaketti

Finnish Energy warns against tightening EU Taxonomy emission thresholds

5 Dec 2025
Topic — The European Commission is reviewing the taxonomy to simplify existing technical screening criteria.
Message — Finnish Energy opposes tightening greenhouse gas thresholds for existing energy projects. They recommend aligning bioenergy rules with the Renewable Energy Directive. The organization proposes including electric boilers to support renewable heat production.123
Why — Maintaining current thresholds prevents significant administrative burdens and financial difficulties for utilities.45
Impact — Environmental groups lose if legacy plants avoid stricter emission standards through grandfathering.67
Read full response

Meeting with Philippe Moseley (Cabinet of Commissioner Dan Jørgensen) and Energiföretagen / Swedenergy

4 Dec 2025 · Nuclear energy

Finnish Energy calls for technology-neutral EU nuclear policy

3 Dec 2025
Topic — Consultation on the future development and deployment of Small Modular Reactors in Europe.
Message — The organization requests that nuclear be treated equally to renewables in EU climate policy and financial instruments. They advocate for harmonized licensing and standardization to create a unified European market for reactors.12
Why — This would enable easier cross-border deployment and provide access to critical EU funding streams.3
Impact — Renewable energy projects might face reduced funding as nuclear gains access to climate-related financial instruments.4
Read full response

Meeting with Margareta Djordjevic (Head of Unit Energy)

21 Nov 2025 · The energy efficiency target and H&C strategy

Finnish Energy urges technology-neutral funding for clean transition and innovation

12 Nov 2025
Topic — EU's post-2027 budget focusing on competitiveness and clean transition investments.
Message — The organization requests that funding allocation be based on project quality and technology neutrality rather than quotas or regional criteria. They emphasize the need for greater investment in clean energy innovation, commercialization, and industrial electrification while avoiding national subsidy competition.1234
Why — This would allow Finnish energy companies to compete for EU funding based on project merit rather than geographic or technology-specific quotas.56
Impact — Regions or technologies currently benefiting from quota-based or geographically targeted EU funding allocations.7
Read full response

Finnish Energy urges EU to support waste-to-energy in circular economy

6 Nov 2025
Topic — EU regulation on circular economy, secondary raw materials, and recycled material markets.
Message — The organization requests that waste incineration be recognized as a valid part of the circular economy when material recycling is not feasible. They oppose sanctioning waste-to-energy and advocate for market-based approaches rather than regulatory restrictions on incineration.123
Why — This would protect their members' waste-to-energy facilities and district heating business models.45
Impact — Environmental groups lose stronger restrictions on waste incineration that could drive higher recycling rates.6
Read full response

Meeting with Kitti Nyitrai (Head of Unit Energy)

5 Nov 2025 · Development of clean gases in Finland

Meeting with Ville Niinistö (Member of the European Parliament)

5 Nov 2025 · Energy, hydrogen

Finnish Energy Urges Forward-Looking Emission Factors in Building Climate Calculations

31 Oct 2025
Topic — EU framework for calculating life-cycle global warming potential of new buildings.
Message — The organization requests that emission factors reflect future energy system changes rather than historical data. They argue this ensures fair comparison between heating technologies and incentivizes cleaner solutions.12
Why — This would prevent their district heating systems from appearing less favorable under national averages.34
Read full response

Meeting with Aura Salla (Member of the European Parliament)

30 Oct 2025 · General introduction to the work in Brussels (EP) and lobbying

Finnish Energy Opposes New Digital Fairness Rules for Energy Sector

24 Oct 2025
Topic — Proposal to strengthen consumer protection against unfair digital practices and dark patterns.
Message — The organization argues existing EU laws like GDPR and the Digital Services Act already provide sufficient consumer protection online. They request that energy trade be regulated nationally rather than under EU-wide digital rules, as energy markets operate differently from other sectors.12
Why — This would exempt them from new compliance requirements and preserve their flexibility in national markets.34
Impact — Energy consumers lose stronger EU-wide protections against unfair personalization and dark patterns online.5
Read full response

Meeting with Eero Heinäluoma (Member of the European Parliament)

22 Oct 2025 · Energia-asiat

Meeting with Stefan Leiner (Head of Unit Environment)

20 Oct 2025 · Exchange of views about the environmental omnibus related to Industrial and Livestock Rearing Directive (IED) and permitting

Finnish Energy urges comprehensive EU directive for energy security

10 Oct 2025
Topic — The Commission is revising energy security rules to address new geopolitical and climate risks.
Message — Finnish Energy requests a comprehensive security approach through a new EU directive that safeguards supply. They advocate for public-private cooperation and market-based solutions while emphasizing company-led infrastructure management.123
Why — A flexible directive allows Finnish companies to maintain their successful national public-private cooperation model.45
Impact — Centralized energy producers may face higher risks compared to decentralized renewable energy providers during crises.6
Read full response

Finnish Energy urges EU to embrace district heating electrification

8 Oct 2025
Topic — EU strategy to decarbonise heating and cooling across households, industry, and businesses.
Message — The organization requests technology-neutral policies supporting district heating electrification, including biomass, heat pumps, electric boilers, and SMRs. They advocate for recognition of Energy-as-a-Service providers in legal frameworks and EU support schemes. They emphasize simplifying EU legislation to remove barriers to smart electrification and system integration.123
Why — This would enable continued profitable electrification of district heating networks using flexible electricity consumption.456
Read full response

Meeting with Katri Kulmuni (Member of the European Parliament)

2 Oct 2025 · Ajankohtaiset energiateollisuuden asiat

Meeting with Katri Kulmuni (Member of the European Parliament)

25 Sept 2025 · Ajankohtaiset energia- ja ilmastoasiat

Meeting with Monika Zsigri (Head of Unit Energy)

23 Sept 2025 · Energy security in Finland and the revision of the EU’s legislative framework

Meeting with Eero Heinäluoma (Member of the European Parliament)

23 Sept 2025 · Ajankohtaiset energia-asiat

Finnish Energy backs 90% emissions cut with technology-neutral approach

16 Sept 2025
Topic — EU proposes 2040 climate target of 90% net emission reductions
Message — Finnish Energy supports the 90% emissions reduction target but urges a technology-neutral approach including all zero and low carbon solutions. They request maintaining current bioenergy sustainability principles and creating an indicative EU-level target for technical carbon sinks like BECCS and DACCS that remains voluntary for companies.123
Why — This would preserve flexibility for Finland's diverse energy sector and avoid mandatory carbon capture requirements.45
Read full response

Meeting with Jens Geier (Member of the European Parliament) and Energiföretagen / Swedenergy

10 Sept 2025 · Exchange on Grid Action Plan

Meeting with Thomas Pellerin-Carlin (Member of the European Parliament) and Energiföretagen / Swedenergy

10 Sept 2025 · Decarbonation & EU competitiveness

Finnish Energy Urges Enforcement Over New Consumer Regulations

29 Aug 2025
Topic — A consultation on EU consumer policy priorities for 2025 to 2030.
Message — Focus on enforcing existing rules rather than creating new regulatory measures. Simplify regulations by setting qualitative objectives and reducing mandatory billing details.12
Why — This would reduce administrative burdens and grant more operational flexibility.3
Impact — Consumers may lose protections if regulators ignore smaller technical violations.4
Read full response

Finnish Energy urges enforcement before adding new data laws

16 Jul 2025
Topic — The consultation addresses streamlining existing rules to create a coherent data-sharing framework.
Message — Focus on effective enforcement of existing regulations before considering new legislative measures. The EU should address overlapping provisions and revise the GDPR to remove barriers to sharing.12
Why — This would reduce regulatory uncertainty and lower administrative costs for energy companies.34
Impact — Digital rights groups could lose protections if GDPR standards are weakened for efficiency.5
Read full response

Meeting with Eero Heinäluoma (Member of the European Parliament)

9 Jul 2025 · Ajankohtaiset energia-asiat

Meeting with Jussi Saramo (Member of the European Parliament)

4 Jul 2025 · Ajankohtaiset energia-asiat

Meeting with Antti Timonen (Cabinet of Executive Vice-President Henna Virkkunen), Silke Dalton (Cabinet of Executive Vice-President Henna Virkkunen)

3 Jul 2025 · Competitiveness and preparedness of the energy sector

Meeting with Eero Heinäluoma (Member of the European Parliament) and Energiföretagen / Swedenergy

2 Jul 2025 · Future of Europe's Power System

Finnish Energy urges merit-based funding for EU Innovation Fund

26 Jun 2025
Topic — This consultation evaluates the effectiveness and operation of the EU Innovation Fund.
Message — The organization argues funding should prioritize project quality and technology neutrality instead of using regional quotas. They recommend using auction models with fixed premiums for hydrogen and carbon removal projects. Application processes should be simplified to reduce administrative burdens.123
Why — This would help competitive Finnish firms secure more funding while reducing their paperwork.45
Impact — Projects in less developed regions would lose the protection of guaranteed funding quotas.6
Read full response

Finnish Energy urges EU to prioritize bioenergy in bioeconomy

19 Jun 2025
Topic — The EU initiative aims to create a circular and climate-neutral bioeconomy for competitiveness.
Message — The organization asks that bioenergy be recognized as a core pillar of the bioeconomy. They call for a stable regulatory environment to provide investment security and clear policy direction. Additionally, they promote efficient biomass use through combined heat and power to ensure energy security.123
Why — A stable regulatory environment would protect their investments and maintain long-term industrial competitiveness.45
Impact — Fossil fuel importers lose market share as bioenergy and electrification replace imported energy.6
Read full response

Finnish Energy defends oral contracts in electricity switching rules

17 Jun 2025
Topic — EU proposal to standardize data exchange for customers switching their electricity suppliers.
Message — The organization calls for rules that permit oral contracts and use flexible terminology for smart meter data. They oppose strict technical requirements for customer verification.12
Why — This allows Finnish suppliers to maintain existing sales practices and avoid redundant data reporting.34
Read full response

Meeting with Nicola Pesaresi (Head of Unit Competition)

17 Jun 2025 · Finnish Energy presented a general picture of the energy sector in Finland. They presented their comments and suggestions on the CISAF draft communication and their views on PPAs

Finnish Energy urges equal EU funding for nuclear power

12 May 2025
Topic — The Commission is assessing investment needs for the European nuclear energy ecosystem.
Message — The association demands technology neutrality in EU financing and equal incentives for nuclear-produced hydrogen. They also propose harmonizing safety licensing to support a common market for nuclear reactors.123
Why — Inclusion in EU funds would reduce financing barriers for planned Finnish nuclear expansion.4
Impact — Renewable energy industries would lose their exclusive access to certain green subsidies.5
Read full response

Finnish Energy Urges Voluntary Reporting to Reduce Industry Costs

26 Mar 2025
Topic — This consultation proposes amendments to simplify EU Taxonomy reporting and reduce company costs.
Message — Finnish Energy requests that operating expenditure reporting becomes voluntary for all companies. They also oppose tightening emission limits while implementation is ongoing to avoid complexity. They support flexible reporting formats and the use of significance thresholds.123
Why — Making reporting voluntary would reduce the significant administrative burden on power companies.45
Read full response

Meeting with Sebastian Tynkkynen (Member of the European Parliament)

6 Mar 2025 · Energiateollisuuden ajankohtaisiset aiheet

Meeting with Eero Heinäluoma (Member of the European Parliament)

6 Mar 2025 · Ajankohtaisasiat

Meeting with Dario Tamburrano (Member of the European Parliament, Shadow rapporteur) and GEODE - The voice of local energy distributors across Europe

6 Mar 2025 · Reti elettriche

Meeting with Katri Kulmuni (Member of the European Parliament)

6 Mar 2025 · Sähköverkkoasiat

Meeting with Elsi Katainen (Member of the European Parliament)

6 Mar 2025 · Bioenergy

Meeting with Pekka Toveri (Member of the European Parliament)

5 Mar 2025 · Current Topics in EU Politics

Finnish Energy demands national flexibility in EU Water Strategy

4 Mar 2025
Topic — A consultation on a cross-sectoral plan for achieving water resilience in Europe.
Message — Finnish Energy requests that water management remains under national decision-making to address regional differences. They argue that water for hydropower and cooling should not be treated as consumption. The strategy should favor a bottom-up approach over uniform EU-wide regulations.123
Why — This would protect energy companies from restrictive water use limits and higher compliance costs.4
Impact — EU environmental regulators would lose the power to enforce uniform water standards across all regions.5
Read full response

Meeting with Mika Aaltola (Member of the European Parliament) and Association of Commercial Television and Video on Demand Services in Europe

4 Mar 2025 · EU Affairs

Meeting with Merja Kyllönen (Member of the European Parliament)

4 Mar 2025 · Ajankohtaiset energiateollisuus

Meeting with Aura Salla (Member of the European Parliament)

27 Feb 2025 · Meeting CEO of Finnish Energy, Jukka Leskelä to discuss the clean energy package

Meeting with Anna-Maja Henriksson (Member of the European Parliament)

21 Feb 2025 · Energy policy

Meeting with Katri Kulmuni (Member of the European Parliament)

14 Feb 2025 · Ajankohtaiset energia-asiat

Meeting with Silke Dalton (Cabinet of Executive Vice-President Henna Virkkunen), Silvia Bartolini (Cabinet of Executive Vice-President Henna Virkkunen)

22 Jan 2025 · Finnish Energy Market

Meeting with Pierre Schellekens (Director Energy)

21 Jan 2025 · Exchange on the Commission’s upcoming initiatives and ET’s take on recent developments in the Finnish electricity market -industrial decarbonisation and flexibility market development

Response to Amendment to Registry Regulation in response to the ETS revision/Fit For 55 (Batch 2)

10 Jan 2025

The proposed change (2) addresses the cancellation of emission accounts in cases where during the five-year reference period the emissions from sustainable biomass has on average exceeded 95 %. The regulation still leaves open what happens to installations which exceed this threshold in the future years. We consider that the owners in such cases should have a possibility to cancel their emission permit. Hence, we call for clarification regarding the treatment of facilities where more than 95% of emissions are derived from the use of sustainable bioenergy. Also, we consider that the wording needs to be changes. Instead that national administrator _shall_ set these accounts to excluded status, it should be _may_. The proposed change (10) addresses cases where an operator or sector has been excluded from the scope and where the operator has though surrendered allowances. We dont agree with the wind fall -argument and hence dont endorse the proposed amendments to the return of emission allowances. In case where the operator would not have needed to surrender the allowances, it could have held them. Hence, we assert that this process should be conducted on a one-to-one basis also in the future.
Read full response

Meeting with Pekka Toveri (Member of the European Parliament)

10 Dec 2024 · Current Topics in EU politics

Meeting with Sebastian Tynkkynen (Member of the European Parliament) and Confederation of Finnish Industries EK and

3 Dec 2024 · Ajankohtaiset aiheet

Meeting with Sebastian Tynkkynen (Member of the European Parliament)

27 Nov 2024 · Ajankohtaiset ilmasto- ja energiapolitiikan asiat

Meeting with Maria Ohisalo (Member of the European Parliament)

27 Nov 2024 · Energy policy

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

27 Nov 2024 · Priorità per la legislatura

Meeting with Ville Niinistö (Member of the European Parliament)

26 Nov 2024 · Energy

Meeting with Eero Heinäluoma (Member of the European Parliament)

26 Nov 2024 · Ajankohtaisaiheet

Meeting with Li Andersson (Member of the European Parliament)

14 Nov 2024 · Energy policy

Meeting with Aura Salla (Member of the European Parliament)

11 Nov 2024 · The coming Commission work programme and the 2040 climate goals

Meeting with Eero Heinäluoma (Member of the European Parliament)

8 Nov 2024 · Ajankohtaisaiheet

Finnish Energy seeks investment stability for low-carbon hydrogen production

25 Oct 2024
Topic — The consultation defines a life cycle assessment methodology for low-carbon fuel emissions.
Message — Facilities should produce renewable and low-carbon hydrogen within the same hour. Use real-time hourly emission data for calculations. Maintain current rules to protect investments.12
Why — Reliable long-term rules prevent the delay or cancellation of major hydrogen projects.3
Impact — High-emission energy suppliers lose the advantage of using favorable country-wide emission averages.4
Read full response

Meeting with Eero Heinäluoma (Member of the European Parliament) and Finanssiala ry - Finance Finland and

1 Oct 2024 · Ajankohtaisaiheet

Meeting with Sebastian Tynkkynen (Member of the European Parliament)

1 Oct 2024 · Energia-alan ajankohtaiset EU-asiat

Meeting with Mika Aaltola (Member of the European Parliament) and KEMIJOKI OY

1 Oct 2024 · Energy Policy

Meeting with Karin Karlsbro (Member of the European Parliament)

24 Sept 2024 · Prioriteringar inför mandatperioden

Meeting with Nils Torvalds (Member of the European Parliament)

28 Jun 2024 · The upcoming term in the European Parliament

Meeting with Eero Heinäluoma (Member of the European Parliament)

19 Apr 2024 · Energia- ja ilmastopolitiikan EU-päivä

Meeting with Henna Virkkunen (Member of the European Parliament)

21 Mar 2024 · Digital policy

Meeting with Héloïse Auplat (Cabinet of Executive Vice-President Margrethe Vestager), Thomas Woolfson (Cabinet of Executive Vice-President Margrethe Vestager)

6 Mar 2024 · Exchange on EU competitiveness and Finnish and EU energy policy

Meeting with Sirpa Pietikäinen (Member of the European Parliament)

5 Mar 2024 · Relevant energy policies

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

4 Mar 2024 · Upcoming events regarding energy policy

Finnish Energy urges simple, non-discriminatory renewable auction criteria

1 Mar 2024
Topic — EU guidance on including qualitative non-price criteria in renewable energy auctions.
Message — Finnish Energy requests that pre-qualification and non-price criteria remain clear and simple. They demand that criteria avoid creating administrative burdens or delaying project development. The association also stresses that new developers deserve equal market access.123
Why — Streamlined requirements would reduce overhead costs and prevent potential project delays.4
Impact — Existing market leaders may lose their competitive advantage to smaller newcomers.5
Read full response

Finnish Energy demands clearer rules to end GDPR legal uncertainty

1 Feb 2024
Topic — Evaluation of the EU General Data Protection Regulation six years after implementation.
Message — Finnish Energy requests more concrete, real-life guidance from authorities to resolve significant legal uncertainty. They call for clearer definitions of roles and simplified rules for international data transfers.12
Why — Specific guidance would reduce the heavy administrative and financial burden of complex compliance assessments.3
Impact — Dominant tech platform providers could lose their disproportionate influence over data processing agreements and terms.4
Read full response

Meeting with Suvi Leinonen (Cabinet of Commissioner Jutta Urpilainen)

30 Jan 2024 · to share their views on the upcoming 2040 Climate Target Plan

Finnish Energy seeks broad free allocation for clean hydrogen

22 Dec 2023
Topic — The European Commission is updating rules for distributing free carbon emission allowances.
Message — All clean hydrogen production should be entitled to full free allowances regardless of technology. Efficiency measures should be flexible and provide guidance rather than detailed requirements.12
Why — This would reduce regulatory costs and provide essential funding for new hydrogen markets.3
Impact — Environmental groups lose if rules for energy efficiency audits are made less stringent.4
Read full response

Meeting with Pirkko Ruohonen-Lerner (Member of the European Parliament)

8 Dec 2023 · Ajankohtaiset kuulumiset

Meeting with Elsi Katainen (Member of the European Parliament)

27 Nov 2023 · Current energy issues

Meeting with Silvia Modig (Member of the European Parliament) and Energiföretagen / Swedenergy

21 Nov 2023 · Climate & Energy policy (staff level)

Response to Network Code on Cybersecurity

17 Nov 2023

Finnish Energy is grateful for the chance to offer our thoughts regarding the NCCS. There are at least seven directives and acts ongoing in various stages that concern cyber security in the energy sector of EU. We cannot stress enough that, for an effective execution of the NCCS, we highly recommend an early clarification on its scope and its connection with other legal frameworks. The proposed network code defines 'high-impact entities' and 'critical-impact entities,' encompassing numerous sectors, subsectors, and digital service providers. Nonetheless, the criteria to identify these entities are somewhat ambiguous, allowing room for varied interpretations by relevant authorities. This ambiguity may lead to uneven and disjointed application throughout the EU, generating severe legal uncertainties for organizations active in multiple regions. We strongly recommend that the Commission offer clear, initial guidelines on the parameters and criteria to determine essential and important entities, including the benchmarks and measures for evaluating incident impacts. Article 17 plays a pivotal role in establishing a methodology for risk assessment. It is essential to define the Electricity Cybersecurity Risk Index (ECRI) for determining high-impact and critical-impact thresholds, as well as enumerating Union-wide high-impact and critical-impact processes. We have concerns regarding the timely completion of these tasks, as they should be given utmost priority to avoid placing uncertain obligations on the entities involved. A cybersecurity risk assessment method needs to be devised with clear input values and scenarios for risk analysis to ensure a comprehensive level of scrutiny. The shift towards a risk-based approach in enhancing resilience is significant, allowing adjustments based on actual risk profiles. Regulation needs to be feasible for both large and small energy entities. Fulfilling the reporting obligations will demand more resources from these entities, so it's crucial that the reporting requirements and associated costs are kept reasonable. The incident reporting procedure should be more straightforward, pinpointing discrepancies in compliance with the NIS2 Directive. Adopting a singular, consolidated reporting system would enhance efficiency, preventing delays, incomplete reports, and redundant obligations. Considering this, we are pleased with the acknowledgment that DSOs should be able to fully recuperate costs arising from the NCCS obligations, either through network tariffs or suitable alternative methods. The introduction of the NCCS marks a significant shift. It's imperative for energy entities, as well as regulatory bodies, to quickly align with this extensive framework to bolster the protection of energy infrastructures against cyber threats, including the escalating risk of AI-based attacks. Understanding the operations of production facilities and the roles of other participants in the electricity market is crucial in formulating this methodology. Nevertheless, gathering data on incidents at an EU-level entity also poses risks, such as potential hacker attacks and the unintentional disclosure of vulnerabilities in national systems.
Read full response

Meeting with Ville Niinistö (Member of the European Parliament)

15 Nov 2023 · Current EU energy policies

Meeting with Elsi Katainen (Member of the European Parliament)

15 Nov 2023 · Nature restoration law, current situation

Meeting with Henna Virkkunen (Member of the European Parliament)

27 Oct 2023 · Current and future EU affairs

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

27 Oct 2023 · Green deal / energy / climate

Meeting with Elsi Katainen (Member of the European Parliament)

26 Oct 2023 · Discussions about current situations in energy sector

Meeting with Mauri Pekkarinen (Member of the European Parliament)

26 Oct 2023 · Discussion on the next European parliament's and Commission's programme

Meeting with Eero Heinäluoma (Member of the European Parliament) and Suomen Ylioppilaskuntien Liitto SYL ry

26 Oct 2023 · Topical issues

Meeting with Nils Torvalds (Member of the European Parliament)

13 Oct 2023 · Hydrogen

Meeting with Eero Heinäluoma (Member of the European Parliament)

13 Oct 2023 · Topical issues

Meeting with Eero Heinäluoma (Member of the European Parliament)

12 Oct 2023 · Topical issues

Meeting with Peeter Kadarik (Cabinet of Commissioner Kadri Simson), Thor-Sten Vertmann (Cabinet of Commissioner Kadri Simson)

5 Oct 2023 · Cabinet members discussed with Finnish Energy various technical aspects of energy market developments, regulatory measures, and future investments in the renewable energy sector

Meeting with Suvi Leinonen (Cabinet of Commissioner Jutta Urpilainen)

5 Oct 2023 · Electricity market

Meeting with Ville Niinistö (Member of the European Parliament)

21 Sept 2023 · Energy policy (staff level)

Meeting with Henna Virkkunen (Member of the European Parliament)

20 Sept 2023 · Finnish Energy Sector's perspective to current EU affairs

Meeting with Eero Heinäluoma (Member of the European Parliament)

30 Jun 2023 · topical climate and energy issues

Finnish Energy Urges Ambitious 2040 Targets Through Carbon Pricing

22 Jun 2023
Topic — The EU is establishing a 2040 climate target to reach climate neutrality.
Message — The organization recommends striving for emission reductions between 80% and 90% by 2040. They advocate for market-based tools like carbon pricing instead of specific technology mandates. They also suggest merging different emission trading systems to improve cost-efficiency.123
Why — A technology-neutral approach allows Finnish firms to utilize their diverse low-carbon energy production.4
Read full response

Meeting with Eero Heinäluoma (Member of the European Parliament)

14 Jun 2023 · Current energy legislation

Meeting with Sirpa Pietikäinen (Member of the European Parliament)

2 Jun 2023 · The Regulation on Wholesale Energy Market Integrity and Transparency (REMIT)

Meeting with Petri Sarvamaa (Member of the European Parliament)

1 Jun 2023 · Topical issues in EU politics

Finnish Energy urges district heating focus in heat pump plan

26 May 2023
Topic — This consultation seeks to accelerate the deployment of heat pumps across the European Union.
Message — The organization advocates for prioritizing district heating systems to ensure grid stability and requests that building regulations allow grid electricity as a valid energy source. They also call for financial guarantees for waste heat utilization and flexibility regarding refrigerant bans for industrial-scale plants.123
Why — These measures would reduce investment risks and maintain the market viability of district heating.4
Impact — Building owners lose by facing higher costs due to restrictive local energy requirements.5
Read full response

Finnish Energy Urges Inclusion of Waste Incineration in EU Taxonomy

3 May 2023
Topic — The initiative defines sustainable economic activities for investment purposes under the EU's environmental taxonomy.
Message — Finnish Energy requests that non-hazardous waste incineration be included in the circular economy technical screening criteria. They also advocate against creating overlapping requirements for switchgears with the upcoming F-Gas regulation.12
Why — This would allow waste-to-energy activities to access sustainable financing and prevent regulatory duplication.34
Read full response

Meeting with Ville Niinistö (Member of the European Parliament)

25 Apr 2023 · EMD

Meeting with Thomas Woolfson (Cabinet of Executive Vice-President Margrethe Vestager)

24 Apr 2023 · market issues and the EU’s latest proposals for the Net Zero Industry Act and the Electricity Market Design

Meeting with Nils Torvalds (Member of the European Parliament)

22 Feb 2023 · Energy market reform

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

17 Feb 2023 · EMD, EED, RED (staff level)

Meeting with Mauri Pekkarinen (Member of the European Parliament)

18 Jan 2023 · Discussion on the EU Nature Restoration Act

Meeting with Elsi Katainen (Member of the European Parliament, Shadow rapporteur) and Association of Finnish Local and Regional Authorities

18 Jan 2023 · Nature restoration

Meeting with Henna Virkkunen (Member of the European Parliament) and Suomen sähkönkäyttäjät ry (Association of Energy Users in Finland)

17 Nov 2022 · EU Energy Policy

Meeting with Mauri Pekkarinen (Member of the European Parliament) and Suomen sähkönkäyttäjät ry (Association of Energy Users in Finland)

16 Nov 2022 · Current EU affairs

Meeting with Ville Niinistö (Member of the European Parliament)

4 Nov 2022 · energy urgency measures and gas files (staff level)

Meeting with Henna Virkkunen (Member of the European Parliament) and Luonnonvarakeskus

29 Sept 2022 · EU Energy Policy

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

7 Sept 2022 · EU Energy policy

Response to Requirements for access to electricity metering and consumption data

1 Sept 2022

Finnish Energy welcomes the draft Implementing Regulation (IR) and thanks for the possibility to provide comments through this public consultation. We have first listed our main comments. Please find also the attachment with some more detailed comments on the draft text (both IR and it's annex). FINNISH ENERGY’S KEY MESSAGES 1. The Implementing Regulation shall respect current national data access and exchange processes. This IR has been prepared for over two years under the activities of the Smart Grid Task Force Expert Group 1 (EG1). Finnish Energy has followed the process closely via the EU DSO associations. During the drafting process it has been communicated that the IR will define a European reference model and require that Member States map their current national practices against this reference model. This way the IR will provide visibility of national practices to market parties around Europe and promote interoperability. During the drafting process it has also been clearly communicated that the IR will not require any immediate changes in national practices concerning data access and data sharing, nor will the IR set a fixed deadline for these changes. This is a highly recommendable principle which will at the same time, improve interoperability and respect the current national practices, thus not creating sunk costs from renewing IT-systems borne by the electricity customers. We strongly see that the IR shall not require harmonization but promote interoperability. This principle is now not clear in the draft IR and needs to be clarified. 2. The scope of the IR should be limited to metering and consumption data of customers connected to distribution network The scope of the IR should apply only to customers connected to distribution grids. Meters connected to high voltage grids (110 kV and up) and meters between network areas should be out of scope. This should be clarified throughout the IR. The proposed reference model has been based on data access for customers connected to lower voltage levels, namely households. Consumer protection rules in the retail markets are significantly different from rules when it comes to large industrial customers. We believe the IR would better fulfill its goals for improving interoperability with the scope limited to distribution networks (low and medium voltage). 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. 3. Member States shall not be required to do several overlapping mappings It shall be mandatory to provide only as many mappings of national practices as it is needed to make sure that at least one mapping is provided for all data access. In the ANNEX of this IR it is clarified that only one national solution needs to be mapped. This is an important principle and should be clarified also in the actual IR. For example, there can be several ways a customer can receive their metering data (from Datahub, from DSO, from supplier...). It needs to be clear that it is sufficient to map only one way according to the ANNEX. Members State shall choose the most relevant data sharing process to be mapped, making sure that at least one mapping is provided for all data access. More detailed comments on specific text parts are in the attachment. Sincerely Ina Lehto Senior Executive Adviser Finnish Energy Finnish Energy follows a code of conduct for sustainable lobbying.
Read full response

Meeting with Alina-Stefania Ujupan (Cabinet of Executive Vice-President Margrethe Vestager) and Green Power Denmark and

15 Jul 2022 · EU regulation on digital transformation and its impact on the energy sector.

Meeting with Mauri Pekkarinen (Member of the European Parliament, Rapporteur for opinion)

29 Jun 2022 · Discussion on energy and climate affairs

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

16 Jun 2022 · Discuss Industrial decarbonisation, Hydrogen and RePowerEU plan

Meeting with Mauri Pekkarinen (Member of the European Parliament, Rapporteur for opinion)

3 May 2022 · Discussion on ETS

Finnish Energy Demands Rapid Certification for Industrial Carbon Removals

2 May 2022
Topic — A regulatory framework to monitor and certify sustainable industrial and ecosystem carbon removals.
Message — They call for a swift certification framework for industrial carbon removals by 2026. Industrial processes should be fast-tracked independently from the more complex carbon farming sector.12
Why — The framework would enable energy companies to monetize removals and attract private funding.3
Impact — Carbon farming initiatives could lose political priority if industrial removals are fast-tracked.4
Read full response

Meeting with Elena Montani (Cabinet of Commissioner Virginijus Sinkevičius)

28 Apr 2022 · To discuss the legislative initiatives and biodiversity

Meeting with Henna Virkkunen (Member of the European Parliament)

27 Apr 2022 · Fit for 55

Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton)

22 Apr 2022 · Energy crisis and implications for industry

Meeting with Nils Torvalds (Member of the European Parliament, Rapporteur)

7 Apr 2022 · RED III

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

31 Mar 2022

About Finnish Energy Finnish Energy represents the Finnish electricity, gas, and heating sectors, and we have 270 members. We strongly support the Commission’s proposal for the EU’s climate targets for 2030 and 2050. We are also committed to Finland’s carbon neutrality target for 2035. Introduction Finnish Energy believes that the revision of the Energy Performance of Buildings Directive should be coherently implemented within the “Fit for 55 Package”. A cost-efficient and technology neutral climate framework based on the EU ETS will prioritise climate action and bring transitions costs down. EU ETS is certain and efficient way to ensure emission reductions and would also minimise the costs for citizens. Therefore, the introduction of emission cap and CO2 price for whole heating sector should be the priority. Finnish Energy’s Key messages to the proposal of EPBD (recast): The Finnish Energy considers that with regard to the provisions of Articles 7 (including Annex III) and 9 on new and renovation construction, the objectives to reduce greenhouse gas emissions from buildings and final energy consumption can be achieved more efficiently and appropriately at Member State level and through national measures taking into account national conditions, climatic conditions and the specificities of energy systems. The content of the proposed directive needs to be developed in orde 1. EPBD is important when minimizing the energy use and emissions in buildings • We consider it important that decision-making power over both the detailed energy efficiency requirements for new construction and the regulation of improving the energy efficiency of existing buildings be maintained at national level. The directive should define the objectives, the measures of achieving them should be chosen by the Member States, taking into account the baseline situation and cost and resource efficiency. • The development of energy systems (electricity as well as district heating and cooling) to be carbon neutral as early as the 2030s in Finland should be taken into account when defining zero-emission buildings and the calculation methods of life-cycle Global Warming Potential involved. • All carbon neutral energy sources and waste heat recovery play a key role in the decarbonisation of the EU building stock. Therefore, they should be treated equally with renewables when it comes to meeting the renewable energy targets for heating and cooling, district heating and cooling and buildings. 2. Sector integration enables a cost-effective carbon-neutral future: regulation must not jeopardize the operating conditions of energy networks • The definition of a zero-emission building imposes unnecessarily narrow limits, ignoring the inherent possibility of achieving a carbon-neutral building stock, namely the role of the energy system. The directive should allow the existing building stock to be made carbon-free including through changes at energy system level. This would allow the fastest and most cost-effective transition to a carbon-neutral energy system and thus to the building stock in Member States where the energy purchased for buildings is based on district heating, district cooling and electricity. Categorical building-level requirements can lead to sub-optimal solutions and jeopardize the development of sector integration. • Equal treatment of on-site and supplied energy (electricity, heat and cold) should be ensured. Distribution grids will play an important role in this transformation, enabling resources to be efficiently and economically transferred between different sectors and market actors. • While heating and cooling sector is currently heavily reliant on fossil fuels in many European countries, a whole system approach with all available low carbon energy carriers is needed • Wider level approach in decarbonising the heating and cooling sector will create system efficiencies on a larger scale and make more significant impact at a lower price.
Read full response

Meeting with Mauri Pekkarinen (Member of the European Parliament)

23 Mar 2022 · Current energy issues

Meeting with Mauri Pekkarinen (Member of the European Parliament)

22 Mar 2022 · Discussion on Fit for 55 and REPower EU

Meeting with Elsi Katainen (Member of the European Parliament)

22 Mar 2022 · energiapolitiikka

Finnish Energy calls for urgent clarity on biomass rules

10 Jan 2022
Topic — Updates to the monitoring and reporting rules for emissions from sustainable biomass.
Message — Finnish Energy requests immediate clarification on sustainability criteria to ensure functioning biomass markets. They advocate for moving implementation dates if delays occur and excluding taxation schemes.123
Why — This delay prevents companies from being penalized while waiting for finalized EU rules.45
Impact — Environmental groups lose as delays slow the enforcement of biodiversity and carbon protections.6
Read full response

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

18 Nov 2021

Finnish Energy welcomes the opportunity to comment on the Fit for 55 climate package. We strongly support the EU’s climate targets for 2030 and 2050, and we are also committed to Finland’s carbon neutrality target for 2035. The energy and climate policy initiatives published by the Commission in July set the Europe to the right path towards climate neutrality. Please find our comments here attached.
Read full response

Finnish Energy warns against complex sub-targets and bioenergy rules

18 Nov 2021
Topic — The European Commission is revising the Renewable Energy Directive to meet 2030 climate goals.
Message — The organization demands technology neutrality and the removal of complex sub-targets. They strongly oppose the cascade principle for biomass to prevent regional energy restrictions.12
Why — This would reduce administrative costs and protect the industry's ability to use forest biomass.34
Impact — Environmental advocates lose strict biodiversity safeguards like no-go-areas for sourcing forest biomass.5
Read full response

Response to Revision of the Energy Tax Directive

17 Nov 2021

Finnish Energy welcomes the opportunity to comment on the Fit for 55 climate package. We strongly support the EU’s climate targets for 2030 and 2050, and we are also committed to Finland’s carbon neutrality target for 2035. The energy and climate policy initiatives published by the Commission in July set the Europe to the right path towards climate neutrality. Please find our comments here attached.
Read full response

Response to Updating the EU Emissions Trading System

8 Nov 2021

Finnish Energy welcomes the opportunity to comment on the Fit for 55 climate package. We strongly support the EU’s climate targets for 2030 and 2050, and we are also committed to Finland’s carbon neutrality target for 2035. The energy and climate policy initiatives published by the Commission in July set the Europe to the right path towards climate neutrality. We welcome the Commission’s proposal on the wider use of carbon pricing. The EU ETS is the most cost-effective climate policy instrument, and it guarantees that the decided level of emissions reductions is achieved. Emissions trading is a clear and predictable way for companies to integrate emissions into future economic performance. Please find our comments here attached.
Read full response

Meeting with Anne Funch Jensen (Cabinet of Executive Vice-President Margrethe Vestager)

20 Oct 2021 · Draft State aid Guidelines on Climate, environmental protection and Energy

Response to Restoring sustainable carbon cycles

7 Oct 2021

Finnish Energy welcomes Commission’s initiative and Road Map for developing a long-term vision for sustainable carbon cycles (including capture, storage, and use of CO2) in a climate-neutral EU economy and to kick-start the development of technological and nature-based solutions. We consider this a very welcome and timely initiative. There is urgent need for proper incentives to value the capturing and using CO2. Especially we underline the importance that processes using biomass and waste are properly compensated for carbon capture. We also emphasize that while proceeding with this important initiative, it is important to follow that other initiatives do not conflict nor hinder the economics of CCS and CCU, especially when considering biomass and waste. While sufficient resources for R&D&I continue being utmost important, the European market needs to be created so that companies can proceed from pilots to industrial investments.
Read full response

Meeting with Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans), Riccardo Maggi (Cabinet of Executive Vice-President Frans Timmermans)

30 Sept 2021 · Green Deal implementation

Finnish Energy urges revisions to biomass sustainability verification rules

16 Jul 2021
Topic — The Commission is establishing rules to verify sustainability and emissions saving criteria for biofuels.
Message — Finnish Energy requests including forestry residues in sustainability lists and extending mass balance periods to one year. They also seek a transition period and more flexible auditor requirements.123
Why — These changes would prevent raw material shortages and reduce excessive administrative burdens for operators.45
Impact — Certification bodies may be excluded from the market by unrealistic conflict-of-interest requirements.6
Read full response

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

2 Jun 2021

Finnish Energy welcomes the opportunity to comment on the European Commission’s draft Delegated Act on taxonomy-related disclosures by undertakings reporting non-financial information. Finnish Energy is a branch organisation for the industrial and labor market policy of the energy sector. It represents companies that produce, procure, distribute and sell electricity, gas, district heat and district cooling and related services. Finnish Energy strongly supports the European Commission’s goal of climate neutral Europe by 2050. In fact, Finland has pledged to become carbon neutral already in 2035. The sustainable finance framework has great potential to facilitate investments towards activities that support this goal. We believe that the EU Taxonomy’s main purpose should be to support the transition to climate neutral Europe, and therefore, the Delegated Regulation on taxonomy-related disclosures should contribute to driving investments into carbon-neutral and low-carbon energy sources. We would like to highlight the following in the draft Delegated Act: Entry into force To provide adequate time for companies to properly understand the disclosure requirements and assess the eligibility of their economic activities, not to mention to build the needed reporting systems, we support phased-in reporting and suggest postponing the start of mandatory reporting by one year. Previous five reporting periods Requiring companies to publish the key performance indicators covering the previous five reporting periods constitutes an excessive burden that we do not see to exceed the benefits. At least, the comparative and 5-year information should not be required to report retroactively for the year of adoption. Disclosure of long-term objectives and targets We find that this obligation goes beyond the level 1-legislation (EU Taxonomy Regulation). Furthermore, this obligation as such could lead to disclosing commercially sensitive information and make companies vulnerable to litigation. We suggest that any disclosure that goes beyond the Taxonomy Regulation should be done on a voluntary basis only and companies should have certain flexibility in the way they present additional information. Contribution to multiple objectives The requirement of reporting KPIs for each environmental objective would add additional administrative burden and not be justified for the purpose of the regulation. KPIs should be disclosed on one environmental objective that has been duly chosen to assess significant contribution. Taxonomy eligible and aligned/not-aligned and taxonomy non-eligible activities Taxonomy Regulation only requires undertakings to report on "how and to what extend the undertaking's activities are associated with economic activities that qualify as environmentally sustainable", i.e. is limited to reporting on "Taxonomy-aligned" activities only. We find that the mandatory reporting requirements should be limited to Art. 8 of the Taxonomy Regulation. Otherwise, it would lead to overreporting and also unofficially pave the way for an extended Taxonomy or brown-listing, which would be premature since such an extension has not been formally proposed. Definitions The European Commission should ensure coherence with the European reporting framework and there should be an alignment between EU Taxonomy definitions/guidance and the corresponding guidance under IFRSs to avoid different interpretations. To ensure comparability between companies, more guidance is needed on how to allocate turnover, OpEx and CapEx between compliant and non-compliant activities. OpEx KPI should be disclosed only “where relevant”. Disclosure format We find that some flexibility in the disclosure format, not least as part of the phase-in, should be allowed. Please see our more detailed consultation response attached.
Read full response

Finnish Energy warns EU biomass guidance exceeds legal mandate

27 Apr 2021
Topic — Operational guidance on sustainability criteria for forest biomass under REDII directive.
Message — Finnish Energy demands amendments to ensure the guidance stays within the directive's mandate. They want to remove new definitions and extra administrative requirements.12
Why — This would reduce administrative costs and simplify compliance for local energy producers.3
Impact — Environmental groups lose stronger protections against biodiversity loss and carbon sink depletion.4
Read full response

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

1 Apr 2021

Finnish Energy strongly supports the EU target of carbon neutrality by 2050 and the Commission’s proposal for the climate target for 2030. To reach the objectives of the European Green Deal, it is important that all industries will participate. The energy sector especially plays an important role in this challenge. At the same time, Finnish Energy strongly supports the development of internal market for energy. An EU emission trading scheme together with open and well-functioning energy market should drive carbon neutral investments and phase out emitting technologies. This should be priority in the revision of State aid guidelines and general block exemption rules. By nature, State aid schemes have almost always some impacts to the functioning of market. Therefore, we consider that exemptions from the notification/approval process should be rather limited instead of loosening the existing rules. While we acknowledge that reaching such an ambitious target requires also governmental guidance, the revisal of the General Block Exemption Regulation (GBER) raises concerns. It is mentioned that some changes to these exemptions are needed to reflect EU priorities, specifically the Green Deal. Even though it is necessary to promote the targets of the Green Deal, the end should not justify the means. Therefore, the State aid should not be allowed to cause market distortion even if the result would be favorable for the Green Deal. There are sectors with no technologies currently available for needed emission reductions. Developing new technologies, such as different carbon capture, storage and utilization technologies, hydrogen etc., is essential for reaching the Green Deal targets. State aid is integral for R&D and demonstration of new technologies. The State aid policy should not rule out any technologies which contribute Green Deal targets. To reach carbon neutrality by 2050 requires that all technologies contributing to the target shall be included. On the other hand, there should be a level playing field and no technology should be preferred over another.
Read full response

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

22 Mar 2021

Finnish Energy (FE) believes that the revision of the EPBD should be coherently implemented within the “Fit for 55 Package”. A cost-efficient and technology neutral climate framework based on the EU ETS will prioritise climate action and bring transitions costs down. EU ETS is certain and efficient way to ensure emission reductions and would also minimise the costs for citizens. Therefore, the introduction of emission cap and CO2 price for whole heating sector should be the priority. In the revision of the EPBD, we support the approach focusing on non-regulatory measures (Option 2). This option includes reinforced non-regulatory policy instruments and additional guidance and support measures, such as technical assistance, information campaigns, training, project financing to increase energy renovation rates. FE’s Key messages to the review of EPBD: 1. Promote energy fuel switch from fossil-fuel based heating and cooling technologies to the use of carbon neutral energy or waste heat. • All carbon neutral energy sources and waste heat recovery play a key role in the decarbonisation of the EU building stock. Therefore, they should be treated equally with renewables when it comes to meeting the renewable energy targets for heating and cooling, district heating and cooling and buildings. 2. Ensure equal treatment of on-site and nearby produced and supplied energy, heat and cold. • Neighbourhood, district, and city level approach in decarbonising the heating and cooling sector will create system efficiencies on a larger scale and make more significant impact at a lower price. 3. Emphasise the important role of long-term policy planning tools in the energy transition of buildings. • In particular, national energy and climate plans, resource efficiency and circular economy plans, and long-term renovation strategies. 4. Recognise the need for flexibility in the implementation of national targets for Member States. • In order to define the most cost-efficient policy pathways for the renovation and decarbonisation of the building stock, the EU level measures need to take into account national specificities. • There is a need to adapt the implementation to the specific conditions and priorities of individual Member States with regard to climatic conditions, resource availability, building stock, heating and cooling, and ownership structure. • It should also be recognised that Member States have different approaches to energy poverty. In Nordics, energy poverty is not separated from other types of poverty. These issues are tackled with comprehensive social security system. • Tackling of the energy poverty and social compensations should serve the emission reductions. This can be done, for example, by helping individuals to move from fossil fuels to more sustainable solutions and improving energy efficiency. 5. Highlight the benefits of digitalisation of the buildings and construction sector, demand response and flexibility. • More intelligent building automation and control, automated collection of data, demand response, and flexibility systems are crucial in achieving energy efficient buildings and connecting the buildings smartly to the energy networks (= energy system integration). One tool in promotion of more intelligence to the buildings could be the implementation of the smart readiness indicator (SRI). 6. District heating companies should focus on the customer, improve the level of customer information and transparency. • District heating companies should publish plans for low carbon action / progress, so-called "low carbon roadmaps"; publish prices of heat supply and their components; strengthen disconnection rules for consumers – customers should always have a right to disconnect and swich to alternative heating solutions; maintain close dialogue and co-operation with customers and thus increase the customer confidence while shifting the role from a mere heat distributor to a service provider (”heat as a service”).
Read full response

Response to Revision of EU rules on Gas

10 Mar 2021

Finnish Energy represents the Finnish electricity, gas, and heating sectors, and we have 270 members. We strongly support the EU’s climate targets for 2030 and 2050. We are also committed to Finland’s carbon neutrality target for 2035. Finnish Energy welcomes the proposal to better facilitate infusion of carbon neutral and low-carbon gases as well as hydrogen and synthetic gases based on hydrogen production into the EU energy mix. Finnish Energy’s key principles for EU Hydrogen and Gas Markets Decarbonisation Package include the following: 1. Technology neutrality should be in the core of Commission’s policy proposals to ensure that all carbon neutral gases including synthetic gases fit the market criteria and will have an opportunity to contribute to reach the goals of EU climate targets. • All CO2-neutral electricity should be accepted for clean hydrogen production, including nuclear, hydropower, and bioenergy, and other CO2-neutral electricity being produced into the existing electricity grid. In Finland, 85 % of electricity production was carbon neutral in 2020. • Many hydrogen applications as well production technologies are in the development phase at the moment and need more research and demonstration. Most promising technologies need to be scaled up during upcoming decade. Limiting of technology development at this phase is not beneficial for emission reductions or technology development. 2. Existing low carbon electricity grid and gas infrastructure should be the foundation for developing hydrogen markets. • Only this way hydrogen can be an enabler of full system integration. Electricity market and hydrogen can provide great flexibilities for each other. • Utilising and developing existing grids is essential to minimise costs for companies, citizens, and society and to guarantee just transition. • In case there are no existing gas grids available, off-grid production should have the same equal treatment as grid connected production. 3. Clear legislative principles, preferably by integrating hydrogen into the gas legislation, are relevant for current stage of hydrogen development. • Providing long-term visibility and clarity on as market based as possible policy framework is crucial for companies to make investments. • Role of energy NRAs to implement common cross border regulatory principles throughout the European grid access and operations should be strengthened. • A regional MAM (Market Access Manager) approach should be developed to accommodate problems arising from common cross border gas balance areas e.g. Finland, Estonia, Lithuania. 4. Well-functioning energy markets and carbon pricing through EU ETS are crucial for achieving the EU climate targets, and state aid should not jeopardise competition nor bring distortions to the system. • Safeguards against competition distortions must be put in place, and all temporary support schemes for decarbonisation solutions must be subject to clear sunset provisions. • For all technologies, aid should only be considered at early stages of development. • Eventually, market prices of different energy products and carriers as well as CO2 price should create incentives for investments in hydrogen where it is cost efficient abatement technology.
Read full response

Response to Revision of the guidelines for trans-European Energy infrastructure

8 Mar 2021

Finnish Energy’s views on the revision of the TEN‐E Regulations Finnish Energy (ET), the association representing Finnish companies that produce, acquire, transmit and sell electricity, gas, district heat and district cooling and offer related service, welcomes the revision of Guidelines Trans‐European Energy Networks. We share the Commission’s view on the need for modernizing the regulation by aligning it with the policy objectives of the Green Deal and the Clean Energy Package (CEP) regulatory framework, notably supporting an increased role of DSOs. TEN‐E together with PCI‐framework and CEF‐funding is an important tool to facilitate energy network ‐projects with benefits overarching national borders. Regarding electricity smart grids, we consider that the requirement having TSOs from at least two Member States involved and excluding infrastructure for low‐voltage projects should be re‐considered. These fail to acknowledge that the continuous increase of renewables and electrification, in line with climate and energy targets, does and will require considerable investments in the distribution system’s infrastructure. Also, the same technical criteria as for TSO‐driven projects make these funds for smart grid projects not accessible to most of the DSOs. Also, more local network projects, with broader benefits, needs to be recognized in the regulation. Such can be smart grid projects which provide solutions that are used or can be used more broadly in EU, or network projects which significantly provide for regional secure supply of electricity or gas on a regional, or which significantly provide for reaching European climate targets by enabling emission reductions. Such could be, for example, heat network project connecting more tightly heat and electricity infrastructure together and/or significantly reducing the emission caused by heating needs. Especially companies acting in distribution find the reporting requirements somewhat burdensome. PCIstatus is not considered too helpful for to enable project to proceed, except having access to European financing. Hence, some streamlining in reporting and applying for PCI‐status is foreseen important. We welcome the inclusion of hydrogen and smart gas grids infrastructure. Gas infrastructure is a bridging solution and recognizing the foreseen future with ever‐increasing share of low‐carbon gases and need to update gas grids to fit for purpose is welcome. Hydrogen networks may become important in the future, and it is important to recognize them also in the guidelines. We consider Electrolyser category not fit in the scope of TEN‐E and it needs to be removed. The core of TEN‐E are the energy transmission networks, namely electricity transmission infrastructure. We welcome the explicit stakeholders involvement in the network planning process. The current structure on TYNDPs is still on national plans, and there is a clear need for a more TOP‐DOWN‐ approach. While we agree that offshore‐infrastructure needs more focus, we emphasize that all electricity generation forms need to be treated equally. Offshore must carry its connection costs in the same manner as onshore. We are somewhat hesitant whether new priority corridors for offshore are needed, or whether the already existing priority corridors could be updated to have a stronger focus on offshore. Petteri Haveri (petteri.haveri@energia.fi, +358 50 5711554) Senior Advisor Finnish Energy
Read full response

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

26 Jan 2021 · Finnish energy sector views on the European Green Deal

Response to Climate change mitigation and adaptation taxonomy

14 Dec 2020

Finnish Energy strongly supports the European Commission’s goal of climate neutral Europe by 2050. Finland has pledged to become carbon neutral already in 2035. The sustainable finance framework has great potential to facilitate investments towards activities that support these goals. We believe the Taxonomy’s main purpose should be to support the transition to climate neutral Europe. Since it seems that Taxonomy will be widely used not only in private sector but also within e.g. public sector and EU’s financial programs, it is crucial that taxonomy supports transition to climate neutrality and takes into account all carbon-neutral technologies. This is also a prerequisite for a functioning energy market. Therefore, we regret to see that the draft Delegated Act fails to meet technology neutrality and does not recognize that all carbon-neutral technologies are needed in transition to climate neutrality. Unfortunately, draft Delegated Act simply does not support Commission’s long-term climate strategy and pathways towards achieving carbon neutrality by 2050. Furthermore, draft sustainability criteria create policy instruments through financial sector that are overlapping with existing sectorial legislation and do not consider system-level demands for transition to carbon-neutral society. PLEASE SEE ATTACHMENT FOR OUR COMPLETE RESPONSE AND AMENDMENTS TO DRAFT DELEGATED ACT. Nuclear power: •It is essential to take the necessary time to review these delegated acts so that the evaluation of the whole energy block is completed. •Nuclear power should be included in the sustainable finance scheme by considering all energy sources according to equal principles and sustainability criteria for nuclear power should be created accordingly. The Commission should make sure that the decision on inclusion of nuclear is based on scientific assessment and technological neutrality rather than political views. Hydropower: •All the technologies that are well below the threshold of 100 gCO2eq/kWh should be treated equally and hydropower should be exempted from the life-cycle assessment. •The Do no significant harm (‘DNSH’) criteria for hydropower, especially those for “Sustainable use and protection of water and marine resources” should refer to existing European Union environmental legislation, such as Water Framework Directive. •Hydropower should be added to Section 7.6. Installation, maintenance and repair of renewable energy technologies. Bioenergy: •All renewables technologies should be placed on the same footing and bioenergy be classified as ‘sustainable’ in accordance with Article 10.1(a) of the Taxonomy Regulation. •Further streamlining with the existing legislation (RED II) is needed. •Bioenergy should be added to Section 7.6. Installation, maintenance and repair of renewable energy technologies. •The references to bioenergy in Annex II Section 1.4. should be removed. Manufacture of Hydrogen: •The sustainability criteria for manufacture of hydrogen should be set in accordance with the TEG final report thus resulting in limit of 5.8 tCO2/eqtH2. Gaseous and liquid fuels: •Threshold on life cycle GHG emissions for gaseous and liquid fuels should be based on roadmap that works as an incentive for the gas sector’s decarbonisation. Transmission and distribution of electricity: •All electricity transmission and distribution infrastructure or equipment shall be eligible with except for infrastructure that is dedicated to creating a direct connection or expanding an existing direct connection between transmission or distribution system and a power production plant that is not eligible. •Criterion 2. on calculation of CO2 values shall not be mandatory to fulfil in order of being eligible. Storage of electricity: •All electricity storage technologies, incl. reservoir storage and pumped hydropower, should be categorised as economic activities making a substantial contribution based on their own performance, not only as enabling activities.
Read full response

Response to Revision of the Energy and Environmental Aid Guidelines (EEAG)

10 Dec 2020

Finnish Energy strongly supports the goal of climate neutral Europe by 2050 and the Commission’s proposal for the climate target for 2030. For the energy sector, the climate framework and state aid should provide clarity and long-term certainty. The energy transition needed for the carbon neutrality is mainly an investment challenge. Private funding should have a key role in this, because the scale of needed investments is huge and public funds are rather limited. A cost-efficient and technology neutral climate framework based on the EU ETS will prioritize climate action and help maintaining the competitiveness of Europe. A well-functioning carbon market will also incentivize a continuous increase of renewables and energy efficiency. The main goal should be to strengthen the EU ETS and avoid overlapping national and EU level subsidies. State aid should be more in line with EU ETS system and within EU ETS sector State aid should be granted only for new technology. Improving Europe’s internal market for energy should be in the focus of the revision of the State aid guidelines. An energy market where cross-border energy flows effortlessly will maximise integration of carbon neutral energy, which is essential in the decarbonisation of the EU economy. The State aid should be regulated so that the harm caused to the energy and emission markets is minimized. Red line should be that mature electricity production investments should not be subsidised in future. Giving clear schedule for the phase out of subsidies, would significantly improve functioning energy market. When aiming at carbon neutrality, big emission reductions are needed in transport, industry and heating sectors. There are sectors where there is no technology commercially available for needed emission reductions. Therefore, it is essential to develop new technologies, such as different carbon capture, storage and utilization technologies, hydrogen, nuclear, smart energy networks and production technologies as well as integrate the energy system. Therefore, public funding should focus on the R&D and demonstration phase of technologies. Especially currently due to the covid-19 pandemic, it is tempting to support national electricity production, even with mature technologies, through State aid or upcoming RRF. However, such measures shall be avoided. In short-term, it is possible speed up many new investments with public funding, but in the long run those slow down the market-based investments. When there will be public subsidies for electricity production, the information about these should be available for market actors as early as possible. Information is crucial for the investors planning market-based investments in carbon neutral electricity production, but also project developers planning to invest based on State aid. At the same time, there should be a very clear vision about the phasing out of the possible subsidies. For instance, because of technology development and reduced production costs renewable energy has become much more competitive within the past years. The need for financial support has decreased significantly. This should be considered as well. When State aid schemes are at place, they should be technology neutral and established in a way that all renewable and carbon neutral technologies could participate into the scheme or competition. Production technologies have different roles as well as strengths and weaknesses in the energy system and market. It should be up to market actors to decide which technologies the market and the system needs and where to invest. The climate challenge is global, and the EU is committed to create and implement climate policy together as a continent. For this reason and for the sake of the internal market, the EU should steer Member States to regional and cross border co-operation in the field of State aid. This could increase competition within subsidy schemes and bring needed State aid levels down.
Read full response

Response to EU Forest Strategy

4 Dec 2020

Finnish Energy (FE), the association representing Finnish companies that produce, acquire, transmit and sell electricity, gas, district heat and district cooling and offer related service, thanks for the possibility to provide feedback on the Roadmap for the EU Forest Strategy. Finnish Energy supports the Commission’s target to make Europe the first climate neutral continent in the world by 2050 and highlights that the climate framework should provide clarity and long-term certainty when reaching the target. That in mind, we support the need for a comprehensive Forest Strategy in order to reach coherence between sectoral policies affecting the use of forests. The Commission should build on the good foundation set with the views of the European Parliament (European Parliament Resolution 8 October 2020) and Member States (Council conclusions 11 November 2020) on the Forest Strategy. The holistic approach to address forests and their multifunctionality that both these institutions are calling for, is something Finnish Energy also stands for, as well as respecting the distribution of competences between the EU and Member States. FE proposes to highlight the following aspects in the strategy: • Increasing number of policies is affecting forests and the forest sector in the EU, while at the same time forest policy falls under national competence of the Member States. EU Forest Strategy should be the key tool to make policies impacting forests work in the same direction and help to bridge national policies and forest-related EU policies. It should create an enabling framework of conditions that does not hamper the implementation of sustainable forest management at national level, and therefore it is important to prepare the EU forest strategy in wide cooperation between different DGs, Member States and stakeholders. • EU Forest Strategy should build on Sustainable Forest Management (SFM) of EU’s forests. SFM is the ground for the strategy and it is vital that all different aspects of sustainability are properly considered in a balanced way. • As the strategy is joint for all of Europe, the different natural conditions, challenges, and traditions regarding the use of forests in different parts of Europe should be recognized. This is particularly important when considering the role of forests in the forested regions of Europe. The forest strategy should be built on facts, including national statistics of forests and their use. • The substitution effect should be acknowledged in the EU’s Forest Strategy, not only on the side of substituting products but also as substituting fossil fuels, as sustainable bioenergy plays a significant role in achieving EU’s climate neutrality goals in the future. Without the sustainable use of forestry residues and waste wood for bioenergy there is no way to achieve the goals set in the Green Deal.
Read full response

Response to Land use, land use change and forestry – review of EU rules

26 Nov 2020

Finnish Energy welcomes the Commission’s preliminary thoughts on the content of the impact assessment and policy options. In addition to those, Finnish Energy calls for the market creation for carbon removals and clarification the use of international units. Carbon removal technologies (CRT) are important in a post-Paris world (IEA 2016 CCS report). The revision of the climate policy framework is a great opportunity to clarify incentives for CRT and market mechanism (Article 6 in Paris Agreement). If market for CRT is done via the LULUCF, link to the EU ETS needs to be assessed. Waste incineration (WI) should be assessed as a part of waste treatment and circular economy. The main purpose of WI is to treat waste and therefore waste-to-energy (WtE) plant can’t switch fuels. At this moment, the most efficient route to decrease ghg emission of WtE plants, seems to be CCS/CCU and more efficient recycling (in line with waste directive). The Commission should assess the option where WtE is included into the LULUCF (AFOLU + waste treatment). Finnish Energy is the voice of over 260 member companies that produce, acquire, transmit and sell electricity, district heat and district cooling and offer related services. Finnish Energy supports the EU’s net-zero carbon emissions goal by 2050 and an increased ambition towards at least a 55% target GHG reductions by 2030. Finnish electricity supply is already well underway towards climate neutrality before 2030. The emissions of electricity and district heating have decreased by 60 % in last 15 years. In next 15 years ghg emissions reduction will be over 90 %. To achieve this all energy sources to be available. The EU must ensure the availability of nuclear, bioenergy and hydro power.
Read full response

Response to Updating Member State emissions reduction targets (Effort Sharing Regulation) in line with the 2030 climate target plan

26 Nov 2020

Finnish Energy welcomes the Commission’s preliminary thoughts on the content of the impact assessment and policy options. We would like to highlight the following points to consider: 1. Carbon removal technologies (CRT) are important in a post-Paris world (IEA 2016 CCS report). The revision of the climate policy framework is a great opportunity to clarify incentives for CRT and market mechanism (Article 6 in Paris Agreement). If market for CRT is done via the ESR, link to the EU ETS needs to be assessed. CRT needs public support and this can be done in different ways, e.g.: a. state aid or the EU funding, b. market creation into the ESR: shared CRT quota for member states, c. market creation into the EU ETS: CRT units may lead the decreasing amount of auctioned allowances (income to MS). 2. The 2030 climate target plan indicates several changes for the EU ETS sector. The EU ETS should be extended to the new sectors, but cross-sectional impacts need to be carefully assessed. In the worst case heating and transport are regulated via the EU ETS, ESR (national plans) and RED/EED. 3. When assessing the means to speed up emission reductions in heating and transport, it should be noted that the data for the price elasticity of demand is quite old. For example, a report in June 2020 referred to the data from 1993 to 2008. Options in heating and transport have diversified after that. 4. Waste incineration (WI) should be assessed as a part of waste treatment and circular economy. The main purpose of WI is to treat waste and therefore waste-to-energy (WtE) plant can’t switch fuels. At this moment, the most efficient route to decrease ghg emission of WtE plants, seems to be CCS/CCU and more efficient recycling (in line with waste directive). The Commission should assess the option where WtE stays in the ESR or is included into the LULUCF (AFOLU + waste treatment). Finnish Energy is the voice of over 260 member companies that produce, acquire, transmit and sell electricity, district heat and district cooling and offer related services. Finnish Energy supports the EU’s net-zero carbon emissions goal by 2050 and an increased ambition towards at least a 55% target GHG reductions by 2030. Finnish electricity supply is already well underway towards climate neutrality before 2030. The emissions of electricity and district heating have decreased by 60 % in last 15 years. In next 15 years ghg emissions reduction will be over 90 %. To achieve this all energy sources to be available. The EU must ensure the availability of nuclear, bioenergy and hydro power.
Read full response

Response to Updating the EU Emissions Trading System

25 Nov 2020

Finnish Energy welcomes the Commission’s preliminary thoughts on the content of the impact assessment for the EU ETS revision. We would like to highlight the following points to consider: 1. Carbon removal technologies (CRT) are important in a post-Paris world (IEA 2016 CCS report). The revision of the climate policy framework is a great opportunity to clarify incentives for CRT. If CRT is incentivized via the EU ETS, the MSR and other parameters have to assess in order not to undermine the emission reductions. If market for CRT is done via the ESR, link to the EU ETS needs to be assessed. CRT needs public support and this can be done in different ways, e.g.: a. state aid or the EU funding, b. market creation into the ESR: shared CRT quota for member states, c. market creation into the EU ETS: CRT units may lead the decreasing amount of auctioned allowances (income to MS). 2. The 2030 climate target plan indicates several changes for the EU ETS sector. The EU ETS should be extended to the new sectors, but cross-sectional impacts need to be carefully assessed. In any case, the EU ETS must be strengthened for policy overlaps and unforeseen external events. 3. If the overlapping policy is needed in new sectors, policy should be designed to speed up the transition in the consumption side. When assessing the means for this, it should be noted that the data for the price elasticity of demand is quite old. For example, a report in June 2020 referred to the data from 1993 to 2008. Options in heating and transport have diversified after that. The Commission should also assess the significance of the predictable EU ETS price signal for the development of a common European technology and services market (compared to the situation, where climate policy is driven by 27 national action plans). 4. Waste incineration (WI) should be assessed as a part of waste treatment and circular economy. The main purpose of WI is to treat waste and therefore waste-to-energy (WtE) plant can’t switch fuels. At this moment, the most efficient route to decrease ghg emission of WtE plants, seems to be CCS/CCU and more efficient recycling (in line with waste directive). Finnish Energy is the voice of over 260 member companies that produce, acquire, transmit and sell electricity, district heat and district cooling and offer related services. Finnish Energy supports the EU’s net-zero carbon emissions goal by 2050 and an increased ambition towards at least a 55% target GHG reductions by 2030. Finnish electricity supply is already well underway towards climate neutrality before 2030. The emissions of electricity and district heating have decreased by 60 % in last 15 years. In next 15 years ghg emissions reduction will be over 90 %. To achieve this all energy sources to be available. The EU must ensure the availability of nuclear, bioenergy and hydro power.
Read full response

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

21 Sept 2020

Finnish Energy, the association representing Finnish companies that produce, acquire, transmit and sell electricity, gas, district heat and district cooling and offer related service, thanks for the possibility to give feedback to the roadmap for the impact assessment on the review of EED. Finnish Energy supports commissions target to make Europe the first climate neutral continent in the world by 2050 and agrees on the role of energy efficiency on helping to achieve the target. We are happy to notice that commission is willing to evaluate whether the framework of the EED is fit to overcome remaining regulatory and non-regulatory barriers, and market failures, which do not allow energy efficiency to be fully part of the energy systems. As said previously on the consultation response of the EU 2030 Climate Target Plan, we however do not support the rapid recast of RED or EED. Both these directives include detailed demands which affect directly to current investments. The climate framework should provide clarity and long-term certainty when reaching the 2050 carbon neutrality target. Now planned revision of EED comes immediately after the national implementation, which is now still ongoing, and there is yet no valid data on the effects the revised directive has. Finnish Energy has given a national climate pledge, in which we endorse Finnish Government's efforts to make Finland carbon neutral by 2035. We have committed to foster climate and energy policy, which halves the GHG current emissions from electricity and district heating by 2030 and the renewables and energy efficiency already have an important role on achieving this goal. When some of the actions proposed in several initiatives, strategies (for example Energy System Integration Strategy and the Renovation Wave) and plans that have been adopted or will be adopted under the EGD, bring up the need to revise EED, revision should only be made to necessary parts or amendments. Additional information: Sirpa Leino, senior advisor, sirpa.leino@energia.fi Finnish Energy
Read full response

Finnish Energy warns against rapid renewable energy rule changes

18 Sept 2020
Topic — This consultation explores updating renewable energy rules to align with 2030 climate targets.
Message — Finnish Energy opposes a rapid recast of the directive to maintain long-term certainty for existing investments. They suggest focusing on implementing current biomass sustainability criteria instead of introducing new regulations. Furthermore, they argue that nuclear energy should be included as a CO2-free source in the energy strategy.123
Why — This would provide the necessary regulatory stability to protect current energy sector investments.4
Impact — Environmental organizations lose more precise biodiversity protections regarding the usage of whole trees.5
Read full response

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

8 Sept 2020

Finnish Energy welcomes the opportunity to comment on the European Commission’s inception impact assessment on the proposed Delegated Regulation on taxonomy-related disclosures by undertakings reporting non-financial information. Finnish Energy is a branch organisation for the industrial and labor market policy of the energy sector. It represents companies that produce, procure, distribute and sell electricity, gas, district heat and district cooling and related services. Finnish Energy strongly supports the European Commission’s goal of climate neutral Europe by 2050. The sustainable finance framework has great potential to facilitate investments towards activities that support this goal. We believe that the EU Taxonomy’s main purpose should be to support the transition to climate neutral Europe, and therefore, the Delegated Regulation on taxonomy-related disclosures should contribute to driving investments into carbon-neutral and low-carbon energy sources. The Commission evaluates that to comply with this delegated act, the undertakings under the scope of the NFRD are expected to face additional costs in collecting, organising and disclosing taxonomy-relevant information. In the case of SME’s the Commission sees that there might be indirect impacts and possible extension of scope of the NFRD might have an impact on the current initiative, including SMEs. We would like to express our concerns. At the current difficult economic situation, we find that any additional administrative burden, unnecessary reporting obligations and additional costs for companies should be avoided. Especially in the case of SMEs these elements may induce real challenges and therefore the scope of reporting non-financial information should not be extended. We understand that this initiative aims to increase the harmonisation of information that investors and other economic actors can access and use. We would like to point out that reporting on material issues is the key principle in sustainability and non-financial reporting. It is important to allow companies to assess whether a topic is material, i.e. relevant to their business overall. What is considered a material topic will be different from one company to another, even within a sector. It is important to respond to the growing demand for data and information from investors and other stakeholders. However, when assessing whether non-financial reporting practices meet certain objectives, it should be based on justified needs of stakeholders rather than expectations that can create additional reporting burdens for companies without real added value. Therefore, non-financial reporting requirements should be complemented with a sense of proportion about (company) relevant non-financial information. Further, it is important to note that 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.
Read full response

Response to Union renewable Financing mechanism

3 Jun 2020

Finnish Energy (FE) thanks for the possibility to give feedback to the draft for the commission implementation regulation on the Union renewable energy financing mechanism. Electricity producers and investors need a long-term view on market development The EU Emission trading scheme (EU ETS) should be the primary, and ideally the only instrument to steer CO2-emmissions of electricity production. The main goal should be to strengthen the EU ETS and avoid overlapping national and EU level policies. Partially due to the COVID 19, electricity prices are slumped and the uncertainty of investors has increased. For the same reason, the profitability of the electricity production is threatened. Flooding the electricity market with new public subsidies would cause more uncertainty to the market and should therefore be avoided. In short term, it is possible to have many new investments with public funding, but in the long run they slow market-based investments down and are harmful. If there will be public subsidies for electricity production, the information about these should be available for market actors as early as possible. There are many reasons for this. Information is important for the investors who plan market-based investments in renewable electricity production, but also project developers planning to invest based on state aid. State aid schemes should be technology neutral State aid schemes should be technology neutral and established in a way that all renewable technologies could participate into the scheme or competition. Different production technologies have a different role as well as strengths and weaknesses in the energy system and market. It should be up to market actors to decide which technologies the market and the system needs and where to invest. Policy makers should create a level playing field and a smooth investment framework for all different renewable technologies. Despite the new mechanism allowing technology neutral state aid, it is still our concern that in practice different renewable technologies and sectors are not in level situation when competing state aid. EU funding should not encourage to new national subsidies National subsidies and policies are harmful for the development and efficient functioning of the common electricity market. National subsidies individualize member states when they compete investments with subsidies. Therefore, this kind of EU-level state aid scheme is welcomed, but only when it replaces national subsidies and schemes. At the same time structure and financing of this new mechanism should not encourage to creation of new national schemes. The mechanism should be as market based as possible It is important that state aid respects market principles. Investors must be exposed to the market price of electricity. Even subsidized investors must carry market risks. State aid should not hedge their production or remove producers balance responsibility or other obligations. There are many sectors which need focus Cap filling is the main reason for the introduction of the mechanism. In future, it is good to remember that electricity production is just one sector which can fill the cap. Now the mechanism allows state aid to other sectors (heating and transport) as well. At the next phase, it is important to evaluate how well suited the mechanism is for them. Research, development and demonstration When aiming at carbon neutrality, big emission reductions are needed in transport, industry and heating. It is essential to develop new technologies, like different carbon capture, storage and utilization technologies, hydrogen, smart energy networks and production technologies as well as integrate the energy system. Therefore, public funding should focus on the R&D and demonstration phase of technologies. The long-term target should be the phase out of state aid for mature technology. Additional information: Antti Kohopää, antti.kohopaa@energia.fi, +358 50 344 9265
Read full response

Meeting with Helena Hinto (Cabinet of Commissioner Kadri Simson), Laure Chapuis (Cabinet of Commissioner Kadri Simson) and Energiföretagen / Swedenergy

24 Apr 2020 · climate ambition, sustainable financing

Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans) and Energiföretagen / Swedenergy and Nordenergi

24 Apr 2020 · Green deal, taxonomy, carbon pricing

Response to Climate change mitigation and adaptation taxonomy

20 Apr 2020

Finnish Energy strongly supports the EC’s goal of climate neutral Europe by 2050. We believe that the Taxonomy’s main purpose should be to support the transition to climate neutral Europe, and therefore, Taxonomy should be aligned with the Commission’s long-term climate strategy and pathways towards achieving carbon neutrality by 2050. We call the future Taxonomy process to: • Provide clarity and predictability through a stable policy framework. This is needed to achieve a successful economic and industrial transition to long-term sustainability, at the same time ensuring the security of supply. Taxonomy should not create overlapping criteria but consider the existing definitions and classifications in climate related legislation. • Provide objectivity and technological neutrality. The EU long-term strategy underlines that carbon neutrality by 2050 is achievable through efficient use of all available technologies. In accordance, the classification of sustainable activities in Taxonomy should be technology neutral, including all activities that genuinely contribute to reducing GHG emissions. • Involve industry expertise. This is important in order to establish a fit for purpose regulatory framework to trigger the necessary investments to finance the energy transition. The energy industry should be effectively represented within the Sustainable Finance Platform. EC should swiftly appoint an expert group of scientifically qualified nuclear experts to finalise the assessment of nuclear energy under the Taxonomy during 2020 in order to guide the adoption of the Delegated Acts. • Assess the impact of the screening criteria before finalising the Taxonomy, in line with the agenda of Better Regulation. • To avoid any ‘brown’ listing that could label the industry. • Include nuclear power and Waste-to-Energy in the sustainable finance scheme by considering all energy sources according to equal, technology neutral, principles. Including nuclear power in the sustainable finance scheme is indispensable in order to achieve climate neutrality. Demand for clean electricity is growing fast and nuclear power is enabling the decarbonisation of other sectors. Financing must be secured for maintenance, lifetime extensions of the existing nuclear fleet and new construction. Nordic nuclear power most certainly meets the sustainability criteria. The first final waste repositories are under construction in Finland and Sweden. Waste-to-Energy contribution to EU sustainability needs to be properly assessed by the Sustainable Finance Platform, not only in the case of non-recyclable hazardous waste but also for waste that cannot be re-used or recycled and would be otherwise landfilled. TEG’s report could potentially threaten the gas sector’s transition to climate neutrality by 2050. The emission limit of 100 gCO2/kWh is significantly stricter than the limit adopted by the EIB, 250 gCO2/kWh. The GHG saving requirement for bioenergy in the final TEG report is not in line with RED II. The report also narrows sustainable feedstock for bioenergy to those listed in Part A of Annex IX of Directive (EU) 2018/2001 that differs significantly from the sustainability definitions in RED II. Hydropower in EU is far below the limit of 100 gCO2/kWh and in our opinion all existing hydropower facilities within EU should be exempted from conducting LCA and for new hydropower WFD should be followed. No special requirements should be made for small hydropower that can provide flexibility and storage services to the electricity system. We strongly believe that all electricity transmission and distribution infrastructure or equipment shall be eligible without any burdensome and unnecessary reporting concerning whether the system is on a trajectory to full decarbonisation. The definition of waste heat in TEG’s table 4.25 should refer to existing definition in RED II that includes other sources of waste heat than only industry. Please, attached a more detailed analysis.
Read full response

Response to 2030 Climate Target Plan

15 Apr 2020

Finnish Energy represents 260 companies that produce, acquire, transmit and sell electricity, district heating and cooling, and offer related services. Our vision is to make Finland carbon neutral. Finland’s energy system is already on top of many sustainability indicators, with a high share of renewables, low emissions, affordable prices for the customers and a good level of security of supply. With our advocacy, we aim to speed up the shift to a fully sustainable energy future. Finnish Energy supports net-zero emissions target for the EU by 2050 and setting target for 2040. The climate framework should provide clarity and long-term certainty of the 2050 carbon neutrality target and maintain the Emissions Trading System as a central instrument. Therefore, the impact assessment should address the reality of political processes and help to find the most effective way to increase the climate target for 2030. The assessment should especially analyse whether there is a need and time to open all climate regulation (e.g. RED, EED) or should the Green deal focus on the ETSd and ESR.
Read full response

Response to Revision of the Energy Tax Directive

1 Apr 2020

Finnish Energy (FE) thanks for the possibility to give feedback to the Inception Impact Assessment. FE supports the EU to restructure the Community framework for the taxation of energy products and electricity. The existing directive is in many ways outdated as it is from the year 2003 and does not recognize the current climate and energy policy objectives and measures. In the Inception Impact Assessment, the Commission recognizes many relevant questions. Some of which we would like to highlight and add. Please find an attached memo, which opens following aspects: - Harmonization of energy taxation would benefit the internal market as a whole - Systemic challenges need systemic and integrated policy tools. Therefore, focus should be in the relation of different policy instruments, specially taxation and emission trading scheme. - Technology development challenges energy taxation and should be considered in the development of tax regime - Uniform and comparable methodology for tax related fossil fuel subsidies is needed when discussed on the topic - Electricity is fuel for emission reductions and key for coupling different sectors. - State aid question will rise together with the market integration and there shdoul be link between revision of state aid rules and energy taxation directive. The goal of the review process should be the creation of a more efficient, harmonized and fair tax framework. The revised energy taxation directive should minimalize market distortions to emissions trading and to the internal energy market. In the future, the energy taxation directive should support the ongoing energy transition.
Read full response

Response to Carbon Border Adjustment Mechanism

20 Mar 2020

Taking care of competitiveness and avoiding emissions to slip outside of Europe are relevant concerns. Carbon leakage takes place also in the electricity sector, for example between Finland and Russia, as imported electricity carries no cost of carbon. One option is to introduce a Carbon Border Adjustment to place a carbon price also on imported products. The aim of European policy in this area should be to encourage its partners to develop their climate policy instruments towards a more global coverage of carbon pricing. For to promote market-based, competitive and transparent solutions, all imported electricity should be sold through common European market platforms instead of bilateral contracts. This also ensures that the origin of electricity can be reliably traced.
Read full response

Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans) and Green Power Denmark and

4 Mar 2020 · Green Deal priorities

Response to Climate Law

4 Feb 2020

Finnish Energy is in favor of setting intermediary targets to lay a linear path towards net-zero emissions by 2050. For us, the most important elements of the climate framework are the clarity and certainty of the 2050 carbon neutrality target as well as confidence in the Emissions Trading System to remain a central policy. We also support the aim to make the climate policy in technology neutral and cost-efficient manner and ensure the competitiveness of the economy. Certainty on the commitment to a net-zero target can be increased by passing a law. The critical part, however, is in the implementing acts. A key question is how to allocate the reduction efforts to the three sectors, but also how the changes will be made in the future. It is not cost-efficient for the carbon market, if the targets for renewables and energy efficiency take us already further than our emission target demands. We recognize that during the past five years the urgency of climate action has become even more tangible whereas the cost of renewable energy has decreased remarkably. Targets for renewables and energy efficiency should remain at current levels and the option to continue with a single climate target post-2030 should be explored. The efforts and costs should be borne by all sectors, within and outside the ETS.
Read full response

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

19 Dec 2019 · Discussion on sector integration and decarbonization of the Finnish energy system

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

20 Mar 2019 · Market design

Meeting with Telmo Baltazar (Cabinet of President Jean-Claude Juncker)

15 Mar 2019 · Energy Union

Meeting with Risto Artjoki (Cabinet of Vice-President Jyrki Katainen)

14 Mar 2019 · EU Climate policy

Meeting with Ruth Paserman (Cabinet of Commissioner Marianne Thyssen)

15 Oct 2018 · European employment policy and Social Dialogue

Response to Strategy for long-term EU greenhouse gas emissions reductions

19 Jul 2018

A new strategy for long-term greenhouse gas emissions is warmly welcomed by Finnish Energy. We represent 260 energy sector companies in Finland and our aim is to make Finland carbon neutral. Our five key asks for the future of EU climate and energy policy are: 1. Clarify the long term ambition of emission reductions 2. Use a strong carbon price to speed up emission reductions 3. Focus on decarbonising heating and transport 4. Utilise markets to promote renewables and energy efficiency 5. Set a level playing field and enabling data regulation to foster new energy services Please find more details on our beyond 2030 policy messages in the attachment.
Read full response

Meeting with Jyrki Katainen (Vice-President)

23 Mar 2018 · Future of Europe, economy and growth and investments

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

13 Dec 2017 · future of energy + climate policy

Response to Fitness Check of the Water Framework Directive and the Floods Directive

17 Nov 2017

Finnish Energy, representing just under 250 Finnish energy companies, welcomes the fitness check of the Water Framework Directive. We are very supportive of the approach to have quantitative assessments of actual costs and benefits including impact on businesses. Many businesses and other parts rely on electricity from hydropower and that perspective also needs to be taken into account. In any evaluation of the Water Framework Directive an analysis of the harmonisation with the various legislative EU initiatives regarding renewables and climate is necessary. Since in order for the EU to reach the renewable and climate target a significant contribution is needed from Europe’s hydropower plants. We therefore also think it is of outermost importance that the work of the European Commission on the Water Framework Directive is coordinated between the Directorate-General for Environment and for Energy.
Read full response

Meeting with Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen) and Eurelectric aisbl and ENEL SpA

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

Response to EMIR Amendment

29 Jun 2017

Finnish Energy welcomes Commission’s proposals on amending Regulation (EU) No 648/2012. We support the suggested changes that alleviate the reporting responsibilities and clearing obligation responsibilities of NFCs. According to the proposal double-sided reporting would be simplified by transferring reporting responsibility to the CCP and financial counterparty. In addition, non-financial companies would not need to report intragroup transactions or historic transactions. NFCs would clear only the asset classes for which they have breached the clearing threshold and the hedging exemption used in the calculation of clearing thresholds would be sustained. Also, companies would need to assess their situation vis-à-vis the clearing obligation only once a year. We find these alleviations beneficial since these obligations have unnecessary or disproportionate burden on those counterparties which do not pose significant risks to financial stability –e.g. energy companies that use derivatives mainly in hedging purposes. Commission could however take the initiative even further by turning all the reporting into one-sided as is the case in the USA and Switzerland. We find important that the hedging exemption for non-financial counterparties in calculation of the clearing threshold will be kept unchanged as the Commission has proposed. The European Securities and Markets Authority has mentioned the option of deleting the hedging exemption and increasing the relevant thresholds. Removing the hedging exemption from EMIR would not simplify the regulatory obligations for non-financial counterparties who will remain obliged to consider the exact same hedging exemption under the framework of MiFID II (RTS 20 (Art. 5) and RTS 21 (Art. 8)). The EMIR review provided an opportunity for the Commission to revisit the issue of bank guarantees. Hence, Finnish Energy is disappointed that the Commission did not consider continuing the use of bank guarantees even though the issue was actively discussed during EMIR review and consultation period. Article 46 of EMIR allows the use of bank guarantees as collateral by non-financial clearing members and does not require posting of further collateral. In contrast, the Delegated Regulation No 153/2013 required that bank guarantees are backed 100% with liquid assets, which made bank guarantees in practice not usable for wholesale energy market participants who would need to free this liquidity and hold such liquid assets. The Commission could state more clearly that bank guarantees without full backing are indeed allowed according to Regulation No 648/2012 by adding wording “non-fully backed” to Article 46. As a response to risk exposure, the current obligation is disproportionate and leads to deteriorated liquidity and transparency –against the objectives of EMIR. The overall effect of disallowing bank guarantees has been modest so far, but during high interest rates, the trading costs will increase significantly and the effects will become more visible. Already several smaller market participants have withdrawn from the market (app. 15%, 30 small- to midsize members of Nasdaq Commodities) and reverted to bilateral trading outside transparent and supervised venues and CCP clearing. Another highly negative impact from the removal of bank guarantees is that the liquidity has suffered as participants do not wish to take on large positions anymore as the margin calls and associated costs by posting cash have increased. This means that market participants actively choose not to manage their risk to the same extent as before. From the perspective of systemic risk, the changes have been clearly negative. Historically, exchange members have held a direct relationship with the Clearinghouse, now even the largest members are behind General Clearing Member “GCM” banks. This has led to a significant rise in concentration risk, where if one major GCM bank would fail a major part of the market would be impacted.
Read full response

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

21 Jun 2017 · energy policy developments

Meeting with Jyrki Katainen (Vice-President) and Confederation of Finnish Industries EK and

11 May 2017 · Future outlook of the Energy Union package

Response to Commission Regulation establishing a guideline on electricity balancing

19 Dec 2016

Article 5 Approval of terms and conditions or methodologies of TSOs - We have worries regarding the timelines and the consistency of the proposed timings. It is important that there is enough time for the stakeholders to procure the needed IT-systems with sufficient public consultations and according to the procurement laws. Hence, instead of proposing a strict time in regulation, it might be more appropriate for many of the requirements, that TSOs make a proposal for the implementation timeline and regulators approve it. Article 20 European platform for the exchange of balancing energy from replacement reserves - We have concerns that the requirement for starting with European platforms might be too ambitious and lead to delays. We propose for a more practical approach and that the requirement in regulation requires TSOs first to constitute a set of standard products and to ensure regional platforms (which to some extent already exist). Article 55 Imbalance settlement period - It is unclear, whether this sort of requirement can be proposed in a delegated act. Our main concern is however the proposal for a very short implementation period, which undermines the needed changes in metering-, IT-, and commercial infrastructures. Further, as this change would affect all citizens, we find it utmost important, that the NRAs have a possibility to assess whether a longer implementation period would be needed. Hence, we propose a new wording for the article: Article 55 Imbalance settlement period 1. By seven years after entry into force of this Regulation, all TSOs shall apply imbalance settlement periods of 15 minutes in all control areas while ensuring that all boundaries of market time unit shall coincide with boundaries of imbalance settlement periods. 2. Each regulatory authority may issue a reasoned decision for an extension concerning the entry into force requirement in paragraph 1. Where the extension decided is longer than three years, the regulatory authority shall perform a cost-benefit analysis concerning the harmonisation of the imbalance settlement periods within and between synchronous areas in cooperation with the Agency. 3. The TSOs of a synchronous area may jointly request an exemption from the requirement in paragraph 1. The relevant regulatory authorities shall issue a reasoned decision concerning the request for the exemption in accordance with ‎Articles 5(3) and 55 (2).
Read full response

Meeting with Marlene Madsen (Cabinet of Vice-President Jyrki Katainen)

10 Nov 2016 · Labour market

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

20 Sept 2016 · energy efficiency

Meeting with Kaius Kristian Hedberg (Cabinet of Commissioner Elżbieta Bieńkowska), Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska) and Finnish Forest Industries Federation (Metsäteollisuus ry)

29 Apr 2016 · Large Combustion Plant

Meeting with Aura Salla (Cabinet of Vice-President Jyrki Katainen)

26 Apr 2016 · topical EU issues and energy policy in general

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

7 Apr 2016 · energy market legislation

Meeting with Heidi Jern (Cabinet of Vice-President Jyrki Katainen)

4 Jun 2015 · Investment plan

Meeting with Heidi Jern (Cabinet of Vice-President Jyrki Katainen)

26 Mar 2015 · Investment package