GEN-I, trgovanje in prodaja električne energije, d.o.o.
GEN-I, d.o.o.
ID: 145604632964-90
Lobbying Activity
Response to Review of Directive 2012/27/EU on energy efficiency
21 Sept 2020
The GEN-I Group welcomes the European Commission's initiative, via the European Green Deal, to increase the EU's climate ambition for 2030 and thereby accelerate also the deployment of renewable energy, in particular as it affects the potential for active consumer empowerment through renewables self-consumption. In view thereof, the newly proposed 55% emissions reduction target, as per the Communication on “Stepping up Europe’s 2030 climate ambition Investing in a climate-neutral future for the benefit of our people” (COM(2020) 562 final) necessitates significant acceleration of renewable energy and renewables self-consumption deployment, the integration of which will require distribution system operators to make use of all available decentralised flexibility sources, in particular those provided by active consumers.
In this regard, from the options proposed in the public consultation on the Combined Evaluation Roadmap / Inception Impact Assessment for the review of the Energy Efficiency Directive, Option 3 (revision of the EED) is absolutely necessary, not only to address the identified gaps and shortcomings but to place appropriate focus on realisation of network infrastructure efficiency improvement potentials as have been identified under article 15(2) of the Energy Efficiency Directive (or, where the required assessments have not been performed, to ensure they are also carried out). While such improvements may be considered and incentivised through the provisions of article 32 of the Directive 2019/944 on common rules for the internal market for electricity, such enabling measures will not be sufficient to motivate network operators to improve system flexibility, and will thereby reduce the otherwise significant contribution that active consumers can provide to the clean energy transition.
In GEN-I, d.o.o.’s view, such realisation can be ensured only through a legally binding, mandatory policy target for a minimum share of network efficiency, to be achieved through market-based procurement of flexibility by distribution system operators, which is necessary not only from a technical perspective but also to create a market framework that will appropriately reward and incentivise consumers who wish to empower themselves to become active (and potentially renewable self-) consumers. Of course, such policy targets must also be accompanied by necessary enabling measures, which would necessarily form part of a comprehensive policy package that would catalyse a virtuous cycle of consumer empowerment through active renewables self-consumption, both individually and collectively, and would thereby put the European Green Deal firmly in the hands of every European citizen. A more detailed description of such a policy package is enclosed.
Read full responseResponse to Revision of the Renewable Energy Directive (EU) 2018/2001
21 Sept 2020
The GEN-I Group welcomes the European Commission's initiative, via the European Green Deal, to increase the EU's climate ambition for 2030 and thereby accelerate also the deployment of renewable energy, in particular as it affects the potential for active consumer empowerment through renewables self-consumption. In view thereof, the newly proposed 55% emissions reduction target, as per the Communication on “Stepping up Europe’s 2030 climate ambition Investing in a climate-neutral future for the benefit of our people” (COM(2020) 562 final) necessitates significant acceleration of renewable energy and renewables self-consumption deployment.
In this regard, from the options proposed in the public consultation on the Inception Impact Assessment for review of the Renewable Energy Directive, option 5 – which combines options 2 (non-regulatory measures), 3 (raising the ambition level of the REDII targets and subtargets in line with the 2030 Climate Target Plan), and 4 (amend REDII to translate into legal measures the actions proposed in other energy strategies of the EGD) – is the only reasonable starting point, whereas a far more ambitious direction is needed. Such an ambitious direction is outlined in the European Commission’s Impact Assessment accompanying the aforementioned Communication (SWD(2020) 176 final), in particular in Option RES_4: High intensification of RES policies, with a stronger emphasis on “capacity building schemes to implement renewable energy communities financed by the EU and self-consumption models enabling higher consumer uptake and faster development of decentralised renewable energy technologies“ (as per Option_3: Moderate intensification).
In the GEN-I Group’s view, such an ambitious direction should take the form of legally binding, mandatory policy targets and enabling measures, which would necessarily form part of a comprehensive policy package that would catalyse a virtuous cycle of consumer empowerment through active renewables self-consumption, both individually and collectively, and would thereby put the European Green Deal firmly in the hands of every European citizen. A more detailed description of such a policy package is enclosed.
Read full responseMeeting with Blaz Pongracic (Cabinet of Commissioner Violeta Bulc), Matej Zakonjsek (Cabinet of Commissioner Violeta Bulc)
5 Apr 2019 · Meeting the CEO - on electro mobility
Meeting with Violeta Bulc (Commissioner) and
26 Oct 2018 · meeting with GEN-I and partners GEN-I sonce and Post of Slovenia