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Green Power Denmark

GPD

Green Power Denmark represents 1,500 companies across the renewable energy value chain, including developers, electricity companies, and energy storage firms.

Lobbying Activity

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

26 Jan 2026 · European Competitiveness Fund

Meeting with Stine Bosse (Member of the European Parliament, Rapporteur for opinion)

12 Dec 2025 · ECF

Meeting with Bruno Tobback (Member of the European Parliament)

9 Dec 2025 · Future Electricity Markets

Meeting with Monika Zsigri (Head of Unit Energy)

9 Dec 2025 · Exchange of views on security of energy infrastructure

Meeting with Jan Ceyssens (Cabinet of Commissioner Jessika Roswall) and Confederation of Danish Industry and

8 Dec 2025 · Address to the cleantech MFF roundtable: An EU Budget for a Stronger, Cleaner and More Sovereign Europe – Recommendations from Danish Investors, Business Community & Civil Society

Meeting with Matthias Jorgensen (Acting Director Trade) and Novo Nordisk A/S and

3 Dec 2025 · Exchange of views on EU-US Trade Relations.

Meeting with Matthias Jorgensen (Acting Director Trade) and Novo Nordisk A/S and

3 Dec 2025 · Exchange of views on EU-US Trade Relations.

Meeting with Mechthild Woersdoerfer (Deputy Director-General Energy) and Ørsted A/S and

1 Dec 2025 · Exchange of views on electricity market rules and electrification

Meeting with Bruno Tobback (Member of the European Parliament) and Centrica plc and

1 Dec 2025 · Grids Package, planning and the Electrification action plan

Meeting with Niels Fuglsang (Member of the European Parliament)

14 Nov 2025 · Energy

Meeting with Niels Fuglsang (Member of the European Parliament)

15 Oct 2025 · Energy Solutions

Meeting with Niels Fuglsang (Member of the European Parliament)

19 Sept 2025 · Energy

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament) and Confederation of Danish Industry and

18 Sept 2025 · Erhvervsnetværk - Sustainability omnibus

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament) and Vestas Wind Systems A/S and Dansk Metalarbejderforbund

30 Jun 2025 · Trip to offshore wind farm

Meeting with Niels Fuglsang (Member of the European Parliament)

12 Mar 2025 · Meeting on energy

Meeting with Aleksandra Baranska (Cabinet of Executive Vice-President Teresa Ribera Rodríguez), Terhi Lehtonen (Cabinet of Executive Vice-President Teresa Ribera Rodríguez), Thomas Woolfson (Cabinet of Executive Vice-President Teresa Ribera Rodríguez) and

4 Mar 2025 · To hear interest representatives’ view on the Clean Industrial Deal and Affordable Energy Action Plan.

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament)

11 Feb 2025 · Energy system

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament)

5 Feb 2025 · EU energy policy

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

4 Feb 2025 · Challenges related to the implementation of 2030 framework in the EU and in Denmark

Meeting with Dan Jørgensen (Commissioner)

4 Feb 2025 · Electrification and decarbonisation

Meeting with Tomas Anker Christensen (Cabinet of Commissioner Dan Jørgensen)

28 Jan 2025 · Exchange on EU energy polices with a focus on electrification

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament, Shadow rapporteur)

17 Jan 2025 · Electricity grids and clean industrial deal

Meeting with Niels Flemming Hansen (Member of the European Parliament)

13 Dec 2024 · Planning of event in March about the Clean Industrial deal

Meeting with Stine Bosse (Member of the European Parliament)

3 Dec 2024 · European energy policy

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament)

22 Nov 2024 · Introduction to the energy system

Meeting with Sigrid Friis (Member of the European Parliament) and Danish District Heating Association/Dansk Fjernvarme

6 Nov 2024 · Upcoming term and energy

Meeting with Niels Flemming Hansen (Member of the European Parliament)

17 Sept 2024 · Energy policy

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament)

12 Sept 2024 · Energy policy in the EU

Meeting with Morten Løkkegaard (Member of the European Parliament)

12 Sept 2024 · News from Danish energy sector

Meeting with Per Clausen (Member of the European Parliament)

3 Sept 2024 · Meeting on Energy infrastructure and upcoming EU legislation

Meeting with Sigrid Friis (Member of the European Parliament)

28 Aug 2024 · Upcoming mandate

Meeting with Bruno Tobback (Member of the European Parliament)

17 Jul 2024 · The future of European energy policy: Challenges and opportunities to address during the new legislative mandate

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

17 Jul 2024 · Policy Event with Commissioner Simson “The future of European energy policy: Challenges and opportunities to address during the new legislative mandate

Meeting with Niels Fuglsang (Member of the European Parliament) and The Danish Chamber of Commerce

7 Mar 2024 · Elektrificeringskonference - Sæt grøn strøm til Europa

Meeting with Christel Schaldemose (Member of the European Parliament)

6 Mar 2024 · Energi og klima

Meeting with Daniel Mes (Cabinet of Commissioner Wopke Hoekstra)

5 Mar 2024 · green industrial policy

Meeting with Wopke Hoekstra (Commissioner)

5 Mar 2024 · Wind power development

Meeting with Niels Fuglsang (Member of the European Parliament)

22 Jan 2024 · Grøn omstilling

Meeting with Niels Fuglsang (Member of the European Parliament)

22 Nov 2023 · EU's grønne omstilling

Meeting with Morten Petersen (Member of the European Parliament)

21 Nov 2023 · Ongoing Parliamentary work related to the green transition

Meeting with Margrete Auken (Member of the European Parliament)

17 Nov 2023 · Energy transition

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

24 Oct 2023 · Ongoing Parliamentary work related to the green transition

Meeting with Ditte Juul-Joergensen (Director-General Energy) and Ørsted A/S and

6 Oct 2023 · Energy Transition

Meeting with Marianne Vind (Member of the European Parliament)

5 Jul 2023 · AFIR

Meeting with Marianne Vind (Member of the European Parliament)

5 Jul 2023 · Arbejds

Meeting with Erik Poulsen (Member of the European Parliament, Shadow rapporteur for opinion)

8 Jun 2023 · NZIA etc.

Meeting with Christel Schaldemose (Member of the European Parliament)

24 May 2023 · greener future

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

26 Apr 2023 · Energy Market Directive

Meeting with Erik Poulsen (Member of the European Parliament)

1 Feb 2023 · Renewable Energy Directive

Meeting with Niels Fuglsang (Member of the European Parliament)

25 Aug 2022 · Energy

Meeting with Alina-Stefania Ujupan (Cabinet of Executive Vice-President Margrethe Vestager) and Finnish Energy - Energiateollisuus ry and

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

Meeting with Margrethe Vestager (Executive Vice-President) and

25 Apr 2022 · Transition towards a fossil free society.

Response to Revision of EU rules on Gas

3 Mar 2022

Dansk Energi (Danish Energy Association) welcomes the opportunity to comment on the proposed revision of EU rules on market access. Dansk Energi fully supports the initiative to provide an appropriate market framework to accommodate the increasing EU climate ambitions. If the gas sector is to be decarbonized, it is critical to assure the parallel development of supply, infrastructure, market, and demand for RES (low carbon) gases, including hydrogen. As such, the package provides a good starting point for infrastructure and market growth, including consumer empowerment. The directive and regulation appear to cover the key topics in the gas market's green transition, with an emphasis on enabling national market solutions. Our key concerns include the diversified approach to renewable and low-carbon fuel certification. Renewable sources should not be regarded more stringently than low-carbon sources. Furthermore, the Directive fails to address the requirement for regulatory oversight and incentives to demolish obsolete natural gas infrastructure. Please find our detailed comments attached.
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Response to Revision of EU rules on Gas

3 Mar 2022

Dansk Energi (Danish Energy Association) welcomes the opportunity to comment on the proposed revision of EU rules on market access. Dansk Energi fully supports the initiative to provide an appropriate market framework to accommodate the increasing EU climate ambitions. If the gas sector is to be decarbonized, it is critical to assure the parallel development of supply, infrastructure, market, and demand for RES (low carbon) gases, including hydrogen. As such, the package provides a good starting point for infrastructure and market growth, including consumer empowerment. The directive and regulation appear to cover the key topics in the gas market's green transition, with an emphasis on enabling national market solutions. Our key concerns include the diversified approach to renewable and low-carbon fuel certification. Renewable sources should not be regarded more stringently than low-carbon sources. Furthermore, the Directive fails to address the requirement for regulatory oversight and incentives to demolish obsolete natural gas infrastructure. Please find our detailed comments attached.
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Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

12 Jan 2022

Dansk Energi (Danish Energy Association) welcomes the opportunity to comment on the proposed revision of the Energy Performance of Buildings Directive (EPBD). In general, we commend the Commission's efforts to address the need to improve the energy performance of Europe's building stock. We applaud the elimination of financial incentives for fossil-fuel-based heating, such as gas boilers. It is critical to use financial incentives to stimulate investment in more efficient, renewable types of heating and cooling. Similarly, making data about the building available to owners, tenants, and third-party actors is a desirable notion. It is a vital tool for ensuring access to data on heating, cooling, and water use, much like data on electricity consumption is available now. At the same time, we feel compelled to emphasize that climate change is relentless. As a result, we are concerned that the proposed implementation date for lowering the building automation threshold is too late. It is concerning that the Commission does not ensure that buildings be activated considerably sooner - by 2024, when the requirement in any case only applies to new construction and renovations. Because post-installation is significantly more expensive, adopting the requirement later is less cost-effective. Please find our detailed comments attached.
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Response to Review of Directive 2012/27/EU on energy efficiency

18 Nov 2021

Attached our input on the Energy Efficiency Directive, mainly focused on the Primary Energy Factor (PEF).
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Response to Revision of Alternative Fuels Infrastructure Directive

18 Nov 2021

In general, we applaud the regulation's intention of facilitating the adoption, deployment, and development of charging infrastructure across Europe, as well as improving interoperability and transparency for the benefit of both customers and the green transition in transportation. A comprehensive regulatory framework that facilitates and supports companies when investing in charging infrastructure, while also making it easier for drivers of electric vehicles to travel across Europe, is desperately needed. The most crucial element for electric vehicle users is easy access to a vast and integrated network of charging ports that are easy to reach, do not have long lines, and where it is easy to pay in a uniform manner. The following annex elaborates on Danish Energy's position on the revision of the Alternative Fuels Infrastructure Directive, as well as the initiative on CO2 emissions standards for vehicles and vans.
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Response to ReFuelEU Aviation - Sustainable Aviation Fuels

18 Nov 2021

This document comprises Danish Energy’s updated positions on: 1. ReFuelEU Aviation on ensuring a level playing field for sustainable air transport 2. FuelEU Maritime on the use of renewable and low-carbon fuels in maritime transport It is important to have ambitious European targets for decarbonization and the use of renewable energy and renewable fuels. This requires targets in specific sectors which is especially true for the transport sectors (land transport, aviation, and shipping). It is important to establish European rules and market frameworks which promote the use of renewable energy and renewable fuels across EU countries. The European transport sectors are especially challenging to decarbonize as there is still a significant price difference between fossil fuels and renewable fuels. Furthermore, there is a need to significantly increase the production of renewable fuels for the heavy transport sectors such as the aviation- and maritime sector. Renewable hydrogen and renewable fuels of non-biological origin (RFNBO) are key to the decarbonization of heavy transport sectors such as the maritime sector. The production of synthetic aviation fuels (renewable fuels of non-biological origin, RFNBO) is being developed and established in Europe. However, scaling and industrialization of the production of RFNBOs is required to provide sufficient amounts of fuel and for the price of the fuels to decrease. The industries producing RFNBO are still developing in the Union and they require significant offtake of the fuels in order to realize the sufficient scale. Therefore, it is important to develop the supply and demand in parallel and ambitious targets for the use of renewable fuels in transport sectors is a central step to achieve this. Please find our detailed comments in the document attached.
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Response to Revision of the Energy Tax Directive

18 Nov 2021

We commend the Commission's proposal for a fundamental shift in the minimum taxation of energy. Due to the current incoherent system, which includes ambiguous definitions and national loopholes, green electricity does not receive the support it needs, despite the critical role electrification will play in Europe’s decarbonization. For example, many countries subsidize fossil fuels at the expense of greener, renewable alternatives. The same is true in Denmark, where electricity tariffs do not reflect the significant role that electricity will play. This, we believe, must change. We want to highlight a potential issue that a differentiated and inefficient taxation of sustainable biomass could cause. We believe that the proposed tariff on sustainable biomass is unsuitable because it risks impeding the targeted reduction of fossil fuels in the energy sector. For our full comments please see document attached.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

18 Nov 2021

The Renewable Energy Directive (RED II(I)) is a crucial part of the FF55 puzzle, and we support adjusting it to fit the decarbonization ambitions. First, we find it positive that that the RE-target is increased, however we would advise setting a target of 45% RE in 2030. This is in line with the swift buildout needed and supported by the Commission’s own impact assessment. Second, we support clarification on biomass sustainability criteria, however, advise further studies are needed before setting additional restrictions. Third, we warn against setting many sector-specific targets e.g. on buildings which could be suboptimal, and better dealt with in the upcoming EPBD1 revision. Please find our detailed comments attached.
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Response to Carbon Border Adjustment Mechanism

8 Nov 2021

we welcome the implementation of a Carbon Border Adjustment Mechanism, as it is an important tool to ensure emissions reductions on a global scale. Particularly positive that electricity is covered by the mechanism since it is a sector subject to unfair competition from outside the EU. We suggest the inclusion of hydrogen within the scope of the mechanism to support investment in green hydrogen, which is under pressure from the import of hydrogen produced from fossil fuels. Please find our detailed comments in the file attached.
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Response to Updating the EU Emissions Trading System

8 Nov 2021

This document comprise Danish Energy’s updated positions on: 1. The ETS-directive and the Market Stability Reserve (MRS) 2. The Carbon Border Adjustment Mechanism (CBAM) Generally, we find that the proposed revision of the ETS-directive is very positive. First and foremost, it is important to reform the market for emissions allowances to ensure that more sectors are covered, and that the emission of carbon, and fossil fuel consumption, becomes more expensive. The price on allowances has risen in recent years, and we find it important to ensure that this trend continues. We welcome the Commission’s proposed increase in the linear reduction factor, as well as the retention of the reserve of 24% of allowances outlined by the Market Stability Reserve (MSR). Furthermore, we support the gradual integration of buildings, road transportation and the maritime sector into the ETS system. The green transition relies on a strong and resilient market for allowances, making it of utmost importance that the goals and ambitions are maintained. Similarly, we welcome the implementation of a Carbon Border Adjustment Mechanism, as it is an important tool to ensure emissions reductions on a global scale. Particularly positive that electricity is covered by the mechanism since it is a sector subject to unfair competition from outside the EU. We suggest the inclusion of hydrogen within the scope of the mechanism to support investment in green hydrogen, which is under pressure from the import of hydrogen produced from fossil fuels. Please find our detailed comments in the document attached.
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Response to Revision of EU rules on Gas

10 Mar 2021

Danish Energy welcomes the opportunity to comment on the roadmap for the Hydrogen and Gas mar-kets Decarbonisation Package. Danish Energy is an association representing Danish electricity and gas companies. Our members include gas suppliers and companies active in the North-western Euro-pean gas markets. Danish Energy fully supports the effort to ensure a suitable market framework to support the achieve-ment of the proposed increased EU climate ambitions. Furthermore, we support a more holistic energy sector approach with interdependencies of electricity, renewable hydrogen and green gasses. The 2050 target of carbon neutrality means that fossil fuels must be phased out completely, which generally requires direct electrification and for hard-to-abate sectors it requires indirect electrification through the production of renewable hydrogen or green gases. Furthermore, hydrogen production and green gases can provide additional flexibility solutions when and where it is considered efficient for the energy system. Revised rules should prepare the gas market for its new dual role and set an adequate framework for the required investments. The Hydrogen and Gas Markets Decarbonisation Package is necessary to prepare the energy system for the challenges posed by the decarbonisation journey and the take advantages the opportunities arising from developing a European hydrogen industry. The revision of the gas market rules and the establishment of hydrogen market rules should enable and facilitate efficient integration of renewable hydrogen and gases into the market - on both commodity and infrastructure sides. The initiative should be aligned with the objectives of the Energy System Integration and Hydrogen Strategies and prepare the gas sector for deep decarbonisation by 2050. Hydrogen infrastructure and hydrogen markets Renewable hydrogen is necessary to reach the 2030 reduction target and full decarbonisation in 2050. Danish Energy support the aim of this initiative to modify existing EU legislation and create a new framework for an internal hydrogen market, which is key to achieve a cost-efficient clean hydrogen economy.This will require dedicated hydrogen infrastructure to enable cost-efficient transportation from hydro-gen production sites to consumption of pure hydrogen or to further procession into hydrogen-based fuels such as ammonia, methanol or jetfuel. Furthermore, cross-border hydrogen infrastructure is re-quired to connect different national hydrogen markets and to ensure that renewable hydrogen is pro-duced where the most favourable conditions are present. Dedicated hydrogen infrastructure could be new infrastructure or repurposed gas infrastructure – considering what is more cost effective and sus-tainable relative to other production patterns and means of transportation. Natural gas pipeline owners (network operators) should be allowed to own, operate and finance hydrogen pipelines – and they should be allowed to repurpose the existing gas pipeline into pure hydrogen pipelines. Gas TSOs should, however, not be allowed to own or operate electrolysers. This could potentially make them hydrogen producers as well as hydrogen infrastructure owners/operators, which would not follow the European principle of unbundling. Ownership and operation of electrolysers should be mar-ket based and should be managed by commercial market participants. To this purpose, the production of renewable hydrogen, i.e. via electrolysis, should have adequate direct support and funds as well as a carbon allowances scheme that do not distort competition between technologies or energy carriers. Hydrogen pipelines should be regulated to achieve competitive market outcomes, e.g. there should be requirements of third party access and other measures to ensure an effective hydrogen market both nationally and at an EU level. Furthermore, it is important to have regulatory predictability for investors in and users of infrastructure. SEE REST IN ATTACHED FILE
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Response to Revision of the Communication on important projects of common European interest

18 Dec 2020

Danish Energy thanks for this opportunity to provide input to the revision of Communication on important projects of common European interest (IPCEI). IPCEIs can be a very important factor to support large scale industrial development in areas such as in the development of renewable energy and on industry, who rely on the availability of affordable and green electricity, and can in the coming years represent a very important contribution to economic growth, jobs and competitiveness. Danish Energy represents danish energy companies within power, heat and hydrogen production, energy trading of power and gas as well as owners of power distribution grids. We hope the Commission will find our feedback regarding the revision of IPCEI process valuable. Danish Energy believes that the IPCEI can be a very important instrument to overcome mar-ket failures and to assist with first industrial deployment in the areas such as the green transi-tion. It can thus help the development of new products with a high research and development and innovation (R&D&I) content or of a fundamentally innovative production process that is needed between a pilot line and until start of mass production. IPCEIs can thus be a valuable tool in scaling up technologies that are already ready for broader deployment in order to achieve the EU climate objectives. It is however important for Danish Energy to emphasize that the IPCEI must adhere to the fundamental principles of the Single Market, and the IPCEIs should only be used as a tool where there is a strong need to overcome market failures. Furthermore, we urge the Commission to align the IPCEI-criteria with the Union’s energy and climate objectives in the updated Communication on IPCEIs. In the current Communication, paragraph 23 states that “Environmental, energy or transport projects must either be of great importance for the environmental, energy, including security of energy supply, or transport strategy of the Union or contribute significantly to the internal market, including, but not limited to those specific sectors”. In order to contribute to the EU’s 2030 and 2050 climate targets and ensure the internal market is not steered in a wrong direction, we believe IPCEIs should contribute to both Union strategies (e.g. the hydrogen strategy, offshore renewable strategy and the energy system integration strategy with regards to energy projects) and the internal market. IPCEIs should deliver on the Green Deal and contribute to the overarching target of climate neutrality. Therefore, “transitional” technologies, such as “low-carbon” hydrogen, should not be regard-ed as IPCEIs, recognizing that renewables are most compatible with the Union’s long-term objectives. The current framework on the rules and regulations on IPCEI projects for such projects are currently perceived quite opaque, making it hard not large parts of the companies to under-stand the aims and objectives of the IPCEIs. There is thus a need to both clarify and simplify the communication around the IPCEIs but also to simplify the rules and guidelines by making a more transparent framework for all companies and other stakeholders that wishes to take part of an IPCEI process. Currently, many companies do not fully understand neither the process nor the aims. We thus welcome the revision’s position to create a more transparent and inclusive process. Yours sincerely Dansk Energi Lars Koch, Director of EU-Affairs
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Response to Revision of the Energy and Environmental Aid Guidelines (EEAG)

10 Dec 2020

The European State Aid Guidelines for Environment and Energy (EEAG) are of great importance for the green transition, as they allow national support mechanisms for renewable energy compatible with internal market rules, thus supporting the necessary buildout of renewables. It is important, that the revision of the EEAG serves the EU’s overarching target of climate neutrality by 2050 and the Commission’s newly proposed target of at least 55% CO2e emissions reduction by 2030. This means continued national support schemes to ensure the necessary deployment of renewables in order to reach the EU’s climate and energy objectives. Ideally, the green transition could happen without state aid. Current market prices are not yet sufficient for ensuring the needed energy transformation. That being said, investment signals should be market-driven, so state aid should be market-compliant and commercially viable projects should manage without subsidies. However, in order to meet the Union’s climate objectives, putting subsidies to rest is not a viable solution in the short term. Removing support schemes for renewables will only delay the necessary buildout. Please read the attached file for Danish Energy's full contribution to the upcoming revision of the EEAG.
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Response to Updating the EU Emissions Trading System

26 Nov 2020

Danish Energy highly welcome the opportunity to comment on the European Commission’s Roadmap as part of the EU Emissions Trading System (ETS) review process. In light of the EU target of climate neutrality and the Commission’s proposal to increase the 2030 reduction target to at least -55%, Danish Energy supports reviewing and strengthening the EU ETS in order to ensure the ETS remains a primary driver of Europe’s green transition. We hope the Commission will find our input valuable and take them into account when preparing the amendment of the EU ETS Directive (2003/87/EC). Please read the attached file for our recommendations and full contribution to the revision of the EU ETS.
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Response to Revision of the CO2 emission standards for cars and vans

26 Nov 2020

Danish Energy highly welcomes the European Commission’s decision to revisit and strengthen the CO2 standards for cars and vans for 2030 and thanks the Commission for this opportunity to share our views on the revision. Danish Energy is a non-commercial organisation for Danish energy companies, mainly active in the electricity sector, covering activities from energy production, distribution and trading. The Danish Electric Vehicle Alliance at Danish Energy represents companies interested in promoting electrical vehicles (EVs) in Denmark. Together, we represent the entire value chain for EVs from energy production to charging station operators and car manufacturers. Our input can be summarized into the following main points: 1. Strengthen CO2 emissions standards for cars and vans 2. Enable Member States to ban sales of petrol and diesel-powered cars as of 2030 al-ready today 3. Revise the WLTP test cycle for plug-in hybrids We hope the European Commission will find our contribution valuable. Please read the attached file for our full contribution.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

21 Sept 2020

Please read the attached file for Danish Energy's full feedback. Danish Energy highly welcomes the European Commission’s initiative to review and revise the REDII in order to promote renewable energy production and utilization in the EU. The directive is based on the EU’s current 2030 climate and energy framework aiming at a 40% GHG-reduction in 2030 and will thus fail to contribute to the new and increased 2030 and 2050 climate targets of the EU. Our feedback is divided into the following 3 headlines: 1. Increase overall RES-target to at least 40% 2. Include definitions of hydrogen consistent with other EU-legislation and classifications 3. Promote renewables in non-ETS sectors An accelerated build-out and deployment of renewables into our energy systems and sectors is absolutely vital. The review of the REDII should aim at removing all barriers to the necessary ramp up of renewables.
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Response to Review of Directive 2012/27/EU on energy efficiency

21 Sept 2020

Please find the attached paper for our full feedback. Danish Energy Welcomes the Commission's initiative to evaluate the Energy Efficiency Directive (EED) in order to align it with the EU's new and more ambitious climate targets. Reaching climate neutrality by 2050 cannot be done without tackling GHG-emissions from the energy sector, and energy savings and promotion of energy efficiency is an important tool to reduce emissions. We wish to highlight the importance of electrification as the most cost-effective way to decarbonize European societies, and that electrification will provide significant energy savings, because electricity is substantially more efficient than fossil fuels. A main focus in the evaluation of the EED should be on reviewing the Primary Energy Factor (PEF) for electricity. Currently, the PEF punishes the use of electricity. As our electricity increasingly is based on renewables, the use of electricity should be promoted in order to decarbonise across sectors. Reviewing the PEF should be with a clear purpose of promoting the use of renewables in electricity and heating/cooling and incentives the transition away from fossil fuels to renewables.
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Response to Revision of the EU Emission Trading System Monitoring and Reporting Regulation (MRR)

24 Jul 2020

Danish Energy welcomes the opportunity to comment on the European Commission’s consultation on the draft Commission Regulation amending and correcting Implementing Regu-lation (EU) 2018/2066 on the monitoring and reporting of greenhouse gas emissions pursuant to Directive 2003/87/EC of the European Parliament and of the Council (hereafter “MRR”). We acknowledge the need for updating monitoring and reporting rules head of EU ETS phase IV trading period starting 2021, especially to fit the objectives of the European Green Deal and to mitigate risks of double counting. The current implementing regulation 2018/2066 allows laboratory test and guarantees of origin (GoO) to certify the biomass-fraction of the gas blend. The new draft regulation Art. 39 proposes two new mutually exclusive verification methods: • (4) the operator can use purchase documents to demonstrate the biomass fraction, provided that sufficient evidence is given such as GoO according to Art. 2(12) of Directive (EU) 2018/2001, or • (5) Member States determine the biomass fraction based on average values determined by the competent authority We believe the second calculation method in Art. 39(5) is problematic and should be removed as it: • Creates an unlevel playing field between countries who might opt for different calculation methods • Disincentivizes cross-border trade of biomass • Disincentivizes individual industries to further improve their energy performance • Distorts the ETS-certificate trading market, which needs to be robust when new technologies are introduced We therefore propose to delete Art. 39(5) of the current draft regulation and appreciate your consideration of our input. Yours sincerely Danish Energy
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Response to A EU hydrogen strategy

8 Jun 2020

Danish Energy's contribution to the EU's hydrogen strategy roadmap: Danish Energy welcomes the opportunity to contribute to the EU’s hydrogen strategy. Danish Energy represents Danish energy companies within power, heat and hydrogen production, energy-trading of power and gas as well as owners of power distribution grids. Danish Energy supports the development of an energy system and infrastructure based on high degree of direct electrification supplemented with Power-to-X technologies for hard-to-abate sectors. We believe a key focus in the EU hydrogen strategy should be to create large-scale market demand for renewable hydrogen across multiple sectors, e.g.: • Abatement of existing “black” hydrogen and hydrogen-based chemicals in heavy industry, especially in industries not related to existing fossil fuel production • New areas for use of renewable based hydrogen: - Hydrogen for trucks, busses and other heavy-duty vehicles - Aviation fuels (e-kerosene) - E-ammonia for fertilizer and shipping Facilitating market demand for renewable hydrogen requires the establishment of efficient and liquid markets as well as clear definition of renewable hydrogen and other renewable gasses. Market participants, such as industrial consumers and the transport and shipping sec-tors, demanding and using hydrogen needs to be able to trust and verify that the product they buy is in fact renewable and green. Therefore, the EU needs a clear and objective definition of hydrogen which is consistent with other classifications, definitions and taxonomies in EU legislation. Power-to-X and the production of renewable hydrogen is a commercial activity with the potential for competing entities in the EU. It is therefore important that Power-to-X is a market activity, also to avoid the likely conflict of interest if electrolysers are owned by TSOs. The market should target private investors related to renewable hydrogen production and usage; hence an EU-coordinated support mechanism and market volume across Member States can attract investors. Further, EU regulation and climate targets should make renewable hydrogen and hydrogen products attractive to end-users especially in hard-to-abate sectors. The support for renewable hydrogen could be targeting the cost gap between renewable and fossil-based hydrogen. Further, hydrogen derived products such as e-kerosene, e-ammonia and e-methanol could have additional premium support mechanisms. Further, continuous R&D support for hydrogen and Power-to-X is important for the EU to be front runner in the development of new technologies and business models. Other important areas the strategy should address: • CO2-impact of power-grid based hydrogen. Establish clear rules preferably before the end of the year 2020 that define the CO2-impact of hydrogen from power grid-based electricity. In the medium to long run fossil-based power production will most likely not play any role in the production of electricity-based hydrogen. • Hydrogen infrastructure in Europe. It is important to analyze the need for dedicated hydrogen grids and storages and to which extent parts of the existing natural gas transmission grid could play a role in the future hydrogen grid. • Development of renewable based hydrogen should be the main element in the EU hydrogen strategy. Support of “Blue hydrogen” infrastructure and technologies could end up as stranded assets in case renewable-based hydrogen proves to be a cost-competitive technology within the next decade. We are at your disposal for any queries on our response Yours sincerely On behalf of Danish Energy Morten Stryg Chief advisor mst@danskenergi.dk
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Response to Revision of the guidelines for trans-European Energy infrastructure

8 Jun 2020

Please find Danish Energy’s feedback on the Revision of the guidelines for trans-European Energy infrastructure in the attached file. In the light of the increased European climate ambitions, the TEN-E regulation is in need for a revision. We thus highly welcome this initiative, and urge the Commission to include the following:  - Strengthen timely implementation of PCIs  - New governance for determining transmission infrastructure needs  - Facilitate offshore grids to sustain offshore wind  - Facilitate hydrogen infrastructure  - Fully and effectively support energy system and sector integration  - Ensure that national implementation of the Clean Energy Package secures cost-effective and smart infrastructure investments  - Digitalisation as the foundation of energy system integration We refer to the attached file for Danish Energy's full feedback.
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Response to Strategy for smart sector integration

8 Jun 2020

Please find Danish Energy's comments and recommendations on what the strategy for energy system integration should entail in the attached file. Danish Energy highly welcomes the European Commission’s initiative on a European strategy for energy system integration. Linking energy systems and coupling sectors is essential to reach climate neutrality by 2050 in the most cost-efficient way. In brief, Danish Energy believes the following are key elements in an energy system integration strategy: - Energy efficiency first must remain the leading principle, and thus direct electrification of sectors should be priority, e.g. heat pumps in heating systems, electric vehicles in road transport, high-temperature heat pumps in industrial processes etc. - For the hard-to-abate sectors where direct electrification currently occurs infeasible, indirect electrification converting electricity into storable E-fuels and green gasses through power-to-X-processes will be key. We welcome the Commissions initiative to develop an EU Hydrogen strategy, which should address how to bring electrolysis to scale, dedicated hydrogen pipelines and put an EU definition of renewable hydrogen in place in order to promote investments. - Flexibility – e.g. energy storage, demand side response, flexible production of power-to-gas products or power-to-liquids – is crucial to integrate increased amount of renewable electricity in the energy system. Digitalisation will pave the way for stronger utilization of data in managing utilities and identifying where sector integration could enhance flexibility and enable more cost-effective solutions, e.g. through price signals in the energy system. - Improve national and trans-European electricity and gas infrastructure and invest in interconnectors to enhance cross-border trade in the EUs internal energy market. We refer to the attached file for our full feedback.
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Response to Climate Law

1 May 2020

See the attached file.
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Response to 2030 Climate Target Plan

15 Apr 2020

Please find Danish Energy's comments in the attached PDF-file
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Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans) and Finnish Energy - Energiateollisuus ry and

4 Mar 2020 · Green Deal priorities

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

5 Nov 2019 · Presentation. European decarbonisation efforts and the role of DSOs

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

12 Jul 2019

Danish Energy agrees to the need for an evaluaton of effectiveness and policy coherence of the TEN-E Regulation. Since the adoption of the TEN-E Regulation in 2013, several developments have significantly changed the landscape for energy policy in the EU. 1) The Paris agreement obliges the participating parties to keeping a global temperature rise this century well below 2 degrees Celsius above pre-industrial levels and to pursue efforts to limit the temperature increase even further to 1.5 degrees Celsius. 2) The cost of renewable energy (notably solar and wind) has come down by at least 20 to 75 % depending on technology, and is now competitive to conventional electricity production on several markets. https://www.irena.org/-/media/Files/IRENA/Agency/Publication/2019/May/IRENA_Renewable-Power-Generations-Costs-in-2018.pdf 3) The European Commission in 2018 pulished a study showing a possible pathway to a carbon neutral EU by 2050. In these scenarios power to X is considered an important and viable part of the solution. Against this backdrop, Danish Energy would like to underline the importance of including the following elements in the evaluation of the TEN-E regulation. - How to ensure that updates of the PCI list are strictly Paris compliant, meaning only projects that contribute directly towards climate neutrality in 2050 should be included. - Assessing how to address the role of hydrogen in PCI criteria - including the possibilty of dedicated hydrogen infrastructure. - Exploring the reasons for delays in PCI implementation and possibilities to ensure more stringent enforcement of PCI permit granting deadlines. More than 30 % of PCI initiatives are currently delayed: https://www.acer.europa.eu/Official_documents/Acts_of_the_Agency/Publication/Consolidated%20Report%20on%20the%20progress%20of%20electricity%20and%20gas%20Projects%20of%20Common%20Interest%20for%20the%20year%202017.pdf Further, the role of the soon to be established DSO entity in the regular updates of the PCI list, should be considered in the TEN-E evaluation.
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Meeting with Stig Joergen Gren (Cabinet of Vice-President Andrus Ansip) and Confederation of Danish Industry and

6 Nov 2018 · DSM general, eCommerce, data, copyright

Meeting with Claes Bengtsson (Cabinet of Commissioner Margrethe Vestager)

6 Mar 2018 · EU Energy Markets

Meeting with Arunas Ribokas (Cabinet of Commissioner Vytenis Andriukaitis)

29 Sept 2016 · Commission energy efficiency package

Meeting with Soren Schonberg (Cabinet of Commissioner Margrethe Vestager)

3 Dec 2015 · EU Energy Union, including future State aid Guidelines

Meeting with Christian Linder (Cabinet of Vice-President Maroš Šefčovič)

3 Dec 2015 · Energy Efficiency investment schemes; market design; heating and cooling

Meeting with Christina Holm Eiberg (Cabinet of Commissioner Margrethe Vestager)

23 Sept 2015 · Introduction to the Danish Energy Assocation

Meeting with Soren Schonberg (Cabinet of Commissioner Margrethe Vestager)

5 May 2015 · EU Energy Union and State Aid Policy

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

5 May 2015 · Energy Union conference in Copenhague