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Helen

The main tasks and objectives of Helen Ltd include: Energy Production: Helen produces electricity, heating, and cooling in power plants and heating plants around Helsinki. The range of production includes hydropower, wind power, solar power, and nuclear power. Energy Efficiency: Helen is constantly improving energy efficiency with over 100 years of experience. Green Hydrogen: Helen aims to be at the forefront of delivering green hydrogen-based solutions to replace fossil fuels and store energy on a large scale. Climate Neutrality: The goal is to achieve 100% carbon neutrality by 2030 in their energy production. Helen has over 500,000 customers throughout Finland.

Lobbying Activity

Response to Future development and deployment of Small Modular Reactors (SMRs) in Europe

28 Nov 2025

Feedback Helen Ltd / Helsinki / Finland Helen Ltd is Helsinki city owned utility company with approximately 600,000 customers in Finland. We offer district heating and cooling, electricity and energy services. Helen Ltd sees nuclear energys role as extremely important in Europe's decarbonization, competitiveness, and resilience. Helen Ltd has set a target to build a nuclear power plant (SMR) in Helsinki city, the capital of Finland. In the first phase Helen will negotiate with potential partner shareholders, evaluate plant suppliers and determine potential plant sites. Helen evaluates light-water small modular reactors (SMRs) based on proven solutions, which can be used to produce only heat or both electricity and heat. In spring 2025 Helen invited suitable suppliers to participate in the tender process, during which the company will choose a partner for more detailed project planning. In Autumn 2025 we published three potential power plant sites for further assessment. Helen sees that the concept of a technology-neutral approach is crucial for the clean transition in Europe. This approach ensures that nuclear power is considered on an equal footing with renewable energy sources in various initiatives. We appreciate the EUs work in advancing this theme, and in our feedback, we highlight a few perspectives that could accelerate our SMR project and SMR in general in Europe. How can EU support small modular reactors role in Europe's decarbonization, competitiveness, and resilience? 1. For Europe SMRs offer a promising fossil free solution for district heating and combined heat and power (CHP), especially in urban areas where electrification faces grid constraints or storage limitations. EU should highlight the urban and industrial applications, because Europe is densely populated, and SMRs provide a solution by enabling safe construction close to residential areas. Through a regulatory amendment, the consideration should relate modern SMRs with the overall safety and risks in society. The consideration should also cover the disputable linear non-threshold model (LNT) for low radiation doses. 2. It is crucial that in Europe we can secure access to both private and public funding, by further developing long-term contracts, and ensuring nuclear and derivative low-carbon solutions can fully access European financing and guarantee programs. To accelerate the deployment of clean heat solutions for Europe, small modular reactors (SMRs) should be eligible for EU Innovation Fund financingjust like other non-market-ready technologies such as hydrogen and carbon capture. The first-of-a-kind SMR projects must not be delayed due to lack of financing and public funding. Tackling the investment barriers should be dealt with through targeted CAPEX support; direct electricity and heating market interventions should be avoided. 3. EU should also enhance collaboration to build a resilient and scalable supply chain across Europe, benefiting the whole industry in the EU and helping to maintain its competitiveness and energy independence. By ensuring that the relevant skills, expertise and know-how are maintained, EU can drive innovation and reinforce longstanding European excellence and strategic autonomy in the nuclear sector.
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Response to Heating and cooling strategy

9 Oct 2025

Helen Ltd is Helsinki city owned utility company with approximately 600,000 customers in Finland. We offer district heating and cooling, electricity and energy services. In our feedback we provide our view not only to cut down the emissions of heating and cooling but also to ensure the security of supply of heating and cooling and affordable costs. In Finland heating and cooling sector will become almost fossil free during the 2020s. Already in 2023, 94% of Finlands electricity came from emission-free sources. Fossil-based energy in district heating is also rapidly declining for example Helen Ltd has cut already 80 % and aims to cut 95% of its district heating emissions by 2030. In heating and cooling fossil fuels are used only when clean energy is temporarily unavailable. District heating offers a triple solution: it addresses emissions, energy sufficiency, and security of supply. Helen has energy ecosystem based on system integration (electricity, heat, cooling and customer solutions). We have nearly achieved fossil-free district heating through a combination of large-scale electrification (heat pumps and electric boilers), recovery of waste heat, and sustainable bioenergy. AI and data centers trend are inevitable in Europe, and they should be used to decarbonize district heating systems. Data centers increase the cooling demand, but their waste heat recovery also plays a big role in district heating. Currently tax incentives are being used to support the development of data centers integration into the district heating system in Finland. Similar approach would steer data center placement toward cities with existing district heating infrastructure in Europe. Separate the EPBD from the energy market in countries with clean energy production to speed up the clean transition and ensure energy security In countries like Finland, where energy production is already nearly fossil-free, the EPBD should focus solely on improving the structural energy efficiency of buildings rather than steering the energy market. The current directive unfairly favors on-site heat pumps over clean district heating, which forms a major risk for energy security in Finland. By decoupling EPBD from energy market steering in these front-runner countries, the EU can: 1. Accelerate the clean transition without penalizing existing low-emission systems like district heating. 2. Support energy security by preserving diverse and resilient heating solutions. 3. Enable fair treatment of technologies like district heating and small modular reactors (SMRs), which are essential for balancing the energy system. The decoupling would accelerate emission reductions in the heating and cooling sector, as countries would be incentivized to reach a clean energy system status that reduces their regulatory burden in EPBD. The approach aligns with the EUs broader goals of climate neutrality and energy sovereignty: it accelerates emission reductions on the effort-sharing sector when EPBD would focus only on that in countries where energy production is already clean. The EU should also allow the use of permanent carbon dioxide removals (CDR) units to reduce emissions from district heating. This would help to boost the CDR market. Include SMRs in EU Innovation Fund Support Helens goal is to become combustion-free by 2040. To achieve that Helen has launched a nuclear energy program aiming to build a nuclear power plant (SMR) in Helsinki. For Europe SMRs offer a promising fossil free solution for district heating and combined heat and power (CHP), especially in urban areas where electrification faces grid constraints or storage limitations. SMRs can help balance the energy system and reduce emissions in hard-to-abate sectors and power-to-x solutions. To accelerate the deployment of clean heat solutions for Europe, small modular reactors (SMRs) should be eligible for EU Innovation Fund financingjust like other non-market-ready technologies such as hydrogen and carbon capture
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Response to Nuclear Illustrative Programme

9 May 2025

Helen Ltd is Helsinki city owned utility company with approximately 600,000 customers in Finland. In addition to production of electricity, heating and cooling, we offer solutions for energy services and electric transport. We are developing a smarter, carbon-neutral energy system that enables our customers to produce, use and save energy with respect to the environment. We have set a target of making our energy production carbon neutral by 2030. In addition, we aim to phase out combustion-based energy production by 2040. Helen Ltd sees nuclear energys role as extremely important in Europe's decarbonization, competitiveness, and resilience. Helen Ltd has set a target to build a nuclear power plant for heat production of Helsinki city, the capital of Finland. In autumn 2024 we launched a nuclear energy program, and in its first phase Helen will negotiate with potential partner shareholders, evaluate plant suppliers and determine potential plant sites. Helen evaluates light-water small modular reactors (SMRs) based on proven solutions, which can be used to produce only heat or both electricity and heat. In spring 2025 Helen invited suitable suppliers to participate in the tender process, during which the company will choose a partner for more detailed project planning. The plant supply agreement will be signed upon completion of project planning. Helens decision to start exploring the potential of nuclear energy stems from the companys goal to become combustion-free in energy production by 2040. Helen has more than one hundred years of experience in energy production and the operation of power plants. We have also been co-owners in Finnish nuclear power since its early years. We are known as a pioneer of the energy industry and are one of the most reliable energy companies in the world. Now we are taking another step towards a new era of energy. How can EU support nuclear energys role extremely important in Europe's decarbonization, competitiveness, and resilience? Firstly, Helen sees that the concept of a technology-neutral approach is crucial for the clean transition in Europe. This approach ensures that nuclear power is considered on an equal footing with renewable energy sources in various initiatives. Secondly it is crucial that we can secure access to both private and public funding, by further developing long-term contracts, and ensuring nuclear and derivative low-carbon solutions can fully access European financing and guarantee programs. Thirdly, Helen stresses that any support for nuclear power should be used to enable market-based projects, not to provide continuous subsidies that distort market signals. Any support should complement the functioning market environment. To support capital-intensive clean energy investments such as small modular reactors, state loans and guarantees are efficient tools to reduce financial risks. These mechanisms can improve project bankability and reduce cost of capital, helping ensure projects reach final investment decision. Helen does not support state aid mechanisms directly tied to electricity market price formation. State aid should complement functioning markets, not replace them. The energy-only market should remain the foundation of electricity markets, and any new mechanisms must be thoroughly assessed to ensure they do not undermine market stability or previous investments. Technological neutrality, cost-effectiveness, and stable investment environments must be guiding principles in state aid policy.
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Response to Greenhouse gas emissions savings methodology for low-carbon fuels

25 Oct 2024

Helen Ltd. would like to thank the Commission for the well-prepared draft delegated act that will bring the needed clarity to the regulatory landscape. We see that the proposed draft corresponds to the expectations of the industry. Due to the low-carbon electricity grid of Finland, the Finnish companies are mostly interested in the production of the electricity-based low-carbon hydrogen and our remarks will therefore mainly concentrate on the production route defined in the Article 6(a) of the Annex. Helen warmly welcomes the low carbon delegated act. It is a necessary part of hydrogen regulation, and the hydrogen producers need it to finalize their feasibility studies. With this last piece of hydrogen legislation in place, the projects can move forward. Detailed comments in the attached document.
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Response to Revision of EU rules on Gas

12 Apr 2022

Helen thanks to the European Commission for the opportunity to leave feedback on Proposal for a directive of the European Parliament and of the Council on common rules for the internal markets in renewable and natural gases and in hydrogen 2021/0425 (COD). Helen is the second biggest energy company and in Finland with the largest district heating and cooling network in Finland what is the fifth largest in the world. Helen supports the European Union’s goal to reduce CO2-emissions -55 % by 2030 and sees that the well-functioning internal markets of renewable and natural gases and especially of hydrogen act the important role to achieve the carbon neutrality by 2050. Helen will achieve carbon neutrality by 2030 mainly by non-combustion technologies but sees that the fossil natural gases can ensure the security of supply in case of uncertainties in 2020’s. Helen sees that the renewable and climate-neutral hydrogen acts the important role to decarbonize fossil-based mobility as well as the industrial processes what are hard to abate. Helen thinks that the gas market directive should primarily create fair and transparent market rules for the renewable and climate-neutral gases that guides the actors towards carbon-neutrality and accelerate the green transition in the EU. Helen sees that the clear and technology-friendly regulation is the premise that the EU can achieve energy independency from the Russian fossil fuels by 2030. Helen sees that the upcoming hydrogen market plays the important role in decarbonisation of European energy sector. To accelerate the decarbonisation of European energy sector, it is necessary to implement the transparent and market-based rules for the hydrogen market. Helen supports the Finnish Energy’s views to base the hydrogen market rules on methane gas market’s rules. By 2030 it should be existed the clear rules between grids, producers as well as end-users what accelerate the decarbonisation. Helen sees that the well-functioning and decentralized gas market will decrease the EU’s dependency on Russian gas. Helen finds it is necessary to rethink the gas taxation and border tariffs between Member States to accelerate the creation of the European Energy Union where liquid and gaseous fuels play the important role. Helen sees the one of the important goals in the European Energy Union is to cut the gas dependency of Russia and meanwhile the reaching of climate goals. The legislative flexibility and technology neutrality are necessary to be included in the European legislation. With kind regards, Dr. Sari Mannonen, Senior Vice President, Solutions and Portfolio Development Ms. Maiju Westergren, Senior Vice President, Sustainability and Public Affairs
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Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

24 Mar 2022

Helen supports the European Union’s goal to reduce CO2-emissions -55 % by 2030 and sees that the energy efficiency in the buildings acts the important role to achieve the carbon neutrality. Nevertheless, Helen considers the Commission’s proposals to the legislation of heating sector. The Commission has proposed and defined the energy efficient district heating system in the article 23 of the renewable energy directive (RED) and in the article 24 of the energy efficiency directive (EED) with the additional renewable energy sources in the DHC-production. Helen sees that the utilization of the waste heat and cold in the DHC-production will increase the energy and resource efficiency, and waste heat and cold should be included in the definitions of the energy efficient district heating system. Helen understands the differences between the DHC-networks in Europe and supports the possibility to review nationally the energy efficiency of the DHC-networks. Helen finds it is necessary to consider the importance of the energy use of the attention buildings to the entire energy system in the regulation of construction. Helen sees that the controlling the amount of purchased energy in the individual buildings is only a partial optimization. Helen finds the buildings’ energy performance regulation should not be directed at choosing a particular form of heating at all, but it should be directed at reducing a buildings’ CO2 emissions and energy needs. In the view of climate and energy efficiency, on-site renewable energy should be of the same value in terms of emissions and energy efficiency as renewable energy purchased through the grid. The proposed EPBD favours on-site specific solutions. Helen is the biggest DHC-company in Finland and has a fifth largest district heating network in the world. Helen will reach the carbon neutrality by 2030 mainly by non-combustion technologies what utilize waste heat and cold from the industry and the society. Moreover, the DHC-sector in Finland will reach the carbon neutrality in eight years. Helen sees that the proposed directive on the energy performance of buildings does not recognize Nordic climatical and regulatory circumstances, limit the innovation and development in heating and cooling sector, and in fact does not promote energy and resource efficiency of the energy sector. Helen sees that the treating on-site and central renewable energy sources equally is the right signal to decarbonise buildings and reward sustainable energy. Helen supports the Commission’s proposals to develop digital solutions to increase energy efficiency in the DHC-networks. Helen supports the European Commission's proposed change in the Article 12 concerning EV recharging points and related pre-cabling obligations and finds them as necessary regulation development. The EV recharging points are needed especially in the buildings' parking spaces where cars inherently are parked for longer periods making it convenient place to recharge. Smart charging is necessary to minimize electrical system's over-load as well as to maximize the use of renewable and clean electricity in the e-Mobility. Helen thinks that the e-Mobility will be electrified in the future and demands the European Commission to represent the legislation what is predictable and enables the climate-neutral development. Helen asks the Commission to review the proposed EPBD in view of “Energy Efficiency First” principle as well as technology and climate neutrality. Helen strongly supports Commission’s ambitious to strength Europe’s energy independence what should be achieved mainly by the European energy sources and cutting the Europe’s energy dependence from the Russian fossil fuels.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

18 Nov 2021

Helen Ltd. is the second biggest energy company in Finland and has the fifth largest district heating network in the world. Helen Ltd. is reaching the carbon-neutrality latest by 2030 based on renewable energy sources especially societal and industrial waste heat and cold. In Helen Ltd.’s view, the EU should be reached Paris Agreement’s goals as soon as possible and limit global warming by 1,5 degrees. The promotion of the renewable energy sources is an important element to tackle climate change, but we highlight that all energy sources must be used by the energy efficient way. Helen Ltd. welcomes warmly the European Commission’s ambition to increase goal of the renewable energy sources from 32 % to 40 % by 2030. Utilization of waste heat and cold in the DHC system increases the energy efficiency The “Energy Efficiency First - principle” in the article 3 of the EED requires that waste heat should be equate to renewable energy. Helen Ltd. sees that the utilization of the waste heat should be prioritized over the primary renewable energy sources. Helen Ltd. recommends the European Commission to review the utilization of waste heat and to observe if the share of the waste heat and cold may arise to 50 % of the total renewable energy use. The raised share of the waste heat and cold in the use of the renewable energy sources should be noted also in the article 15a of the RED which sets renewable energy utilization in the construction sector of 49 % because the DHC-system includes also in the construction sector. The EU should not tighten the sustainability criteria for the bioenergy In article 29, the European Commission has opened the sustainability criteria for bioenergy widely and defined them unclearly. Helen Ltd. calls the European Commission to use the established terms of the forest-based bioenergy or to define the new terms seamlessly to avoid misunderstandings. Hydrogen can be a solution to reach decarbonisation in the sectors that are hard to decarbonized. Necessity to develop hydrogen towards highly energy-efficient pathway. Inserting the new article 22a, which aims to increase renewables in hydrogen final energy consumption and used as a feedstock in industry is seen as an effective measure for decarbonization of hard-to-abate sectors Please read our more detailed positions attached.
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Response to Review of Directive 2012/27/EU on energy efficiency

16 Nov 2021

Helen Ltd. is the second largest energy company in Finland with the 1.8 million consumers. Helen Ltd.’s district heating network is the fifth largest in the world and we are reaching the carbon-neutrality by 2030 based mainly by the non-combustion technologies. Already today but in much larger scale in the future Helen Ltd. will utilize widely urban and industrial waste heat and cold proceed by heating pumps in the district heat and cold production. In Helen Ltd. we find waste heat and cold re-utilisation as an energy efficient and resource wise way for the energy production in the future. Helen Ltd. supports Commission’s proposal to increase energy efficiency goals to 36-39 % as well as a new annual energy saving obligation to 1,5% for the period 1.1.2024-31.12.2030. The renewed energy efficiency goals need to be implemented in national, not company level because of the technology neutrality. Helen Ltd. finds that in the national energy efficiency contracts are necessary to maintain the voluntary elements that encourage actors to the energy efficiency acts. The tightened energy efficiency goals will refuse climate change, slow the loss of biodiversity in Europe as well as guide actors towards the more sustainable pathway. European Commission seems to have forgotten “Energy Efficiency First” principle in the proposed legislation under Fit for 55 -package. Promotion of the renewable energy sources are preferred to reused and recycled energy sources in the Energy Efficiency Directive as well as in the Renewable Energy Directive. In the proposed legislation the definition of the energy efficient district heating and cooling (DHC) is unclear between EED and RED and it is unsecure which directive should be applied in the concrete. Helen Ltd. sees the purpose of the EED is primarily to increase the level of the energy efficiency in the EU and secondary to guide actors towards the “right” technologies defined by the Commission. Helen Ltd. finds the interrelated legislation in Fit for 55 -package as a problematic aspect in the legal implementation. Consistent and clear EU-legislation increases investment security and makes possible to guide resources for the climate actions in the energy companies. Helen Ltd. sees in the positive light that the Commission will propose deflections for the DHC-systems to reach the goals of the RED but though encourages the Commission to note “the Energy Efficiency First -principle” also on the RED. In the proposed articles concerning the definition of the energy efficient district heating and cooling cogeneration, the Commission will settle the goals for 2025 that it could include 50 % waste heat, renewables or CHP and increasing the share until and by 2050 to define the system that utilizes only renewable or waste heat using renewables at least 60 %. Helen Ltd. proposes the Commission to review the articles and to settle goals for 2045-2050 the share of renewables at least 30 % and by 2050 the share of the renewables at least 40 %. Helen Ltd. recommends the EU to deal the articles on waste heat and cold, efficient DHC as well as energy efficiency under EED and RED together that secures consistent legislation for the Member States. Helen Ltd. highlights the necessity to renew the definition of waste heat what has limited to industrial and commercial real estates in the current legislation. For the wider utilization in the waste energies the definition should be extended also in the residential buildings. Only with the inclusive approach the climate crisis could be solved in the future.
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Response to Land use, land use change and forestry – review of EU rules

8 Nov 2021

Helen Ltd. thanks the European Commission for the opportunity to give feedback on the Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Regulations (EU) 2018/841 as regards the scope, simplifying the compliance rules, setting out the targets of the Member States for 2030 and committing to the collective achievement of climate neutrality by 2035 in the land use, forestry and agriculture sector, and (EU) 2018/1999 as regards improvement in monitoring, reporting, tracking of progress and review. Helen Ltd. is the second largest energy company in Finland with the 1.8 million consumers. Helen Ltd.’s district heating network is the fifth largest in the world and we are reaching the carbon-neutrality by 2030 based mainly by the non-combustion technologies. In the future Helen Ltd. will utilize widely urban and industrial waste heat and cold proceed by heating pumps in the district heat and cold production but also by secondary forest-based biomass in energy production. In Helen Ltd. we find an energy efficient and a resource wise production as an only way to reach the climate goals and to minimize the environmental footprint of the energy production. Helen Ltd. supports European Commission’s proposal to implement the calculation of carbon sinks based on climate emissions inventory from 2026. Helen Ltd. thinks the emission calculation should introduce globally what demands the harmonisation of the emission calculation rules in the international decision-making. To achieve a global emission calculation, it should be based on voluntary acts but also the EU may encourage the developing countries with the economic support. Only with the transparent and sustainable decision-making we will reach the global emission goals in world-wide. In the review of the regulation of the LULUCF it is necessary to recognise Finland’s role as a forestry-based economy what means not to limit forest-based biomass use in the energy production. Helen Ltd. follows concerned Commission’s proposal to guide biomass utilization what may have negative social impacts in Finland for example by decreased standards of living and housing in urban neighbourhoods. Helen Ltd. encourages the Commission to review the impacts of the LULUCF in the EU-wide and to study how to introduce emission capturing also with non-biological technologies. Helen Ltd. welcomes warmly Commission’s proposal to wide LULUCF also to the agriculture sector by 2026 and beyond that. Only with the inclusive acts the EU can demonstrate climate leadership globally. Helen Ltd. thanks the European Commission on the possibility to give feedback on the regulation of the LULUCF and requests that the European Commission will review the proposal in the global and technology neutral context.
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Response to Revision of Alternative Fuels Infrastructure Directive

15 Oct 2021

Helen Ltd. thanks the European Commission for the opportunity to give feedback Commission’s Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on the deployment of alternative fuels infrastructure, and repealing Directive 2014/94/EU of the European Parliament and of the Council. Helen Ltd. is the second largest energy company in Finland and believes that the electrification of the society will be the sustainable and economic-wise pathway to reach Paris Agreement’s climate goals, refuse the lack of biodiversity and make socially inclusive change. In Helen Ltd.’s business the electrification moves forward in the DHC sector in Helsinki but we want push forward the electrification in transport sector as well. Helen Ltd. is keen to accelerate the adoption of eMobility in Finland and offers charging solutions and digital services that have been developed together with the customers. Digitalisation is needed to accelerate in user-friendly recharging infrastructure. European Commission proposal of the regulation for the alternative fuels infrastructure includes several proposals what slow down the e-mobility recharging infrastructure. In article 5, point 2, Helen Ltd. finds the legislation should not obligate the operators nor the owners build payment card readers in the recharging points because it will incur unreasonable costs for them compared to current expected customer kWh-prices and hence potential income.. Helen Ltd. sees that the payment transaction should be performed primarily by the digital application, and we are strongly disagreeing the obligations concerning physical card readers. In article 5, point 5 there are requirement for the “clearly displayed” in price per session, price per minute, price per kWh what has been defined unclearly. Helen Ltd. sees that the pricing and the billing could be announced via mobile application or website of the operator. There should not be obligation to announce this information in the recharging points. Helen Ltd. find the digitalisation as a functional platform to develop e-mobility services. Helen Ltd. strongly supports supports the proposal in Article 6 that requires eMobility service providers to offer transparent and reasonable recharging services without any discrimination. Helen Ltd. finds that including roaming in this Article as written, will inevitably enhance the transparency. Helen Ltd. highlights that the EU legislation needs to be predicable, future oriented and accelerating for the new and climate-neutral technologies that we can refuse climate and environmental risks in the future. Helen Ltd. sees that the companies have an important role to implement carbon-neutral innovations in concrete what requires unambiguous and ambitious legislation by the European Commission.
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Response to Updating Member State emissions reduction targets (Effort Sharing Regulation) in line with the 2030 climate target plan

11 Oct 2021

Helen Ltd. thanks the European Commission for the opportunity to give feedback on regulation of the European Parliament and the Council amending Regulation (EU) 2018/842 on binding annual greenhouse gas emission reductions by Member States from 2021 to 2030 contributing to climate action to meet commitments under the Paris Agreement. Helen Ltd. strongly supports market-based EU emission trading system and welcomes warmly the widening of the EU ETS to the road transport and buildings’ heating. Only with the well-functioning emissions reduction systems we can reach Paris Agreement’s goal to limit climate warming to the 1.5 °C. Helen Ltd. finds the Effort Sharing Regulation as an important way to reduce emissions in Europe outside the EU ETS. The recently settled -40 % emission reduction goal in the ESR sectors will be reached by 2030. European Commission’s proposal to wide the EU ETS regulation to the road transport and buildings’ heating will effectively accelerate the emission reductions in the fossil-intensive sectors. Helen Ltd. finds the electrification in the transport sector must be quickly accelerated and in the e-mobility charging points should be preferred climate-neutral electricity to the fossil-based. There are still considerations in the double regulation between “the EU ETS” and “ETS of the transport” what must be solved before the implementation of the regulation. Helen Ltd. finds the EU climate regulation must be predictable and overlapping regulation must be avoided. Helen Ltd. finds the centralized, decarbonized and energy efficient district heating and cooling system as a cost-efficient and sustainable ways to reach Paris Agreement’s goals in the heating system. Fossil-based buildings’ heating includes coal, natural gas and oil which must be disposed as soon as possible. The proposed emission trading system in the buildings’ heating sector will act an effective role in the decarbonisation of the heating sector. Helen Ltd. sees it is necessary to safe first the coherence between the separated emission trading systems what means to develop the ETS of the buildings’ heating as a market-based and well-functioning system before compounding it in “the main EU ETS” by the end of the decade. Helen Ltd. calls the European Commission to set the reduction of the climate emissions in the first place to decarbonize the energy-intensive sectors in the EU. Helen Ltd. highlights technology neutrality and the strengthening of the EU-wide market-based emission reduction tools are necessary for the reach Paris Agreement’s goals and prevent climate change as well as the lack of biodiversity in the future.
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Response to Updating the EU Emissions Trading System

27 Sept 2021

Helen Ltd. thanks the European Commission for the opportunity to give feedback on Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Directive 2003/87/EC establishing a system for greenhouse gas emission allowance trading within the Union, Decision (EU) 2015/1814 concerning the establishment and operation of a market stability reserve for the Union greenhouse gas emission trading scheme and Regulation (EU) 2015/757. Helen Ltd. sees it is necessary to reduce climate emissions as soon as possible that reach the European carbon-neutrality latest by 2050 and implement the new European climate target -55% by 2030 as well as -61 % within the EU ETS. Helen Ltd. will reach the carbon neutrality latest by 2035 and finds the EU ETS as an effective way to cut the climate emissions by market-based way. In the concrete Helen Ltd. recently decided to close Hanasaari coal-based power plant almost 2 years earlier as planned because of the raised price of the EU emission allowance. EU ETS push forward the energy sector to clean the production and move towards carbon neutral solutions. Helen Ltd. invests drastically to non-combustion technologies e.g. heat pumps and we highlight predicted investment environment. Helen Ltd. highlights it is necessary to finalize the EU ETS regulation in a moment that actors get started the emission reductions as soon as possible within the businesses. It is necessary to notice “the EU ETS I” is high functional system what should be completed as a detached legislation from other legislative proposals. In a moment accepted directive of the EU ETS will signalize to the actors in the energy production and the industry investment security as well as will stabilize the process towards the carbon neutral future. There are several confluences between EU ETS, CBAM and the proposed emission trading system of the road transport and buildings’ heating under the ESR. There are many political risks what may weaken the completing of the EU ETS. The functionally of proposed and detached elements of the wider EU ETS should be observed first and be combined later to the original EU ETS. Helen Ltd. calls all actors to reduce climate emissions globally as well as in the European Union that prevent climatical and environmental disaster within the Union and our neighborhood. For the wider climate emission reduction Helen Ltd. welcomes warmly the Commission’s proposal to extend the utilization of the EU ETS mechanisms to the new sectors. Only with the inclusive pathways we will reach the carbon neutrality as soon as possible. Market stability reserve of EU ETS needs to be predictable. Helen Ltd. finds the proposed buffer mechanism of the MSR as a stabilizing element for the emission allowance market and it improves the functionality of the market and build up the predictability. Helen Ltd. supports strongly a raised role of the Innovation Fund that encourages green and carbon neutral investments in the EU. The proposed Carbon Contracts of Difference is an encouraging element in the EU ETS and directs actors to green investments and technologies. Helen Ltd. find the potential of hydrogen strongly and hopes that hydrogen solves decarbonization questions in the industry. Integration between hydrogen production and district heating system will present cross-sectoral energy efficiency and resource efficiency in the future.
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Response to Guidance on REDII forest biomass sustainability criteria

28 Apr 2021

Helen Ltd, Finland, is Helsinki-based energy company and represents over 550.000 consumers in electricity and heating all around Finland. 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 for 2035. In addition Helen has been committed to Science Based Targets (SBT) as a first energy company in Finland. Currently biomass is the most prominent renewable energy source in Finland and it has an effective role as a transitional technology towards EU carbon neutrality 2050. Helen’s goal is to reach carbon neutrality for 2035 what will be reached mainly by non-combustion technologies (e.g. heat pumps, waste heat and new technologies) but also by bio-based combustion technologies. Helen Ltd believes that the Renewable Energy Directive’s guidance on the sustainability criteria for forest biomass used in energy production should not revised. RED II has been just implemented in the Parliament of Finland and has been introduced to forest-based industries in Finland. If the Renewable Energy Directive’s sustainability criteria for forest biomass used in energy production will be revised again along with the revision of the Renewable Energy Directive, it will weaken the predictability for carbon-neutrality investments, creates instability for the energy sectors as well as negatively affects the responsibility of supply chains. Helen is reaching the political stability for the actors under RED2 forest sustainability criteria and believes it would be best to revise sustainability criteria at the end of 2020 decade. We support Finnish Energy’s proposals for the Renewable Energy Directive’s sustainability criteria for forest biomass used in energy production of the forest biomass appendix and RED2 guidance. Helen Ltd.’s key messages to the review of the sustainability criteria for forest-based biomass used in energy production under the Renewable Energy Directive: 1. Sustainability criteria for forest-based biomass used in energy production should not revised 2. Ensure that forest-based biomass will be seen as a renewable energy source equally with the others renewable energy sources (e.g. water, 3. Emphasize the important role of long-term policy planning tools in the energy transition towards EU carbon neutrality 2050 4. Recognize Member States’ special features in the energy-transition towards EU carbon neutrality by 2050 and forest-based industries’ importance for Finland 5. Highlight the role of the EU ETS as a mechanism for GHG’s emission reductions 6. Prefer secondary forest-based biomass to primary forest-based biomass in the energy production
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Meeting with Risto Artjoki (Cabinet of Vice-President Jyrki Katainen) and Blic Oy

24 Jan 2019 · Future of energy policy