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Holding Slovenske elektrarne d.o.o.

HSE d.o.o.

Holding Slovenske elektrarne (HSE) is Slovenia's largest producer of renewable electricity, specializing in hydropower, solar, and wind energy.

Lobbying Activity

HSE Group calls for extending EU Modernisation Fund beyond 2030

3 Jul 2025
Topic — This consultation reviews the EU Emissions Trading System and Market Stability Reserve.
Message — The group requests extending the Modernisation Fund beyond 2030 to ensure long-term project stability. They also demand simpler state aid procedures and measures to stop speculative trading.123
Why — This would provide financial predictability and reduce the bureaucratic burden for large energy investments.45
Impact — Financial speculators would lose market access if trading is restricted to industrial players.6
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Meeting with Ditte Juul-Joergensen (Director-General Energy)

3 Jul 2025 · Nuclear, Roadmap

HSE Group urges EU to extend Modernisation Fund beyond 2030

12 May 2025
Topic — The Commission is evaluating the operating rules of the EU Modernisation Fund.
Message — The group advocates extending the fund beyond 2030 to support long-term energy projects. They also call for simplified and accelerated state aid procedures to reduce delays.12
Why — This would ensure long-term predictability and funding for large-scale renewable energy infrastructure projects.3
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Meeting with Maroš Šefčovič (Commissioner) and

30 Jan 2025 · Economic and Energy Security

Response to Recommendation to promote the development of innovative forms of solar energy deployment

2 Apr 2024

HSE Group remains strongly committed to contributing to achieving the European Green Deals objective of climate neutrality by 2050 and welcomes the European Commissions proposal that aims to prepare the guidance on innovative forms of solar energy deployment. Our aim is to further increase the volume of electricity production from renewable energy, both in the light of replacing production from fossil fuels, as well as contributing to reaching national emission reduction and renewables targets. We plan to invest in different renewable energy sources, besides large and small hydro, PV, wind, geothermal, also in what the Commission considers innovative forms of solar energy technology floating PV, transport infrastructure PV and Agri-PV. The European Commission and the Member States have already taken a series of measures to promote an accelerated transition to renewable energy. Significant progress has been made over the last two decades in supporting investment, as well as the continued promotion of innovation and the development of new technologies for the sustainable use of renewable energy. It is known that there are differences between Member States in the permitting process for the construction of industrial and infrastructure objects, which are the result of differences in national legislation. We propose that the guidelines contain recommendations to reduce possible differences between Member States in order to ensure equal starting points for all potential investors in the permitting procedures for innovative technology projects. You will find the detailed recommendations in the attached file.
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Response to Guidance to facilitate the designation of renewables acceleration areas

22 Feb 2024

HSE Group remains strongly committed to contributing to achieving the European Green Deals objective of climate neutrality by 2050 and welcomes the European Commissions proposal that aims to prepare the guidance on designating renewables acceleration areas.The reform of climate and energy legislation as part of the Fit for 55 and REPowerEU package marks an important step towards enabling Member States to accelerate the green transition. One such measure is also designating renewables acceleration areas. To use all potential of hydropower and its role in the renewed energy market design, we call on the Commission to draw up guidelines based on technological neutrality and that recognise the importance of hydropower and all renewable sources that can contribute to the EU's 2030 climate target. To make the necessary investments, hydropower needs to be given the same starting point and incentive measures as other renewables. One such measure is the establishment of acceleration areas for hydropower. 15 of the 18 EU Member States that have submitted their revised National Energy and Climate Plans (NECPs) by the required deadline are planning to use hydropower to increase the share of renewables. Therefore, in our response to the European Commission's consultation on the development of guidelines for the designating renewables acceleration areas, we call on the Commission to address ALL renewable energy sources as defined in the article 2 of Directive on renewable energy (recast), and not just wind and solar energy. It should be left to each Member State to decide for which technologies and resources it will designate priority areas for accelerated deployment, as foreseen in Article 15c(1) of the Directive on renewable energy (recast). We justify our proposal on the following arguments: Hydropower is an important source of renewable energy whose potential has not yet been fully realised in the EU. Hydropower is important for ensuring a secure and safe electricity supply and flexibility of the electricity system. Hydropower is a sustainable source of renewable energy. The choice of energy mix and therefore the choice of technologies to be covered by acceleration areas should be left to Member States. Consistency of EU policy and advocating technology neutrality and the importance of all available renewables. Hydropower represents a mature technology; the EU has the knowledge and capacity to produce the necessary technological equipment. Multifunctional benefits and use of hydropower plants infrastructure. To speed up the implementation of the projects already planned, we propose to the Commission to call on the Member States to include into renewable acceleration areas all areas covered by spatial plans for new energy infrastructure, for which a spatial planning process has already been carried out at the level of each state, which also included environmental impact assessments. Finally, the European Commission stressed the importance of hydropower in achieving the renewables target and its relevance for energy storage in its impact assessment, accompanying the Commission's Communication on the EU 2040 climate target.
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HSE Group Calls for Voluntary Contracts and Storage Incentives

22 May 2023
Topic — The consultation addresses reforms to make the EU electricity market more resilient.
Message — Public guarantees for long-term contracts should be available to producers and consumers. Price support schemes must remain voluntary rather than mandatory for member states. Network tariffs should reward storage systems like pumped hydro to incentivize investments.123
Why — Exempting pumped hydro from grid charges would protect the profitability of their assets.4
Impact — Consumers could face financial penalties for switching electricity suppliers before their contracts expire.5
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Response to Interservice consultation on the electricity market design reform - REMIT

22 May 2023

HSE Group proposes the amended REMIT Regulation to include: a mandate to ACER to define, in close cooperation with National Regulatory Authorities, thresholds for the identification of events which constitute inside information for the purposes of its publication, a clearer definition of contracts for the supply and distribution of electricity or natural gas for the use of final customers being considered wholesale energy products, a clear provision that market participants shall not be responsible for failures in the completeness, accuracy or timely submission of the data which are attributable to the IIPs or RRMs technical or other problems, an obligation for ACER to always consult market participants on guidelines and recommendations which it issues, the continuation of Member States competence to determine the rules on penalties for the violation of the REMIT Regulation. You can find our detailed position, including amendment proposals, in the attached document.
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Response to Fitness check of how the Polluter Pays Principle is applied to the environment

9 Dec 2022

HSE welcomes opportunity to comment on the initiative Polluter Pays Principle fitness check of its application to the environment. Please find our contribution attached.
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Slovenian power giant HSE seeks hydropower safeguards in restoration law

17 Aug 2022
Topic — The European Union is proposing mandatory targets for restoring degraded natural habitats.
Message — HSE Group demands a balance between nature restoration and renewable energy expansion. They want river restoration rules restricted to obsolete barriers to protect existing power plants.123
Why — This would shield the company from asset removals and additional environmental compliance costs.45
Impact — European biodiversity goals for free-flowing rivers may be harder to reach.6
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HSE Group warns methane rules threaten coal mine safety

17 Apr 2022
Topic — New EU legislation aiming to monitor and reduce methane emissions in the energy sector.
Message — HSE Group requests an exemption from the methane venting ban for underground lignite mines. They argue venting is a crucial safety measure and current reduction technologies are too costly for mines slated for closure.123
Why — Exemptions would prevent costly investments in a mine scheduled for closure by 2033.45
Impact — Environmental groups lose as the energy sector fails to achieve rapid methane emission reductions.6
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Response to Revision of EU rules on Gas

1 Apr 2022

HSE Group welcomes the process of revising existing EU rules in the gas market with the aim to facilitate the integration of renewable and low-carbon gases. We believe that this is an utmost necessary step in achieving a completely functioning internal energy market and ensuring security of supply as well as competitiveness of the EU industry. HSE Group is convinced that gaseous fuels, mostly hydrogen, biogas and biomethane will not represent a leading vector in the energy transition, but rather a step in the right direction. In the light of recent geopolitical and unprecedent energy price challenges HSE Group supports the intention of the European Commission to decrease dependence on Russian gas and diversify gas supply routes to the EU as well as protect consumers and industry from rising energy prices. The gas package revision should reflect these proposals to prove more robust and fit to tackle any further challenges that may arise in electricity and gas markets. To summarise, gas legislation revision should: 1. Ensure consistency of gas legislation with all relevant legislative initiatives of the Fit for 55 package (especially revision of the EU ETS Directive, RES Directive, Methane Regulation) as well as recent regulatory proposals arising to tackle EU’s dependency on Russian gas and high energy prices (namely the revision of the Security of Gas Supply Regulations); 2. Recognise that natural gas will most certainly still be present in the EU energy mix in the next decades, alongside processes of diversifying gas supply routes to the EU; 3. Ensure consistency of revised gas legislation with the Delegated Act 2021/2139 and the inclusion of natural gas as a transitional fuel in the EU Taxonomy; 4. Consider local specificities and influence on neighbouring countries in establishing regional markets and enhanced cooperation between Member States at a regional level; 5. Include estimations on large hydrogen storage development, proposals for measures and incentives and clearly set targets in this area, as well as the analysis of import options of various forms of green hydrogen to the EU, especially from countries with high solar energy potential; 6. In implementing the possibility to extend permitting for one year due to extraordinary circumstances, clearly define these extraordinary circumstances; 7. In the initial phase, where natural gas and other gases will be used simultaneously, guarantee a leading role of existing gas network operators; 8. Carefully consider options for the Member States to intervene on the retail market to ensure consistency with principles of free functioning of the market and market-based price formation; 9. Strive for a gradual approach to blending of hydrogen into existing gas networks and in the first phase, for the implementation of minimal levels of blending at the EU level; 10. Within cybersecurity network code proposal advocate for uniform obligations for electricity and gas undertakings in the frame of integral network development approach; 11. Allow certain exemptions to be used only until fully functioning hydrogen market is established (presumably by 2030), for continuation of such exemptions could potentially lead do market distortions; 12. Apply possible stricter measures regarding achievement of emission savings due to the use of low-carbon and renewable gases to gas installations in accordance with the Gas Taxonomy provisions; 13. Include an obligation for the Commission to assess the likelihood of achieving the goals related to market and network development by 2030 and propose additional measures and incentives as soon as possible, should they deem necessary;
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HSE Group Opposes Shifting Carbon Revenues to EU Budget

18 Feb 2022
Topic — This consultation concerns a proposal to amend the European Union's own resources system.
Message — The group wants carbon auction revenues to stay with Member States for climate projects. They oppose using these funds to repay debt from the COVID-19 recovery fund.12
Why — Keeping these funds locally would protect the financing of their renewable energy transition.34
Impact — The European Union's central budget loses a revenue stream for pandemic debt repayment.5
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Response to Revision of the Energy Tax Directive

11 Oct 2021

Energy taxation directive review sets new principles in the field of energy taxation and brings unification of tax rates at the EU level. HSE Group believes that the proposed Directive lacks a clear role of taxation policies of energy products and electricity in the process of decarbonisation and phasing-out of fossil fuels, which are produced or used in the regions that are recognised as regions in the process of restructuring and coal phase-out based on just transition principles. We therefore propose to enable coal regions in transition to coordinate energy taxation policies with coal exit strategies with a view to implement economically viable and socially acceptable just transition measures. Member States need to autonomously determine their taxation policies in coal regions, considering the fact that fundamentals of energy taxation policies lie in exclusive competences of each Member State.
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Response to Review of Directive 2012/27/EU on energy efficiency

11 Oct 2021

HSE Group, as a strong advocate of an inclusive and just energy transition, supports clearer commitments for the Member States regarding the protection of vulnerable consumers as well as prioritisation of energy efficiency measures with end users and vulnerable groups to reduce energy use. We welcome the establishment of new EU instruments to reduce energy poverty, including the new Social Climate Fund, as the burden of preventing energy poverty must not be shifted to electricity producers or final consumers in the form of additional contributions or levies. The effects of accelerated electrification of final energy consumption, a special emissions trading system also in the field of road transport and buildings, and high CO2 prices must be responsibly addressed since the negative consequences will be mostly born by end users. Despite large investments in new energy capacities, the aim should also be to ensure that citizens are not exposed to social risks. HSE Group as part of the energy sector is bound to transition to climate neutral society and is, with this aim, implementing all the necessary measures. But we believe that despite accelerated decarbonisation process an additional potential to achieve energy savings exists in the regions that are currently in the process of phasing out fossil fuels. Energy transition processes and timelines differ between Member States based on their national specificities.With this aim we propose an exemption from the proposed provision (that energy savings as a result of policy measures regarding the use of direct fossil fuel combustion shall not count towards the energy savings obligations from 2024 onwards) for regions, that are identified in territorial just transition plans approved by the Commission. Increasing energy efficiency represents a key element for ensuring security of supply, as stems from the preamble 26 of the Directive EU 2018/2002. It is therefore relevant to tap all the available potential to achieve energy savings in the EU.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

11 Oct 2021

In order to achieve more ambitious GHG emissions reduction target - 55% by 2030 compared to 1990 levels, the European Commission proposes the increase of the share of RES in final energy use from currently set 32% to 40% by 2030. At the EU level this means doubling the share of RES in only one decade, since the current share of RES in final energy use is only 20%. HSE Group supports more ambitious goals in the field of renewables and welcomes the fact that the provision remains binding only at the EU level, but left to Member States to determine their national contributions based on their national specifics, available natural resources, and environmental limitations with a view to ensure consistency between different policies and measures. Slovenia will have to significantly increase the share of RES from currently set 27% by 2030, which will be especially challenging considering the 38% share of NATURA 2000 sites – the largest share of all EU Member States, which makes developing and spatial planning of RES projects very difficult. HSE Group as the largest producer of renewable electricity in Slovenia will endeavour to contribute to achieving Slovenia’s national share of RES with our planned hydro, solar and wind projects. We expect these projects to be recognised as projects of common economic interest and therefore eligible for fast-track permitting procedures and spatial planning, since only timely and coherent measures can ensure achieving climate and energy targets. We therefore welcome the fact that within the RED II revision the Commission recognises the need to simplify permitting procedures for RES projects and accelerate removal of administrative barriers and has bound itself to review the measures that Member states will put forward in their national energy and climate plans reviews in 2023 and even propose additional measures if needed. But we regret that proposed provisions of the revised RED II do not already more thoroughly address the issues of permitting, even though the representatives of the energy sector have already pointed out long permitting procedures as the major obstacle in achieving faster deployment of renewables during previous relevant EU public consultation processes. Without national consensus regarding permitting and spatial planning, successful achievement of renewable energy targets seems highly unlikely. HSE Group is convinced that with the RED II revision the Commission should take the opportunity to propose stricter guidance for Member States to avoid exploiting provisions of prolongation of permitting procedures for reasons that are not duly justified and in line with enhancing the use of RES and the ongoing transition to climate neutrality. Special focus and fast-track procedures should be applied for strategically important RES projects defined in NECPs and long-term climate strategies by 2050. For Slovenia, this is especially relevant in relation to planned new large hydropower projects and large wind parks, not to forget large solar power projects on degraded industrial and energy sites, including coal mines exploitation areas, which are subject to decarbonization process in accordance with just transition principles. HSE Group welcomes that cooperation in cross-border support schemes as well as cross-border opening of support schemes remain voluntary for Member States. Cross-border cooperation among EU members States can, however, be beneficial, when energy, economic and/or environmental benefits are identified. But we do not support the proposed obligation for the establishment of at least one common project between one or more Members States since such obligation can lead to inefficient projects and suboptimal solutions for the deployment of renewables. We are convinced that every Member State should be allowed to tap their own RES potential to the maximum in the most cost-effective and environmentally acceptable manner as well as to choose the option how to fill the gap.
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Response to Carbon Border Adjustment Mechanism

11 Oct 2021

HSE Group finds that free allocation of emission allowances distorts competition, so we welcome the proposal to introduce the Carbon Border Adjustment Mechanism, which should ensure that the price of imported products in the EU more accurately reflects their carbon content, and should gradually, by 2036, replace the free allocation measure in sectors facing a risk of carbon leakage outside the EU. The mechanism will also apply to imports of electricity from third countries, which could lead to a level playing field for electricity generation outside the EU, currently not burdened by the price of emission allowances. However, we draw attention to the administrative complexity of the mechanism for entities/importers of goods that will be included in the mechanism – this includes entities who have been allocated transmission capacity through explicit capacity allocation and who nominate this capacity for electricity imports; the proposed provisions burden those entities with a number of administrative, substantive and later on financial commitments, some already during the transitional period until the end of 2025. We therefore call on the European Commission to re-examine the proposed commitments with a view to their simplification.
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Slovenian HSE Group Urges Access to EU Modernisation Fund

11 Oct 2021
Topic — Review of the EU Emissions Trading System to reach higher 2030 climate goals.
Message — The group requests Slovenia's inclusion in the Modernisation Fund by updating eligibility rules to reflect national energy structures. They also demand that carbon auction revenues remain fully available to Member States for green investments. Finally, they call for faster permitting for renewable energy projects.123
Why — Accessing these funds would secure essential financing for Slovenia's costly transition from coal and nuclear power.4
Impact — The European Union's central budget would lose a revenue source intended for repaying COVID-19 recovery loans.5
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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

HSE Group notes that, unfortunately, the proposal lacks fairer distribution of burden sharing among sectors. The non-ETS sectors are responsible for almost 60% of the total emissions in the EU, but the target for reducing emissions in these sectors by 2030 at EU level will increase from 30% to only 40% compared to 2005, while additional requirements for the ETS sector are significantly higher - increase in the emission reduction target from 40% to 61% by 2030 compared to 2005. In Slovenia, 52% of non-ETS emissions are transport emissions, which means that transport in Slovenia is responsible for 32 % of the total greenhouse gas emissions. In the period 2005-2018, emissions from transport increased by 31.9%, while in the same period, emissions from electricity and heat production, which is responsible for 26% of the total emissions, decreased by 26.8%. It is therefore clear that almost 100% increase in the target - from 15% to 27% for the non-ETS sectors in Slovenia will have to be reflected in ambitious commitments and measures to reduce emissions in transport.
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Response to Revision of Non-Financial Reporting Directive

13 Jul 2021

HSE Group thanks the Commission for its opportunity to provide feedback on the revision of the Non-financial Reporting Directive. We welcome the overall sustainable finance initiative of the European Union and the Commission's plans to establish unified and transparent sustainability reporting to respond to the growing demand for information from investors and civil society. The first step in this direction is the reporting obligation for large companies resulting from the Non-Financial Reporting Directive (the NFRD), while companies that are aware of the importance of non-financial information voluntarily apply other international standards and guidelines. More detailed specification about what kind of non-financial information should companies report and in what way they should report could enable better comparability among companies in the EU. The proposal for a revised directive, which is the subject of this consultation, is a step in the right direction to ensure the necessary quality, coherence, comparability, and consistency of the information disclosed by companies. Below we provide you with our views on the on the proposal for a revised directive.
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Response to Commission Delegated Regulation on taxonomy-alignment of undertakings reporting non-financial information

2 Jun 2021

HSE Group thanks the Commission for its opportunity to provide feedback on the draft EU Taxonomy Article 8 Delegated Regulation and the proposed new rules on non-financial reporting. We support the European Green Deal and the EU's efforts to encourage investment in more sustainable activities, as part of the electricity industry we are committed to decarbonisation. HSE Group welcomes the overall sustainable finance initiative of the EU and the Commission's plans to establish unified and transparent sustainability reporting to respond to the growing demand for information from investors and the general public. However, we believe that the reporting requirements on the sustainable activities of undertakings should not further impose a disproportionate burden or lead to additional costs. We estimate that the time for implementing the new requirements for sustainable reporting is too short. Company reporting is based on established international standards and business environment requirements. It is not possible to abandon or change them immediately, so the companies will need a sufficiently long transitional period to adjust to new requirements. We propose to allow for greater flexibility by using existing performance and to set additional requirements to a minimum, but by ensuring the purpose of sustainable reporting. The draft Delegated Act (DA) provides that the rules for reporting on the share of sustainable activities in CAPEX and OPEX would come into force as early as 2022 (reporting for 2021). We propose that, in view of the very short deadlines and uncertainties associated with the unresolved status of certain activities not yet included in the first delegated act, the reporting requirements referred to in Article 8 should come into force when all uncertainties have been cleared. The Commission has not yet taken a decision on certain key activities in the energy sector, such as the production of electricity and heat from nuclear and natural gas. DA on review criteria for the remaining four environmental objectives have also not yet been adopted. A delay in the adoption of a complementary DA of the taxonomy announced on 21st April 2021 for activities not yet assessed could lead to distortions of competition if certain undertakings were required to disclose activities as 'not included in the taxonomy' simply because they have still not been considered as to their compliance with the taxonomy. Disclosure of the CAPEX share associated with a company's sustainable activity may mean disclosure of any sensitive information that represents a competitive advantage for an individual undertaking. It is also unclear how activities that are also sustainable but not included in delegated acts on screening criteria will be addressed, as such, to highlight the activities of selling electricity that can be produced by technology that is sustainable. We note that the definition of the different groups of sustainable activities in the Taxonomy Regulation and the proposed DA is not fully uniform, and there are therefore some ambiguities in this regard. We also believe that companies will have extra costs for providing data on sustainability reporting for previous five years and even more important is that this data would be dubious as the indicators were not known in the past. We can see similar problem with comparing data from year 2021 with 2022 as the methods and measurements will change. We propose that the Commission provides additional guidance in a timely manner, including a methodology for individual types of derogation and cases where the determination of individual categories of data cannot be easily divided between individual activities or that the data are being fragmented into smaller categories irrationally. All outstanding issues related to the reporting method and the determination of all sustainable activities should, in our view, be resolved before the reporting obligation for companies enters into force.
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HSE Group Urges Gas Rule Revision for Energy Integration

10 Mar 2021
Topic — A consultation on updating EU gas rules to enable renewable gas markets.
Message — HSE Group advocates for integrating electricity and gas sectors to achieve efficient decarbonization. They call for updated rules for the gas grid and the inclusion of hydrogen within gas legislation.12
Why — This would allow HSE to use gas as a flexible back-up for its renewable energy.3
Impact — Regions reliant on coal lose out as natural gas replaces coal as a transitional fuel.4
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HSE Group opposes new methane monitoring costs for coal

26 Jan 2021
Topic — The EU is proposing legislation to monitor, report, and reduce methane emissions in energy.
Message — HSE suggests prioritizing emissions from oil and gas production over the coal sector. They oppose standards causing extra costs for mining companies already phasing out coal operations. The organization requests EU funding for research on capturing methane from abandoned mines.123
Why — Avoiding these rules prevents disproportionate investment costs for mines facing imminent closure.4
Impact — Environmental advocates lose because fugitive methane from coal mining will not be accurately measured.5
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Response to Climate change mitigation and adaptation taxonomy

16 Dec 2020

HSE Group supports the EU's decarbonisation and sustainable development objectives and therefore welcomes the agreement reached on a new higher EU climate target by 2030. 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 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, including natural gas. The adopted criteria should enable transition technologies access to the necessary financial resources in order to fulfil their role in the process of moving towards climate neutrality and inform public and private investors of the sustainable nature of transition technologies, such as natural gas. The investments in the energy transition will need technology neutral and competitive enabling market and investment conditions. Therefore, we regret to see that the draft Delegated Act is not based on technology neutrality and does not recognize that all carbon-neutral technologies are needed in transition to climate neutrality. We believe that the Taxonomy needs to take a holistic approach looking at all solutions that contribute to meeting the EU energy, environmental, climate and circular economy goals. The delegated act should therefore include all available technologies that can contribute to decarbonisation and mitigation of climate change and meet sustainability criteria on a principle of do no harm. A successful energy transformation requires an adequate set of investment signals across the EU, which takes into account regional circumstances and national specifics, and ensures nobody is left behind. We therefore call for the Commission to recognise the significant regional sensitivities across Europe also through the Delegated Acts under the Taxonomy Regulation. It is also necessary to ensure that the proposed technical screening criteria, methodology and assumptions comply with the other emission efficiency thresholds that are already in force in current EU legislation. The delegated acts should not impose on Member States new, revised methodologies, nor more stringent thresholds and sustainability requirements than already existing ones under sector-specific EU regulation (such as the Energy Efficiency Directive, the Renewable Energy Directive, the Clean Vehicles Directive, etc.). Many of these regulations will be revised next year in the framework of the EU Green Deal, and the Taxonomy delegated acts should not predict any outcome of these revisions but refer to the sustainability criteria and objectives that are already defined. HSE Group welcomes a classification scheme to address what activities should be classified as "sustainable" in order to move investments to the green transition. We would, however, like to express certain concerns regarding the draft delegated act. Please find detailed feedback enclosed. 
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Response to Revision of the Energy and Environmental Aid Guidelines (EEAG)

8 Dec 2020

HSE GROUP’S INPUT Public Consultation for the Revision of the Guidelines on State aid for Environmental protection and Energy 2014-2020 (EEAG) 2 December 2020 HSE Group strongly believes that a successful transformation of coal regions is key to a successful decarbonisation of the EU. Therefore, we propose that one of the key areas that need to be given greater attention in the forthcoming EEAG review is the restructuring of coal regions and coal industry according to the principles of a just transition. It is necessary to provide an appropriate policy framework for financing projects in restructuring carbon-intensive generation of electricity according to the principles of just transition. Countries and regions that are heavily dependent on coal and other fossil fuel production will not be able to restructure based only on economic criteria. Additional instruments will need to be provided to support a just economic and social transition and the overall environmental rehabilitation of the regions concerned. The HSE Group sees decarbonisation-supporting state aid measures as a necessity for a successful clean energy transition in the EU. We support the Commission’s aim to streamline the state aid notification processes for sustainable energy projects, but are concerned about the lack of inclusion of just transition in EEAG. We propose to extend the existing guidelines in the field of decarbonisation with a special scheme for the energy transition of coal regions according to the principles of just transition. It is crucial for the HSE Group that the new rules also include a special state aid scheme for coal regions for the implementation of the Territorial Plans for Just Transition. By setting up a special scheme, state aid for projects under co-financing from the Just Transition Fund could be provided more quickly and could include a simplified procedure also for large companies. A timely, socially, and economically equitable transition from coal is important for all stakeholders, employees, regions, and energy companies, who need to be restructured in a timely manner. In addition to the specific earmarked funds under the JTF, it is important that projects and investments are therefore carried out in a timely manner, to which the ex-ante rules under the updated guidelines will apply. HSE Group generally agrees that competitive bidding is an appropriate mechanism to develop larger-scale renewable electricity projects and allocate financial support in a cost-efficient way. All RES projects, regardless of size, must be subject to the same rules - i.e. market premiums and the award of support through tendering procedures. The support schemes shall follow a market-based approach. They shall consider possible system integration costs and grid stability. However, in order to optimise cost reduction potentials, tenders and complementary policies have to be well-designed. Exceptions from tendering can be justified for small demonstration projects, immature technologies as well as in small and fragmented markets with low liquidity and no homogenous bidding structure.
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Response to 2030 Climate Target Plan

15 Apr 2020

Please find the contribution of HSE Group in attachment.
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Response to EU rules on industrial emissions - revision

9 Apr 2020

Please find the position of HSE Group in attachment.
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Response to Fast-track interservice consultation on the 'SEIP including a JTM and the JTF"

11 Mar 2020

Please see the attached file with feedback of HSE Group on the Proposal for a regulation establishing the Just Transition Fund.
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Response to Fitness Check of the Water Framework Directive and the Floods Directive

13 Nov 2017

HSE welcomes the Commission's fitness check intentions and the preparation of the evaluation roadmap for the WFD, which is the most comprehensive instrument of the EU water policy and its national implementation directly affects utilities and the production of electricity from RES - water. HSE is committed to fulfill all obligations, which derive from the relevant EU and national legislation, related to a sustainable transition into a low carbon economy. We support the intention that the fitness check will look at the relevance, efectiveness, efficiency and coherence of the WFD. We would like to point out that when implementing the directive, supporting national documents and its provisions, which derive from the WFD implementation, its is crucial to bare in mind the coherence between environmental, climate and energy targets (at the EU and national level). In the light of achieving ambitious EU (and national) RES targets, it is important to take into account, besides the energy component, also the multipurpose element of the sustainable electricity production from hydro power plants (floods protection, assuring drinking water, tourism). We therefore suport that a quantitative cost and benefit anaysis with an actual impact on business will be carried out. We believe that a more thorough public consultation on the WFD implementation (its benefits and negative impacts) needs to be carried out, so more stakeholders will be able to address different aspects, which derive form the WFD, especially when the WFD revision is planned by the Commission in the years to come. A roadmap contains this as a planned activity in the early 2018, which we warmly welcome and will gladly contribute to.
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