Hrvatska elektroprivreda d.d.
HEP
HEP is the national energy company dealing with generation, distribution and supply of electricity, as well as distribution and supply of heat energy and natural gas to customers.
ID: 555152496638-91
Lobbying Activity
Response to Revision of the EU’s energy security framework
13 Oct 2025
We welcome the revision of the EU energy-security framework and support Policy Option 1 Smart Streamlining as the basis for a balanced, market-driven and coordinated approach. The 20212023 crisis proved that competitive markets and regional cooperation restored supply faster than ad-hoc interventions. The future framework should preserve market integrity, energy system integration, simplify governance and keep emergency tools exceptional and temporary. 1 Market-based security and supply standards EU-wide protected-customer concepts and supply standards can strengthen coherence if applied flexibly. An electricity supply-standard must also value demand-side flexibility and distributed storage, together with existing power plantsnuclear, pumped hydro and thermalwhich repeatedly stabilised grids and prevented blackouts. Gas-storage targets should remain risk-based and regularly reviewed. Technical requirements of Regulation (EU) 2017/1485 and market-based services aligned with EMD, CACM 2.0 and FCA 2.0 must be respected, together with pre-existing interstate agreements forming the EU acquis. 2 Infrastructure standards and diversification Re-examining regional N-1 criteria in a flow-based approach (considering significant loop-flow impacts) and setting similar metrics for DSOs can improve preparedness. Diversification must stay multi-layeredgeopolitical, infrastructural and technologicalcombining regional interconnections with local low-carbon production that provides real flexibility. Policy should use incentives rather than obligations and encourage new interconnectors to reduce congestion rents and costly remedial actions. 3 Resilience and risk mapping Resilience must integrate cyber, climate, governance and workforce dimensions, to protect critical energy infrastructure. The framework should require systematic cross-sector risk mapping while keeping sector-specific operational analyses. Climate adaptation and secure EU-based supply chains are now essential elements of energy security. 4 Crisis management and solidarity Alignment between gas and electricity crisis levels is useful if it simplifies coordination. An EU emergency plan should clearly distinguish a tight market with high prices from a true physical shortage that activates solidarity. Market prices must remain the main allocation signal; temporary interventions should protect only vulnerable customers. 5 Practical example CCGT Jertovec (Croatia) The CCGT Jertovec site in northern Croatia provides unique ancillary services vital for grid stability: black-start, island-mode, redispatch and mFRR, with fast-start thermal backup (<15 min). It is designated as critical infrastructure by the TSO. Its environmental permit under Article 33 of the IED expired end-2023, yet DG Environment confirmed (10 July 2025) that emergency operation up to 500 h/year is legally permissible, proving that environmental compliance and energy-security needs can coexist. A major modernisation approved 20242025 is transforming the plant into a hybrid, low-carbon hub: replacement of 31.5 MW gas turbines with H-ready units, addition of a 16 MW / 32 MWh battery, 14 MWp solar PV and a 9 MW PEM electrolyser. This configuration provides fast balancing, black-start capability and renewable integrationshowing how dispatchable plants evolve into multi-technology resilience nodes. Its location links directly to the CroatiaSlovenia Smart Gas Grid from ACERs 2025 draft PCI list, enhancing fuel diversification and cross-border coordination. Together these projects form a practical, integrated security architecture, fully aligned with An EU Strategy for Energy System Integration. 6 Policy implications Maintain market-driven allocation and evidence-based emergency powers. Recognise low-hours dispatchable assets as part of resilience mapping. Support hybridisation of existing sites through streamlined permitting. Align risk-preparedness and crisis-response frameworks across sector
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