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IBERDROLA

IBE

Iberdrola is one of the world's largest electricity utilities and the leading renewable energy company, producing and supplying electricity to over 100 million people globally.

Lobbying Activity

Meeting with Bruno Tobback (Member of the European Parliament)

17 Dec 2025 · Grids Package

Meeting with Bernardus Zuijdendorp (Head of Unit Taxation and Customs Union) and ENEL SpA and

9 Dec 2025 · Meeting with representatives of 9 European multinationals on Pillar Two, "Side-by-Side" approach & a level playing field

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

24 Nov 2025 · Electrification Action Plan, Grids Package, Iberian blackout

Iberdrola calls for increased funding for industrial decarbonisation

12 Nov 2025
Topic — EU budget proposals for the European Competitiveness Fund 2028-2034.
Message — Iberdrola requests higher allocation for Clean Transition within the European Competitiveness Fund and clarity on Industrial Decarbonisation Bank funding. They advocate for targeting quick-impact actions like decarbonizing industrial heat processes below 500°C.1234
Why — This would increase funding for electrification projects that Iberdrola could supply and develop.56
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Iberdrola urges EU funding expansion for electricity distribution grids

29 Oct 2025
Topic — EU budget 2028-2034 for trans-European energy infrastructure networks.
Message — Iberdrola requests dedicated CEF Energy support for distribution grid investments, including grants for single-country projects with cross-border effects. They want relaxed eligibility rules, especially removing the requirement for DSO involvement at both sides of interconnections, and faster disbursement procedures.1234
Why — This would enable Iberdrola to access EU funding for distribution infrastructure while keeping network charges stable.56
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Response to Revision of the EU’s energy security framework

13 Oct 2025

Iberdrola welcomes the ECs initiative to develop an impact assessment on the revision of the EU energy security framework, as a key pillar for a secure and resilient energy supply, providing the bases for a sustainable path towards climate neutrality and enable affordable and competitive energy prices. Among the objectives and the policy options arisen, we will refer to specific elements of 3 items. Baseline scenarios ACER has published on 19/9 a position on improving and simplifying the legal framework on European grids and disclosed (28/8) a study by Artelys to support the development of scenarios for EU-wide infrastructure planning and adequacy assessments. These documents provide an assessment of the scenarios building, as well as proposals to enhance their consistency through harmonizing their process, while ensuring cooperation among MSs, TSOs, DSOs and NRAs through a robust methodological approach. The baseline scenario, against which the policy options would be considered to address the potential threats to energy security, should follow the recommendations by ACER regarding planning and adequacy scenarios, and provide a holistic and integrated view of the energy system, comprising supply and infrastructures for electricity, gases and liquids. Central projections should be based on the trends and projections assumptions, supported by the most realistic outcome for the different variables. Governance A blackout is clear evidence of a breach of the security of the energy supply, and even if locally confined, it shows an overall impact in the EU internal market. Therefore, it is key to identify the root causes and ensure that the right risk-mitigating measures are taken looking forward. According with Art. 15 Regulation 2017/1485 establishing a guideline on electricity transmission system operation, the investigation of such incidents shall be carried out by TSOs, with the involvement of NRAs and ACER upon their request. However, having TSOs judging their own actions or their piers goes in the wrong direction i.e., an evident conflict of interest. Commission should assess as an alternative to transfer the responsibility of incidents investigations to an independent body (e.g., an expert panel free of conflicts of interest, supported by consultants if needed, and under ACER and NRAs supervision). Promoting clean flexibility assets Putting in place a security and resilient energy system based on a renewable mix requires the integration of substantial clean flexibility, especially storage, to both respond to the variability of energy supply and adapt to consumers consumption patterns. In this sense, hydro pumped storage is the most cost-effective flexibility asset for long duration response. Beyond simple balancing capacity, it provides synchronous response to support system stability, security, resilience and black start. Such properties have been strongly put into value during 28/4 blackout in Spain and its restoration, as illustrated in by the Government, and in a paper published by the IHA (both attached). However, infrastructure planning was delayed by a year, impacting the timeline for network expansion and reinforcement, and connection capacity tenders (over 370 nodes and 180 GW of synchronous generation remain blocked more than 2 years). Without Access and Connection, projects cannot participate in the expected Capacity Market, obtain the Environmental assessment, or continue the permitting process. These challenges add more uncertainty to projects, increasing capital costs and challenges to manage planned equipment. The Spanish Government has recently announced a proposal to address obstacles in network planning, with the potential to unblock barriers to connection of storage projects, that is still pending. It is important that the impact assessment realistically incorporates the current challenges to deploy long duration storage, to offer effective recommendations.
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Iberdrola backs EU plans to accelerate heating and cooling electrification

8 Oct 2025
Topic — This initiative aims to accelerate renewable energy adoption and energy efficiency in heating.
Message — Iberdrola supports the strategy to decarbonize industry and improve electricity network connections. They advocate for redistributing policy costs to make electric heating more affordable for households.12
Why — Higher demand for electricity benefits Iberdrola as a global leader in renewables.34
Impact — Traditional gas heating companies face declining market share as consumers switch to electricity.56
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Iberdrola urges EU to prioritize grid access and cheaper electricity

8 Oct 2025
Topic — This consultation addresses barriers to electrification to reach the EU's decarbonisation targets.
Message — Iberdrola supports improved grid connection guidance and effective industrial decarbonization deals. They also suggest redistributing policy costs to ensure electricity remains affordable for heating households.123
Why — Faster grid deployment and cheaper electricity would increase demand for Iberdrola's massive renewable capacity.45
Impact — Fossil fuel companies lose market share as energy demand shifts toward electric alternatives.6
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Iberdrola backs 2035 zero-emission car target with infrastructure push

8 Oct 2025
Topic — Revision of EU CO2 emission standards for cars and vehicle labelling rules.
Message — Iberdrola urges maintaining the 100% CO2 reduction target for 2035 and avoiding exemptions for climate-neutral fuels. They call for stronger alignment with charging infrastructure rollout, harmonised vehicle labelling across Member States, and direct purchase incentives with favourable electricity taxation.1234
Why — This would expand demand for charging infrastructure and electricity sales from their renewable portfolio.56
Impact — Fossil fuel suppliers lose market share as electricity replaces traditional fuels for transport.78
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Iberdrola urges maintaining 2035 zero-emission vehicle target

8 Oct 2025
Topic — EU regulation on CO2 emission standards for new cars and vans.
Message — Iberdrola requests maintaining the 100% CO2 reduction target for 2035 and avoiding exemptions for climate-neutral fuels. They call for stronger alignment with charging infrastructure rollout and harmonised vehicle labelling across Member States.1234
Why — This would accelerate demand for electric vehicles and charging infrastructure where Iberdrola operates.56
Impact — Fossil fuel companies lose market share as electricity replaces petroleum-based fuels.78
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Meeting with Lukasz Kolinski (Director Energy)

8 Oct 2025 · Electrification & grids

Meeting with Chiara Galiffa (Cabinet of Commissioner Maroš Šefčovič) and WindEurope and

7 Oct 2025 · US and EU Trade Relations concerning tariff rates on the steel industry, specifically the wind energy sector

Meeting with Anna Panagopoulou (Cabinet of Commissioner Apostolos Tzitzikostas), Helena Hinto (Cabinet of Commissioner Apostolos Tzitzikostas), Simone Ritzek-Seidl (Cabinet of Commissioner Apostolos Tzitzikostas) and

1 Oct 2025 · 1. Clean transport corridors 2. Corporate fleet initiative 3. HDV related elements 4. updates on what happens by then with the working groups set up at the HDV dialogue

Meeting with Elena Martines (Cabinet of Commissioner Ekaterina Zaharieva) and Amazon Europe Core SARL and

1 Oct 2025 · Challenges for the EU Heavy-duty vehicles (HDV) industry sector and ecosystem as well as progress on the Industrial Action Plan for R&I related aspects

Meeting with Jan-Christoph Oetjen (Member of the European Parliament) and Amazon Europe Core SARL and

1 Oct 2025 · De-risking Investment in Electric Heavy-Duty Transpor

Meeting with Bruno Tobback (Member of the European Parliament) and TransnetBW GmbH

1 Oct 2025 · The announced EU Grids Package

Meeting with Joachim Balke (Head of Unit Energy)

30 Sept 2025 · Exchange of views on the grid connections practice in Spain

Meeting with Paula Rey Garcia (Head of Unit Energy) and Climate Action Network Europe and

18 Sept 2025 · Electrification, tripartites contracts, storage and flexibility, and grids

Iberdrola backs 90% emissions cut but warns on removals and international credits

16 Sept 2025
Topic — Amendment to EU Climate Law to include 2040 climate target of 90% emissions reduction.
Message — Iberdrola requests clear distinction between gross emissions reductions, land-based sequestration and permanent removals in the target. They want international credits excluded from EU ETS, maintained at 3% limit, and strict quality standards applied. They also call for limiting carbon removals in the ETS to match unavoidable fossil fuel emissions in hard-to-abate sectors.123
Why — This would maintain higher ETS prices supporting their renewable energy investments and competitiveness.45
Impact — Hard-to-abate industrial sectors face higher compliance costs without flexible offsetting mechanisms.67
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Meeting with Ditte Juul-Joergensen (Director-General Energy)

16 Sept 2025 · EU industry operating in Japan (Offshore Wind Power Stakeholders incl. Danish Embassy, COP, Van Oord Japan K.K., Embassy of Netherlands, Jan De Nul, French Embassy, ReTo conseil, Franders Invsestment & Trade, Iberdrola, RWE, Siemens Games)

Iberdrola urges carbon infrastructure funding by technology operators

11 Sept 2025
Topic — Creating competitive markets and transportation infrastructure for carbon dioxide in the EU.
Message — Focus carbon capture only on hard-to-abate sectors after exhausting other mitigation. Operators using carbon capture must fund the necessary infrastructure themselves. Replace EU-wide planning with bilateral cooperation facilitated by the Commission.123
Why — This protects renewable energy investments by ensuring electrification remains the primary solution.45
Impact — Industrial carbon emitters lose access to potentially socialized or taxpayer-funded infrastructure.6
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Iberdrola Backs EU Regulation to Electrify Corporate Fleets

8 Sept 2025
Topic — The initiative aims to set minimum requirements for zero-emission vehicles in corporate fleets.
Message — Iberdrola supports a binding Regulation to ensure harmonized rules and avoid national inconsistencies. They recommend aggressive fiscal incentives, including full income tax exemptions and VAT deductions for zero-emission vehicles.123
Why — Increased electric vehicle adoption drives demand for Iberdrola's renewable power and charging networks.45
Impact — Operators of combustion engine fleets lose financial benefits as tax deductibility is eliminated.6
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Iberdrola urges EU to support anticipatory grid investment and planning

31 Jul 2025
Topic — Consultation on measures to upgrade, digitalise, and expand European grid infrastructure.
Message — Iberdrola proposes incorporating anticipatory investments in grid planning to meet the needs of renewable energy deployment. They request the removal of investment caps and guaranteed stable capital remuneration and cost recovery. They also suggest modifying the first-come-first-served principle to prioritize mature projects over speculative ones.123
Why — This would secure Iberdrola’s long-term capital returns and facilitate their large-scale network infrastructure investments.45
Impact — Speculative developers would lose grid capacity as priority shifts toward more mature and industrial projects.67
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Response to EU industrial maritime strategy

23 Jul 2025

Iberdrola welcomes the European Commissions initiative to develop a comprehensive EU Port Strategy & an EU Industrial Maritime Strategy. These efforts are timely and essential to reinforce Europes maritime infrastructure, industrial competitiveness, and strategic autonomy, while accelerating the green transition. We suggest the following considerations for the electrification of ports and shipbuilders, driving both the industrial maritime competitiveness and the green transition: 1. Onshore Power Supply (OPS) 1.1. Enabling private investment To attract private capital, regulatory frameworks must allow third parties to provide electricity supply services to vessels. In Spain, current legislation permits port authorities to offer such services, but further legal adaptation is needed to enable delegation to external operators. Additionally, national regulations should provide for reductions in occupancy and activity fees for private OPS providers, with enhanced incentives for those who invest in the necessary infrastructure. 1.2. Access tariffs In the early deployment phase (pre-2030), when infrastructure utilisation remains low, regulatory frameworks must avoid excessive fixed costs linked to contracted capacity. Without such flexibility, early investments may be discouraged. Post-2030, long-term structural measures should be introduced based on carbon leakage assessments to ensure the competitiveness of EU maritime transport. 1.3. Grid investment The distribution and transmission electricity grid is a critical enabler of port electrification. The Commission should ensure timely and adequate investment in transmission and distribution infrastructure, including: A review of grid planning processes to ensure anticipatory and adaptive approaches. Strategic investments aligned with EU climate and transport targets, including OPS deployment. 1.4. RED3 credit system OPS should be eligible under the RED III crediting system, recognising renewable electricity supplied to vessels as a contribution to transport decarbonisation. 2. RFNBOs 2.1. Storage and bunkering infraestructure There is an urgent need to deploy storage and bunkering infrastructure for RFNBOshydrogen for small vessels, ammonia and methanol for large cargo ships, and methanol for large passenger or mixed-use vessels. We recommend defining minimum port size thresholds for each fuel type, similar to the criteria used for Union airports. 2.2. Binding objectives Binding RFNBO targets must be established for maritime transport. Without them, compliance may rely on more polluting alternatives (e.g. blue hydrogen or LNG), undermining the uptake of green fuels. We propose mirroring the aviation sectors approach, where sub-targets for e-SAFs ensure the use of RFNBOs. 3. Tax incentives We encourage the EC to promote support schemes and tax incentives across the maritime value chain, including: Manufacturing of components and vessels Fleet electrification and retrofitting Purchase of electric vessels Such measures are essential to accelerate the sectors transition and ensure a level playing field globally. 4. Sinergies between renewables and maritime competiviness The growing offshore wind sector presents a strategic opportunity for revitalizing Europes maritime manufacturing and shipbuilding industries. Moreover, shipbuilding sector, by integrating renewable electricity into shipyard and port operations-especially when vessels are docked-can reduce their carbon footprint. This dual transformationsupporting clean energy deployment while greening industrial processesaligns with the EUs broader climate and industrial policy goals. By capitalizing on these synergies, Europe can push for a new leadership in both clean energy and advanced maritime manufacturing. Please find attached the document with the evidences.
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Iberdrola calls for private investment in port power infrastructure

23 Jul 2025
Topic — The EU Ports Strategy addresses challenges in competitiveness, security, and green energy.
Message — Iberdrola advocates for legal frameworks enabling private companies to supply port electricity. They demand binding green fuel targets and subsidies for vessel electrification. They suggest flexible power tariffs to lower costs for early infrastructure investors.123
Why — This would create new commercial opportunities for Iberdrola's renewable energy and infrastructure.45
Impact — Incumbent port authorities would face competition for electricity supply services from private operators.6
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Iberdrola urges prioritizing renewable electrification in industrial decarbonisation act

8 Jul 2025
Topic — The initiative aims to accelerate industrial decarbonisation and stimulate clean technology investments.
Message — Iberdrola demands that renewable electrification be prioritised through carbon contracts for difference. They call for tax reforms to end the preferential treatment of fossil gas. The company also advocates for streamlined permitting and strategic grid infrastructure development.123
Why — These proposals would significantly expand the market for Iberdrola’s renewable energy and grid infrastructure.45
Impact — Fossil gas providers would lose their competitive price advantage under the proposed tax revisions.6
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Iberdrola urges EU to exclude international credits from ETS

7 Jul 2025
Topic — Review of the EU emissions trading system and market stability reserve.
Message — Iberdrola calls for excluding international credits and strictly limiting carbon removals to unavoidable emissions. They also demand the cancellation of allowances when external measures reduce carbon demand.12
Why — High carbon prices and mandatory electrification benefit Iberdrola's massive renewable energy portfolio.3
Impact — Companies relying on cheap offsets or fossil fuels face higher operating costs.4
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Iberdrola urges stricter identity verification in energy switching rules

17 Jun 2025
Topic — EU initiative setting data access and interoperability requirements for electricity customer switching.
Message — Iberdrola proposes mandatory two-factor authentication using official ID documents for all energy supplier switches. They also demand recorded, third-party telephone verification for contracts signed outside physical offices to ensure valid consent.123
Why — Stricter rules would minimize commercial risks and market distortions caused by identity fraud.4
Impact — Remote sales agencies and door-to-door marketers would face significant new operational hurdles and recording requirements.5
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Meeting with Katarina Koszeghy (Cabinet of Commissioner Wopke Hoekstra) and ENEL SpA and

26 May 2025 · Exchange of views on the need and prospects for simplification in Pillar 2, in particular in light of the current situation with the US

Meeting with Bernardus Zuijdendorp (Head of Unit Taxation and Customs Union) and Novartis International AG and

26 May 2025 · Exchange of views on the need and prospects for simplification in Pillar 2, in particular in light of the current situation with the US

Meeting with Cristina Lobillo Borrero (Director Energy)

20 May 2025 · Blackout in Spain 28 April 2025

Iberdrola urges centralized auctions for EU Modernisation Fund grants

12 May 2025
Topic — The European Commission is evaluating and potentially amending the Modernisation Fund rules.
Message — Iberdrola recommends that states use a centralized auction tool to distribute funds. This would optimize resources by using systems already managed by the Commission.12
Why — This centralized approach would provide Iberdrola more predictable and objective funding opportunities.3
Impact — Less efficient competitors may lose advantages previously gained through national allocation systems.4
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Meeting with Matthieu Moulonguet (Cabinet of Commissioner Wopke Hoekstra) and Transport and Environment (European Federation for Transport and Environment) and

23 Apr 2025 · Greening Corporate Fleet

Meeting with Felix Fernandez-Shaw (Director Directorate-General for International Partnerships) and

1 Apr 2025 · In the context of the EU-LAC Global Gateway Investment Agenda, the European Commission’s Directorate-General for International Partnerships (DG INTPA) launches an initiative with a view to develop circular economy value chains in Latin America

Meeting with Miguel Gil Tertre (Cabinet of Executive Vice-President Teresa Ribera Rodríguez)

31 Mar 2025 · Electrification of energy-intensive industry

Meeting with Isabella Lövin (Member of the European Parliament)

26 Mar 2025 · Clean Industrial Deal

Meeting with Giorgio Gori (Member of the European Parliament) and Eni S.p.A.

19 Mar 2025 · Presentation of priorities

Meeting with Katarina Koszeghy (Cabinet of Commissioner Wopke Hoekstra), Patrice Pillet (Cabinet of Commissioner Wopke Hoekstra) and

19 Mar 2025 · Exchange of views on international tax issues

Meeting with Dan Jørgensen (Commissioner) and

11 Mar 2025 · Energy situation in US and Europe

Response to Implementing Act on non-price criteria in renewable energy auctions

21 Feb 2025

IBERDROLA welcomes the European Commission (EC) proposal to ensure a cleaner, more sustainable, and economically beneficial energy future and enhance energy security and stability by NPC supportive of renewable energy (RE) However, to boost electrification and reduce the cost of RE deployment for consumers, EC should include some additional recommendations in this act for addressing the following potential challenges of NPC: Balance the need for greater resilience and sustainability with the potential cost impact for the electricity system, increased bureaucracy, and risk of undermining RE expansion Due to the insufficient diversification of component manufacturers, a progressive implementation (gradual exclusion of dominant supply chain sources) is needed National impact assessments of the proposed NPC beforehand to ensure the fulfilment of that the 2030 targets NPC should be: mostly included as pre-qualification criteria (PQC) evaluated at the developer level transparent, simple to assess, objective, non-discriminatory and measurable Developers can only make project specific commitments if the relevant auction is close to the execution date of the project. Provide further clarification about: technologies covered under NZIAs Article 26 methodology to assess supply concentration methodology to calculate the disproportionate cost above 15% Below, we present a detailed opinion and the arguments to support or recommend a slight modification to the proposal: 1.A. PQC: Responsible business conduct: at a 'company-level' to truly align EU targets and competitiveness expectations with the spirit and strategy of companies Cybersecurity: additional clarification regarding the term operator is needed to ensure it is the owner of the asset who can also manage/control the asset Ability to deliver should be included as an award criterion (AC), providing more points based on operating experience in specific net-zero technology 1.B. PQC and/or AC: 1. Resilience criteria: Introduce gradually as AC with the lowest possible weight, maintaining competition and preventing unbalanced market power Promote the affidavit of responsibility figure For electrolysers (EZ), allow up to 25% of components to be sourced from third countries 2. Environmental sustainability: Carbon footprint: as AC (to prevent limiting suppliers), at company level; welcome the PEF method to measure environmental sustainability Circular economy: apply KPIs at company level Biodiversity impact: as PQC to avoid the bigger the better effect. If it is included as AC, at company level Energy efficiency: lack of specificity because the development of secondary legislation is still pending, and it is not yet clear which technologies will be included Efficient water use in the EZ case: use air coolers instead of cooling towers and implement wastewater treatment plants to save water 3. Innovation: as AC only for specific innovation tenders, and, in case of auctions that do not specifically focus on innovation, at company level 4. Energy system integration (ESI): avoid its inclusion as NPC, better via alternative routes to secure the best developers. If finally included, only consider one of the three options defined in Article 15 not consider connections across energy carriers (could result in cross-subsidies) allow system operators to decide about the needs, barriers and locational impacts required for ESI temporal flexibility requires additional investment: as a PQC 1.C. Penalties: Iberdrola welcomes the monitoring and strongly penalizing non-compliance with NPC but Only if the failure to apply NPC is the developer's responsibility Penalties must not reduce the developer's bargaining power with manufacturer Penalties and deadlines should be adapted by technology An intermediate milestone related with supply chain should be included (similarly to the 2nd auction requirement of European H2 Bank) Full answer attached.
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Meeting with Lukasz Kolinski (Director Energy)

21 Feb 2025 · Discussion on grids and the Affordable Energy Action Plan

Meeting with Raúl De La Hoz Quintano (Member of the European Parliament)

4 Feb 2025 · introduction

Meeting with Jutta Paulus (Member of the European Parliament)

4 Feb 2025 · EU energy policy

Iberdrola urges EU to accelerate Energy Single Market integration

31 Jan 2025
Topic — This consultation addresses the 2025 strategy for enhancing the European single market.
Message — The company wants the EU to remove energy market barriers and harmonise taxation rules. They request faster permit approvals for renewable energy and major grid infrastructure upgrades.123
Why — Easier permitting and infrastructure support would reduce costs for Iberdrola's renewable projects.4
Impact — Fossil fuel interests lose out as common taxation makes polluting more expensive.5
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Meeting with Andrea Wechsler (Member of the European Parliament) and Association of the European Heating Industry

29 Jan 2025 · EU Energy and industry policy

Meeting with Dan Jørgensen (Commissioner) and

23 Jan 2025 · Charting the future of European green competitiveness.

Meeting with Bruno Tobback (Member of the European Parliament, Shadow rapporteur)

15 Jan 2025 · The role of electricity distribution grids in the green transition

Meeting with Anna Stürgkh (Member of the European Parliament, Rapporteur)

14 Jan 2025 · INI Report on grids

Meeting with Christian Ehler (Member of the European Parliament) and EPIA SolarPower Europe and

13 Dec 2024 · Energy policy

Meeting with Miguel Gil Tertre (Cabinet of Executive Vice-President Teresa Ribera Rodríguez) and WindEurope and

5 Dec 2024 · To discuss European wind industry

Iberdrola calls for stricter GHG methodology for low-carbon fuels

25 Oct 2024
Topic — This consultation outlines a lifecycle assessment methodology for calculating greenhouse gas fuel savings.
Message — Iberdrola requests excluding existing nuclear power and applying additionality conditions to electricity sourcing. They demand methane emission default values reflect actual leakage rates from global fossil producers. Manufacturing timelines must match renewable fuel standards to prevent overstating carbon emission savings.123
Why — This protects Iberdrola’s renewable investments by preventing competitors from using cheaper, higher-emission energy.45
Impact — Nuclear operators and fossil gas exporters from high-leakage countries face increased compliance burdens.67
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Meeting with Susana Solís Pérez (Member of the European Parliament)

16 Oct 2024 · European energy policy

Response to Environmental Implementation Review 2025

5 Jul 2024

EC call for evidence - EU environmental law 2025 implementation review Iberdrola supports the option of sending to the EC the issues in which countries are failing to contribute to the achievement of the EU's energy and climate objectives. In fact, we welcome the future initiative of the EC to publish a communication and a report for each of the 27 countries with the aim of helping them to be more efficient in the transposition of regulations and use of available funds. All of this will have a positive impact on society. Spain has great potential to contribute to decarbonization, industrialization, economic growth,... however there are some bottlenecks that are hindering its green development. Below you can find some of these barriers: - The current market context shows an imbalance between supply and demand for electricity generation that is giving rise to very significant curtailments and prices have fallen to minimum values, with numerous hours of zero price. This situation will be repeated in the future as long as this imbalance is not corrected, putting at risk renewable development and the profitability of projects already executed. Additionally, to minimise the above effects and advance greater renewable development, it is necessary to match such development with greater electrification. Therefore, we consider it urgent: 1. Measures on demand that increase electrification and attract new industry. 2. Accelerate investments in grids to guarantee the connection of demand, under a forward looking planningmodel for grids that allows anticipatory investments to foresee the future needs in advance and eliminates the currently existing limit on investments in grids. 3. Promotion of PPAs, as the renewable Directive establishes. 4. Advance in electricity storage, in step with demand, being necessary to have a capacity mechanism that guarantees its economic viability. 5. Review the taxation of electricity, to avoid penalizing electricity with respect to fossil fuels, following the polluter pays principle included in the discussions under the European Energy Taxes Directives. - The lack of transparency and urgency in the allocation of both European and Spanish funds slows down the development of Spanish green industry o EU funds already granted to the Spanish government are still pending to be allocated. o State aids [e.g. IPCEI funds, H2 Bank auction as a service,] are not available for renewable options developers losing the opportunity to develop innovative technologies - EU ETS Directive is still in process of transposition. This means that several concerns mainly about the new EU ETS2 (i.e. regulated entities and its liabilities) are still pending to be solved o Spanish Social Climate Plan should remove from the electricity bill of the ETS2 sectors consumers, especially the vulnerable ones, taxes and levies not related to the electricity supply reducing the artificially created cost gap between electricity and fossil options (gas, oil...), and investment costs of electric grids needed to electrify the consumption of the ETS2 sectors. - The Renewable Directive (both in 2018 & 2023) has improved some key issue to foster renewable developments that are still pending to be transposed in Spain: o Permitting deadlines for renewable developments: deadlines included in the emergency regulation on permitting (December 2022) and in the new Renewable energy directive (that should be transposed in June 2024) are not being applied. o Overriding Public Interest of renewables and their infrastructures (grids, storage): still pending to be included in the Spanish legislation (supposed to be applied from February 2024, and transposed before July 2024) o Renewable district heating and cooling: develop a harmonized national scheme for its development
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Response to Application of the ‘do no significant harm’ principle to the Social Climate Fund and its possible future extension

28 May 2024

The aim of this response is to propose the Do-no-Significant-Harm (DNSH) criteria best adapted to the SCF among the existing criteria under the current EU acquis. As addressed by the Call for Evidence paper: The DNSH criteria in the Taxonomy delegated acts, that are envisaged to give transparency on sustainability for a wide range of precise economic activities regarding impact on each of the environmental targets of the EU, is not fit for the purpose of evaluating the impact of actions supported by concrete EU funds and programs. Certain objectives of the SCF may support the criteria in Explanatory note on the Application of the DNSH principle under the Cohesion Policy, though they are wide in scope and limited to concrete decarbonisation actions to protect vulnerable entities or consumers. The DNSH Technical Guidance C(2023) 6454 for the Recovery and Resilience Facility (RRF) deploys a more practical approach to impact evaluation, but it is open to all EU environmental targets with largely broad interpretation criteria. The InvestEU Sustainability Proofing Guidance for the repayable support under the InvestEU Fund, which includes concrete criteria focused on decarbonisation, but also covers the assessment of the Taxonomy Regulation in terms of social impact, offers the best principles applicable to the SCF. Furthermore, in the past the EU was focused on reducing its emissions in relation to past levels, but with the Green Deal it is not only crucial to reduce emissions (-55% by 2030), but it is of the utmost importance how to reduce them, with the aim of being carbon neutral by 2050. DNSH criteria applicable to SCF must consider that post 2050, only zero emission technologies will be sustainable. To avoid the effects of carbon lock-in, the SCF must consider only the options that reduce emissions through efficient and zero emission means under the criteria described below: EU must avoid long-lasting impacts that hinder 2050 objectives. The impact of any measure or infrastructure (including those labelled transitory") should be assessed through a Cost Benefit Analysis that includes all costs over its lifetime (stranded costs, environmental costs, remaining CO2 abatement costs for low carbon alternatives). SCF must only finance well-proven options under this approach. When assessing environmental impacts, the perspective must be absolute (not relative anymore). SCF must ask for measured impacts in absolute terms (total remaining emissions/maximum emission savings) of the actions to be financed included in national plans. SCF must emphasise quality (consistency of the measures, climate and sustainability goals post 2050) as a main requirement of the actions to be financed, avoiding those that do not qualify as sustainable, renewable and efficient. The energy efficiency first and level playing field principles should be the basis for all EU regulation, guidelines and aids. Direct electrification based on renewable energy must be the main pillar of decarbonisation. o Applying Energy Efficiency First Principles means that electric vehicle in road transport and electric heat pump in buildings are the best options. Thus, SCF aids should be aimed at promoting electrification, and not at reducing the pressure that ETS2 is exerting on fossil fuels. o SCF could remove from the electricity bill of the ETS2 sectors consumers, especially vulnerable ones: taxes and levies not related to the electricity supply reducing the artificially created cost gap between electricity and fossil options (gas, oil...). investment costs of electric grids needed to electrify the consumption of the ETS2 sectors. Only where the electrification is not possible, SCF support should go to other alternatives (renewable hydrogen, sustainable biofuels) for hard-to-abate ETS2 sectors (high temperature industry, maritime transport).
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Meeting with Maroš Šefčovič (Executive Vice-President) and

23 May 2024 · Green transition and 2040 climate target

Meeting with Mohammed Chahim (Member of the European Parliament) and Fertiberia, S.A. and Patentes Talgo

12 Apr 2024 · Site visit - Puertollano’s Green Hydrogen Valley

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

2 Apr 2024

IBERDROLA welcomes the European Commission initiative for elaborating some guidelines and recommendations to promote the development of innovative forms of solar energy. Issues to tackle by MS when developing building-integrated PV: Processing of Administrative Authorizations: In Member States such as Spain, the authorization process for self-consumption facilities is processed at the autonomous and/or local level. This is a challenge due to the different procedures and documentation requirements established by each administration, leading to a fragmented approach for the obtention of the necessary legal authorizations. We recommend that the guide advocates for standardise procedures within a Member State. In addition, the guide should encourage the simplification of administrative processes through the implementation of measures such as the establishment of one stop shops, the acceptance of responsible statements or the establishment of positive administrative silence, whenever feasible. Public Aid Processing: The processing of public aid encounters the challenges outlined in the first point. Hence, we emphasize the need for the guide to advocate for standardize procedures within a Member State, with the goal of achieving maximum simplification. Additionally, the issue with public aids as direct support is the significant delay between the request and receipt of aid, which undermines their intended incentivizing effect. We suggest that the guide should promote the design of aids that are accessible immediately upon the purchase or contracting of a product or service, such as through tax reductions. Collective Self-Consumption Processing: The processing of collective self-consumption installations presents unique challenges due to the involvement of multiple self-consumers. These challenges include not only those already mentioned in the previous points but also those related to the technical and administrative complexity of registering all participants. This process requires exhaustive coordination between consumers and electrical sector agents, as well as efficient information exchange. The complexity increases proportionally with the number of consumers involved. Therefore, the guide should promote that Member States implement simplified procedures for the processing of these self-consumption installations. A simplification measure could be to authorize suppliers to represent the self-consumers, centralizing and managing the required documentation, which would avoid the need for each consumer to process the information individually. Other issues to be considered in the guidelines for Innovative forms of solar energy: Member States must provide the maximum availability of areas from the beginning of the mapping process to allow developers to find the right sites to define their renewable energy sources (RES) projects, and avoid land speculation and creating no-go areas outside Renewable Acceleration Areas Member States must ensure compliance with the 2030 RES contributions in NECPs and beyond but must not limit renewable deployment. Council Emergency Regulations and Renewable Directive's permitting deadlines and other provisions set must be respected. Grid permitting: no RES will be developed without the grid expansion needed. RES development will not be accelerated anywhere until swift deadlines for granting administrative, environmental and construction permits to both DSOs or TSOs for expanding the network are also set. Accelerate the permits procedure for the grid and storage infrastructure necessary to integrate RES into the electricity system in any area where RES are developed. Future mon: The Commission needs a tool to assess if countries are complying with full implementation of the permitting provisions in the Renewable Directive: Key Performance Indicators (KPIs) are needed to demonstrate that countries have transposed permitting requirements to and do not hinder their national contributions.
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Iberdrola urges auction designs to minimize renewable energy costs

1 Mar 2024
Topic — European Union guidance on the design of qualitative criteria for renewable energy auctions.
Message — Iberdrola opposes negative bidding as it artificially increases the levelized cost of energy. Qualitative criteria should focus on decarbonization rather than indirectly subsidizing manufacturing industries. The company recommends prioritizing merchant bidders over those requesting government financial support.123
Why — This reduces compliance costs and ensures projects remain financially viable throughout development.45
Impact — Manufacturers lose indirect subsidies, while governments lose revenue from direct auction payments.67
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Response to Guidance to facilitate the designation of renewables acceleration areas

23 Feb 2024

IBERDROLA welcomes the revised Renewable Energy Directive (RED) in terms of permitting issues, and the EC initiative to provide practical guidance to Member States (MS) for the identification and designation of Renewables Acceleration Areas (RAA) for wind and solar onshore projects. Main issues to tackle by MS when mapping their territories: Mapping should facilitate developers access to relevant information for the development of their projects, without adding restrictions to project development. MS must provide the maximum availability of areas from the beginning of the mapping process to allow developers to find the right sites to define their RES projects and avoid land speculation. In other words, all surfaces are favourable to renewables if not banned by current legislation, and exclusion areas must be strictly limited to the legally banned areas to renewables. Not hinder RES outside RAA: avoid creating no-go areas. MS must ensure compliance with the 2030 RES contributions in NECPs and beyond but must not limit renewable deployment. Digital tool to provide uniform information to developers and other qualified stakeholders Other issues to be considered when mapping: Digital tool compatible with the usual development tools (GIS-based) Digital map with high enough resolution to avoid misinterpretations in projects boundaries The mapping must be stable over time: constant updates of the layers/tools generate uncertainty for developers and investors Not interfere with the ongoing development of projects adding new restrictions Include different layers of information for developers: -Environmental layer: protected spaces, rivers, livestock routes, migratory corridors, etc. and the level of protection (not all protected areas mean exclusion of RES projects) -Infrastructure layer: existing and projected roads, gas pipelines, railways, networks, substation, urban areas, etc. Modified infrastructures to allow RES development shall benefit from accelerated permitting procedure -Other technical layers inherent to the developer expertise (slopes, resource, etc.) should not restrict developments. Mapping by technology since the requirements of the land/plots vary from one technology to another. Designation of RAA: Consultations on the proposed methodology to select candidate RAA prior to consulting on proposed areas themselves. For the environmental scoping phase, MS may consider digitally collected data from reliable sources and recognised methodologies, either human or technological. By technology since the requirements of the land/plots vary. The designation of RAA should also include an automatic and transparent procedure to change land use, as the reclassification of land often requires lengthy procedures. Finally, permitting deadlines and other provisions set for RAA must be respected. There is little point in creating RAA if the deadlines provided for by RED are not met by the competent authorities of the MS. Grid permitting: no RES will be developed without the grid expansion needed. RES development will not be accelerated anywhere until swift deadlines for granting administrative, environmental and construction permits to both DSOs or TSOs for expanding the network are also set. In this regard, MS should: Develop the voluntary Areas for grid and storage infrastructure necessary to integrate RES into the electricity system, exempting these infrastructures from their own environmental impact assessment to accelerate the permit process. Accelerate the permits procedure for the grid and storage infrastructure necessary to integrate RES into the electricity system in any area where RES are developed. Future monitoring: The EC needs a tool to assess if countries are complying with full implementation of the permitting issues in REDIII: Key Performance Indicators (KPIs) are needed to demonstrate that countries have transposed permitting requirements to and do not hinder their national contributions.
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Iberdrola Urges Equal Carbon Allowances for Renewable Hydrogen

19 Dec 2023
Topic — The consultation updates rules for distributing free carbon allowances under the ETS.
Message — Iberdrola demands identical free emission allowances for carbon-free and fossil processes. They advocate removing technical factors that currently penalize industrial electrification.12
Why — Renewable hydrogen projects would gain additional financial support alongside existing subsidies.3
Impact — Traditional fossil hydrogen producers lose their exclusive competitive edge regarding free allowances.4
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Meeting with Ditte Juul-Joergensen (Director-General Energy)

11 Oct 2023 · Energy Transition

Meeting with Kadri Simson (Commissioner) and

6 Sept 2023 · High level dinner before the ENSTO-E grids event – discussion on the challenges for European networks and electrification.

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

31 Aug 2023 · Energy transition

Meeting with Bjoern Seibert (Cabinet of President Ursula von der Leyen), Peter Van Kemseke (Cabinet of President Ursula von der Leyen) and

31 Aug 2023 · Virtual exchange on the European wind sector

Response to Review report on the Governance Regulation of the Energy Union and Climate Action

3 Aug 2023

IBERDROLA welcomes this initiative as a great opportunity to improve both the elaboration of the NECPs and the reporting on the progress towards the objectives by Member States, as there are some aspects that could be further improved. First, the Renewable Energy Directive (RED) includes now a new paragraph 4a in Article 3. The elaboration of the NECPs and the reporting on their progress should incorporate such a framework explicitly both in terms of its design and its effective implementation, with a special focus on: The detailed estimation of the additional renewable electricity (RES-E) required to meet demand in the transport, industry, building and heating and cooling sectors and for the production of renewable fuels of non-biological origin. The justification of how minimise constrained or interrupted supply of RES-E through greater electricity demand via different concrete projects as renewable hydrogen (RES-H2), interconnections... Permitting procedures Development of the necessary infrastructures, particularly in the electricity sector given it will incorporate most of the new renewable energy (RES) production Second, the governance regulation should monitor the energy security improvements made by MS. The reporting of the progress towards implementation of quantifiable national objectives and targets in the sphere of the energy security dimension, should further consider the following three additional aspects: 1)The importance of storage is not just for flexibility purposes, but also in terms of diversification of energy sources as key enabler for the integration of inflexible primary energies and reducing the energy import dependency from third countries. Therefore, Information on storage capacities (electricity, gas, hydrogen - H2) should be added both in Diversification of energy sources and supply and in Reducing energy import dependency from third countries 2)The section Reducing energy import dependency from third countries needs to include RES-H2 among the fuels to include in section 3)A set of flexibility indicators should be included to complement the adequacy indicators: oLevel of RES curtailments / level of storage deployed vis-à-vis the RES capacity installed and capacity planned in the NECP oLevels of new pumping storage power planned in the NECP which are in advanced stage of commissioning, if relevant (e.g. Spain) oOther sources of flexibility which are reasonably assumed to remain in the system, if relevant (e.g. CCGT in Spain) oThe level of demand response, already deployed and actively participating in the market, and a technical assessment of its potential Third, need for a new section in Decarbonisation: RES energy in which MS shall describe an assessment of their current permitting practices, with the aim of not hindering the achievement of their RES National Contributions. To ensure a swift and full implementation by MS of the revisions to RED in terms of permitting issues, the Commission should publish the KPIs, together with an assessment and recommendations, ranking the different approaches taken in its case, and introduce incentives for compliance i.e. MSs with the highest score in terms of KPIs would have a better chance to obtain funds. The KPIs that should be included are: Total length of permitting process for RES energy technology. Number of staff per GW of RES energy set out in the 2030 NECP. Rate of projects approved over total number of permit applications correctly submitted per technology . Total length of acknowledgment of the validity of the application, both inside and outside RES acceleration areas Proportion of permits that are reaffirmed/not overturned when there is a legal challenge and timing of the legal challenge procedures Number of total windows/stops needed to complete the whole approval process per technology COM will serve as a clearing house facilitating the exchange of information and best practices between MS based on the benchmarks above.
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Iberdrola Calls for Advance Grants and Competitive Bidding

31 Jul 2023
Topic — Revisions to the EU Innovation Fund implementing competitive bidding and efficiency measures.
Message — They request 70% price-weighted criteria and support for operational costs. They also want 50% of grants paid upfront to improve projects.12
Why — Upfront payments would streamline project approvals and lower developer risks.3
Impact — Firms seeking to stack different subsidies would be blocked by cumulation bans.4
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Response to Evaluation and review of the Regulation concerning the screening of foreign direct investments

12 Jul 2023

The EUs FDI screening framework has contributed, over the past couple of years, to identifying and addressing risks to security and public order related to FDIs, while ensuring that the EU remains open to foreign investment. A revised FDI screening framework should maintain this balance. Achieving the EUs ambitious decarbonization targets requires very significant investments. Having an effective and efficient EU FDI screening framework is important in this context to strike a balance between the general openness of the EU to foreign investment flows and the defence of the EU's essential interests. Iberdrola supports the Commissions review of Regulation (EU) 2019/452 to ensure that it remains effective, but also to enhance the efficiency of FDI screening mechanisms across Member States. Efforts should focus on ensuring a competitive playing field and increasing legal certainty around FDI screening, facilitating and promoting relevant information sharing and more streamlined and efficient review procedures. Specially, we support: - Defining, at an EU level, transparent and more harmonized rules, including minimum common criteria for (i) determining the scope of FDI screening mechanisms (e.g., which cases fall within applicable FDI screening mechanisms and are subject to mandatory notification?), (ii) assessing sensitive FDIs, and (iii) addressing risks posed by FDIs. - Standardizing the scope of the information that must be provided by the parties of a proposed transaction as part of an FDI screening notification, with a view of reducing unnecessary administrative burdens. - Streamlining and harmonizing procedures and timelines for FDI screening mechanisms and facilitating information sharing among relevant Member States and the Commission, to avoid undue delays on transactions, while also ensuring that all relevant parties have access to necessary information and can more easily cooperate with each other. In this regard, we support the creation of a single, secure IT platform at an EU level where notifying parties, Member States and the Commission could provide information and exchange information related to the FDI transactions subject to screening. - Strengthening the Commission involvement in FDI screening in cases where EU critical assets are at stake. - Facilitating and promoting cooperation with like-minded third countries to strength the effectiveness of FDI screening mechanisms (e.g., including sharing of best practices and collaboration with respect to specific FDI screenings). - Implementing further measures to guarantee the effective protection of sensitive business and personal data provided as part of FDI screening notification procedures.
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Meeting with Marie Toussaint (Member of the European Parliament, Shadow rapporteur)

29 Jun 2023 · gas regulation

Iberdrola Urges 90% Climate Target and Faster Direct Electrification

22 Jun 2023
Topic — The European Commission is consulting on the EU's 2040 climate target.
Message — Iberdrola proposes setting the 2040 climate target between 80% and 90%. They emphasize that direct electrification must be the main pillar of European decarbonization efforts. Technologies like hydrogen and carbon removals should be restricted to hard-to-abate sectors.12
Why — An electrification-first target would favor Iberdrola’s existing renewable assets and future investments.3
Impact — Fossil fuel importers lose business as the policy seeks to reduce dependency.4
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Iberdrola criticizes proposed auction price premiums and CO2 targets

6 Jun 2023
Topic — The Net Zero Industry Act supports European manufacturing of green energy technologies.
Message — Iberdrola demands impact assessments for CO2 targets to ensure feasibility and cost-effectiveness. They reject mandatory 10% price premiums in renewable auctions to avoid distorting energy markets. This preserves market efficiency principles.12
Why — Removing price premiums prevents their renewable projects from becoming artificially expensive compared to gas.3
Impact — Consumers face higher bills and decarbonization slows as electrification becomes less attractive financially.4
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Meeting with Marie Toussaint (Member of the European Parliament, Shadow rapporteur)

30 May 2023 · gas regulation

Iberdrola backs ambitious EU heat pump deployment targets

26 May 2023
Topic — The European Commission is seeking feedback on accelerating heat pump market deployment.
Message — Iberdrola supports installing 30 million additional heat pumps by 2030 and calls for removing network investment caps. They advocate for harmonized regulations for district heating and cooling and updated primary energy factors.123
Why — This would allow Iberdrola to increase infrastructure spending and expand its electricity distribution business.45
Impact — Suppliers of fossil fuel heating systems lose as new equipment becomes carbon-free.6
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Iberdrola urges voluntary contracts to protect renewable investments

23 May 2023
Topic — Revision of EU electricity market rules to enhance resilience and decarbonisation.
Message — Iberdrola demands that support schemes like Contracts for Difference remain voluntary. They prioritize protecting existing investments from retroactive interventions to ensure regulatory certainty.12
Why — Avoiding retroactive changes protects the utility's massive global portfolio of existing renewables.3
Impact — Standard electricity consumers lose if energy sharing leads to revenue gaps or cross-subsidies.4
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Iberdrola calls for tougher CO2 targets for heavy-duty vehicles

17 May 2023
Topic — The European Commission is reviewing CO2 emission standards for new heavy-duty vehicles.
Message — Iberdrola calls for 100% emission reduction targets for trucks and buses by 2035. They advocate for maintaining a strict definition of zero-emission vehicles excluding hydrogen-powered combustion engines. The company requests reinstating higher financial penalties for manufacturers failing to meet environmental benchmarks.1234
Why — Rapid electrification of heavy transport increases demand for Iberdrola's renewable energy and charging services.5
Impact — Manufacturers of internal combustion engines face significant penalties and a total market phase-out.6
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Meeting with Niels Fuglsang (Member of the European Parliament) and CONCITO, Denmarks Green Think Tank

17 May 2023 · (APA) Electricity Market Design

Meeting with Kadri Simson (Commissioner) and

12 May 2023 · Discussion on the implementation of REPower EU objectives in Portugal.

Meeting with Kadri Simson (Commissioner) and

4 May 2023 · Importance of hydropower in ensuring electricity system flexibility; The application of the electricity market reform to hydropower; How to strengthen the visibility of hydropower as one of the key sources of renewable energy.

Meeting with Riccardo Maggi (Cabinet of Executive Vice-President Frans Timmermans) and ELECTRICITE DE FRANCE and

4 May 2023 · Presentation of new business group

Iberdrola urges stricter bio-waste standards and building alignment

3 May 2023
Topic — Establishing investment classifications for sustainable activities contributing to EU environmental goals.
Message — Iberdrola requests that source-segregated bio-waste constitutes 70% of feedstock to prevent greenwashing. They also propose aligning taxonomy criteria with the revised Energy Performance of Buildings Directive.123
Why — Tighter taxonomy criteria would protect Iberdrola's market leadership and facilitate capital for energy transition.45
Impact — Producers using contaminated biomass from mixed municipal and industrial waste would be excluded.6
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Meeting with Virginijus Sinkevičius (Commissioner) and

12 Apr 2023 · To discuss the Commission initiatives as regards fast-tracked permitting of renewable energy investments and in relation to protection of the environment

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

12 Apr 2023 · Energy Market Directive

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

31 Mar 2023 · Energy Transition. Site visit. Organiser: Administração dos Portos de Sines e Algarve.

Iberdrola backs carbon removal certification focused on hard-to-abate sectors

23 Mar 2023
Topic — The European Commission is proposing a regulatory framework for certifying high-quality carbon removals.
Message — Carbon removals should focus on residual emissions in sectors where no other solution is available. Iberdrola requests a central registry and clear definitions for long-term storage to ensure transparency.12
Why — This framework protects Iberdrola's renewable business by preventing low-quality removals from undermining mitigation efforts.34
Impact — Fossil fuel industries lose as the proposal excludes them to prevent technological lock-in.5
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Meeting with Kadri Simson (Commissioner) and

7 Mar 2023 · Exchange on the needed regulatory support to promote the deployment and manufacturing of the solar power in the EU and the EU’s support for the solar energy so far.

Meeting with Jakop G. Dalunde (Member of the European Parliament)

3 Mar 2023 · Energy Market Design (Staff level)

Meeting with Jens Geier (Member of the European Parliament)

2 Mar 2023 · Exchange of views on the electricity market design (staff level)

Meeting with Tom Berendsen (Member of the European Parliament)

15 Feb 2023 · Electricity Market Design - Meeting with APA

Meeting with Kadri Simson (Commissioner) and

9 Feb 2023 · Electricity market design.

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

2 Feb 2023 · Electricity Market Design

Meeting with Frans Timmermans (Executive Vice-President) and EPIA SolarPower Europe and

2 Feb 2023 · Hydrogen bank proposal and the Green Deal Industrial Plan

Meeting with Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans) and WindEurope and

1 Feb 2023 · Renewable energy

Iberdrola urges tougher Euro 7 standards to favor electric vehicles

28 Nov 2022
Topic — This consultation addresses stricter emission standards for all combustion-engine vehicles in the EU.
Message — Iberdrola calls for all new vehicles to be zero-pollutant by 2030. They request independent limits for cancer-causing chemicals like formaldehyde. Testing must extend to reflect the true lifetime of European cars.123
Why — Stricter combustion regulations accelerate the shift to electric vehicles, benefiting Iberdrola's business.4
Impact — Automakers and ethanol producers face higher costs from stricter limits and extended testing.56
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Iberdrola advocates for stricter air standards to boost electrification

28 Nov 2022
Topic — This consultation revises EU air quality legislation to match WHO health recommendations.
Message — Iberdrola supports a 2050 zero-pollution objective and stricter 2030 standards. They advocate for electrifying transport and heating to solve air pollution. They also want penalties for countries exceeding limits.123
Why — Stricter air rules would increase demand for Iberdrola's renewable power and technologies.45
Impact — Non-compliant governments and polluting industries would face lawsuits and financial penalties.67
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Meeting with Pascal Canfin (Member of the European Parliament)

18 Nov 2022 · Green Deal

Meeting with Marie Toussaint (Member of the European Parliament, Shadow rapporteur)

20 Oct 2022 · gas market

Meeting with Virginijus Sinkevičius (Commissioner) and

7 Oct 2022 · To discuss maritime spatial planning (MSP), co-existence and multi-use of the space, permitting, regional cooperation, sustainability and recycling.

Meeting with Thierry Breton (Commissioner)

27 Sept 2022 · Clean energy transition; energy crisis

Response to Implementing regulation on the Member States’ reporting of information foreseen in the Governance of the Energy Union

5 Aug 2022

IBERDROLA welcomes the proposal of rules for reporting the information on progress towards the objectives by Member States (MMSS). However, there are some aspects that should be further improved. Specifically: Table 2 in Annex V should further consider three additional aspects on energy security dimension: 1) The current gas crisis is proving the importance of storage not just for flexibility purposes, but also in terms of diversification of energy sources and reducing the energy import dependency from third countries. Therefore: •The section on “Diversification of energy sources and supply” should request information on storage capacities (electricity, gas, hydrogen - H2) •The section on “Reducing energy import dependency from third countries” should include dependency from other MMSS’ as interconnections are limited, and also request information on storage capacities (i.e. % of imports from the largest foreign energy provider (electricity, gas, H2) or % of storage Vs. RES capacity in the National and Climate Plan - NECP) 2) Dependency on RES H2 imports should also be monitored including RES H2 among the fuels in section “Reducing energy import dependency from third countries” 3) The template proposed does not include information about the “Increase of the flexibility of the national energy system, in particular by means of deploying domestic energy sources, demand response and energy storage” (see Article 22(d) of Regulation 2018/1999). It should be included based on a set of indicators: oLevel of RES curtailments / level of storage deployed vis-à-vis the RES capacity installed and capacity planned in NECP oLevels of new pumping storage power planned in the NECP which are in advanced stage of commissioning, if relevant (e.g. Spain) oOther sources of flexibility which are reasonably assumed to remain in the system, if relevant (e.g. CCGT in Spain) oThe level of demand response, already deployed and actively participating in the market, and a technical assessment of its potential Need for a new Table 9 in Annex II to ensure a swift and full implementation by MMSS of revision of the RES Directive in terms of permitting issues. MMSS should carry out strategic plans on how they are to transform their permitting system and include it in the NECPs. MMSS should include permitting improvements as part of the NECPs progress report based on a set of Key Performance Indicators (KPIs) to demonstrate that it does not hinder their national Contributions. COM should afterwards publish an assessment and recommendations, ranking the different approaches taken in its case. Finally some incentives should be included (e.g. MSs with the highest score in terms of KPIs would have a better chance to obtain funds from CEF). In this sense, a new table 9 must be included in the reporting of the information on progress towards the objectives by MMSS. The KPIs that should be included are: •Total length of permitting process for RES, including the time to evaluate the environmental impact assessment, to grant grid connection, and to clear legal challenges (where applicable), both inside and outside RES go-to areas (if these are finally approved) •Number of staff (in terms of Full Time Equivalents - FTEs) in the relevant permitting authorities per GW of RES energy set out in the 2030 NECP •Rate of projects approved over total number of permit applications correctly submitted per technology – and where appropriate per federal/regional entity •Total length of acknowledgment of the validity of the application, both inside and outside RES go-to areas (if these are finally approved) •Proportion of legal challenges that are rejected - and where appropriate per federal/regional entity - and timing to reject those legal challenges •Number of total windows/stops needed to complete the whole approval process per technology COM will serve as a clearing house facilitating the exchange of information and best practices between MMSS basedon the KPIs above.
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Iberdrola Urges Binding Deadlines and Fast-Track Renewable Permitting

26 Jul 2022
Topic — Commission guidance on reducing administrative barriers and accelerating renewable energy permitting.
Message — Iberdrola calls for binding deadlines for all permitting steps and environmental assessments. They propose using self-certification and tying EU funding to national performance.12
Why — Faster approvals and self-certification would significantly reduce administrative costs and project delays.3
Impact — Regulatory bodies and environmental groups could lose oversight due to automatic approvals.4
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Response to Regulation on REPowerEU chapters

20 Jul 2022

IBERDROLA welcomes the revision of the Recovery and Resilience Facility (RRF) in terms of the revenues needed to finance the REPower EU Package The REPower EU package represents an ambitious step towards EU energy independence and resilience, while accelerating the energy transition. The Commission envisages strong investment needs, earmarking close to € 300 bn of EU funds, of which € 20 bn are proposed to be generated until 2026, by the auctioning of a quantity of allowances held in the Market Stability Reserve (MSR) of the EU Emission Trading Scheme (ETS). Otherwise, these allowances (around 250 million of EUAs at current ETS prices) would be kept in the reserve and probably invalidated as from 2023, if the number of allowances held in the reserve were above the total number of allowances auctioned during the previous year (Decision (EU) 2015/1814 on MSR). Since the implementation of MSR in 2019 as a quantity stabilising tool, it has succeeded to bring predictability and credibility to EU ETS through clear rules, absorbing or releasing allowances when certain quantity thresholds are activated. Reinjecting the equivalent to € 20 bn allowances has not only a direct effect on ETS prices (10% drop when the proposal was just made) but also distorts the EU ETS functioning in different ways. Deviating from a volume-based principle to a monetary target would not only put the functioning of the EU ETS at risk, but the increased EUA supply would weaken investment signals and trigger an increase of fossil fuel consumption in the short term. Further, it would not only weaken Member States’ (MS) revenues rather than generating new funds, but also reduce Innovation Fund’s budget, a key tool to achieve the REPower EU targets. In general, this decision would disturb the market, given the magnitude of the release and create a first move towards arbitrary use of the EUA stored in the MSR jeopardising market confidence. Further, the EU carbon price signal will be weakened, stimulating fossil fuels consumption, while requesting more EUAs to auction, in order to meet the financial target, and reducing the overall auction revenues for MSs. Finally, the surplus will increase over the years to follow with a carbon budget still high in 2030. Therefore, we can expect at the end of the period, when the MSR would withdraw the excess, a dramatic increase of the carbon price and a reduction on the number of allowances auctioned by MSs. In summary, this measure transforms MSR scope and aim into an “emergency financial box” that in essence means “more money today for REPowerEU” coming from “less money tomorrow from auctions for MSs” at the expense of distorting the ETS’ well-functioning and investor confidence. The consequences could be a permanent weakening of carbon price signal, going not only in prejudice of investors’ confidence but also in jeopardizing MSs’ auctioning revenues and facilitating a larger use of fossil fuels. In the path towards reducing the dependence of fossil imported energy while increasing investment in renewable technologies it is crucial to facilitate significant funding to MSs and investors. This can be achieved without disturbing the ETS, preserving the nature and effectiveness of MSR. To this end several alternative proposals could presented: • In the EU ETS, additional ≈235 million allowances should be auctioned from 2023 until 2026, to provide funding to REPower EU objectives. These allowances could be fed through borrowing around a 6% of the total quantity to be auctioned by MSs between 2027-30. • Enable MSs’ to issue EU Green Bonds collateralizing 6%/y of EUAs to be auctioned between 2027-30. This allows new funding earmarked to REPower EU targets minimising disturbances on the normal functioning of EU-ETS.
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Response to Sustainable Products Initiative

22 Jun 2022

IBERDROLA welcomes the “Fit for 55 Package” The Green Deal though the “Fit for 55 Package” offers a unique opportunity to set a proper regulatory framework that boosts momentum on the most efficient renewable alternatives to enable decarbonisation and the achievement of EU climate objectives. IBERDROLA welcomes the revision of the Ecodesign Regulation IBERDROLA fully supports the following aspects of the proposal: • New framework to improve the environmental sustainability of products • New ecodesign requirements for each product improving aspects such as durability, environmental impact including carbon and environmental footprint, energy efficiency… • Introduction of the Product Passport However, there are some topics that could be further improved: • Alignment with environmental and climate objectives The new Ecodesign Regulation proposal should ensure that only efficient and emission free alternatives that are in line with EU’s environmental and climate objectives, with no lock in effect or stranded costs are considered and promoted. In this context, the ecodesign requirements shall never go against the energy transition, as this shall always prevail. • The electricity Primary Energy Factor (PEF) should be dynamic and forward looking and updated in line with the National Climate and Energy Plans (NECP) The current ecodesign and labelling class limits are still using the outdated PEF of 2.5 instead of the current one of 2.1 in accordance with the Energy Efficiency Directive 2018/2002/EC (EED). However, updating this value to existing regulation is not enough to reflect the real savings of electrification and implement what the Energy System Integration Strategy stated on this regard: “PEF is an important tool to facilitate comparison of savings across energy carriers. Most renewables are 100% efficient and have a low PEF. The PEF should reflect the real savings brought about by renewable electricity and heat”. Current default PEF for electricity set by the EED is one of the main barriers to promote the electrification of end uses and, hence, to calculate the corresponding energy efficiency gains. A default PEF of 2.1 for electricity seems to be clearly outdated as it does not consider how the increase of renewables in the electricity mix has reduced primary energy consumption, energy dependency and emissions in most MSs. The default PEF value for electricity should adequately reflect the future increase of renewables in the electricity mix, it should be dynamic and forward looking, taking into consideration the future energy mix of the MS that is set on its National Climate and Energy Plans (NECP). • A harmonised penalty system The proposal sets that MSs shall lay down the rules on penalties applicable to infringements of this Regulation. However, and in order to ensure the well-functioning of the internal market, the Commission should set a harmonised and EU wide approach.
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Iberdrola urges stricter additionality rules for renewable hydrogen

17 Jun 2022
Topic — This consultation defines the methodology for calculating emissions savings from renewable transport fuels.
Message — Iberdrola demands stricter rules to ensure hydrogen production uses new renewable energy sources. They want equal treatment for direct and grid connections to maintain a level playing field. Additionally, they advocate for zero-emission status for hydrogen produced from 100% renewable electricity.12
Why — These rules would protect the competitive advantage of Iberdrola’s vast renewable portfolio.34
Impact — Consumers and the climate suffer through higher energy prices and increased greenhouse emissions.56
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Meeting with Damien Carême (Member of the European Parliament)

16 Jun 2022 · Paquet gazier

Meeting with Pilar Del Castillo Vera (Member of the European Parliament, Rapporteur) and Apple Inc. and

24 May 2022 · Data Act

Meeting with Jerzy Buzek (Member of the European Parliament, Rapporteur) and Climate Action Network Europe and

19 May 2022 · Meeting on gas and hydrogen regulation

Iberdrola calls for strict fossil-free carbon removal certification

2 May 2022
Topic — The EU is creating a regulatory framework for certifying sustainable carbon removals.
Message — Iberdrola argues that removals should exclude any processes relying on fossil fuels to prevent carbon lock-ins. They recommend a certification system based on robust monitoring and verification to ensure removals are additional and permanent.123
Why — Standardized certification would provide investment signals and boost the credibility of Iberdrola’s climate-neutral claims.45
Impact — Industrial players using carbon capture on fossil-fueled processes would be excluded from certification.67
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Meeting with Stefano Grassi (Cabinet of Commissioner Kadri Simson), Tatiana Marquez Uriarte (Cabinet of Commissioner Kadri Simson) and

27 Apr 2022 · Electricity market design (proposal of Spanish and Portuguese governments)

Meeting with Morten Petersen (Member of the European Parliament)

19 Apr 2022 · RED and permitting

Response to Revision of EU rules on Gas

12 Apr 2022

• CROSS-SUBSIDIES BETWEEN DIFFERENT ENERGY CARRIERS. Cross-subsidies means deviating from the cost-reflective tariffs principle, thus distorting competition between different energy vectors, which is the essence of an efficient energy system integration according to Commission's Strategy itself. Furthermore, cross-subsidies from electricity grid users to hydrogen network users would be contrary to the much-needed electrification, thus hindering achieving efficiently the EU's energy and climate objectives. Therefore, such cross-subsidies should be disallowed in any event, including the Commission should be rejected. In fact, there are other alternative well-known more efficient manners to promote the early stages of the hydrogen network development (e.g. grid tariff methodologies based on backloading depreciation costs, thus enabling future network users to bear a higher share of the investments costs, which were incurred when demand for hydrogen was still low). • GRID TARIFF DISCOUNTS FOR RENEWABLE AND LOW CARBON GASES. While there might be logic / merit in applying tariff discounts to exploit the most economic locations to inject and/or withdraw gas from the system, this is not the approach taken in this proposal. Under this proposal, a tariff discount would be granted to any injection regardless its location, and only from renewable and low carbon gases. Therefore: o This is not about providing a locational signal, but a hidden subsidy to renewable and low carbon gases at the expense of the rest of the network users. o This clearly departs from the cost-reflective tariffs principle. In this sense, consider the contagion effect on the electricity market through the access tariffs paid by e.g. CCGTs. Consider also other renewable and low carbon energy carriers, which do not benefit from similar advantages, thus distorting the much-needed level playing field between the different carriers for the sake of an efficient energy system integration. There are other alternatives, well-known more efficient approaches to subsidise renewable and low carbon gases which do not entail the distortions described. • OBLIGATION TO ACCEPT A MINIMUM BLENDING SHARE AT INTERCONNECTION POINTS. According to article 194 TFUE, Member States have the right to determine the general structure of its energy supply. However, the proposed obligation would limit such right, as it would force a Member State importing natural gas the inclusion of (blended) hydrogen into the general structure of its energy supply. Obviously, a Member State is free to opt for blending, but this cannot translate into an (implicit or explicit) obligation of any kind for neighbouring Member States. In addition, blending hydrogen into network does not allow to direct the use of such specific (and potentially high-valued carrier should it has a renewable origin) towards the most efficient applications.
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Iberdrola demands strict hydrogen rules to reduce gas dependency

12 Apr 2022
Topic — Revision of EU gas rules to facilitate renewable and low-carbon gas integration.
Message — Iberdrola requests excluding fossil-based gas from low-carbon definitions to avoid continued gas dependency. They also demand strict legal and organizational separation between hydrogen and gas networks.12
Why — These requirements would benefit Iberdrola's renewable hydrogen business by removing fossil-based competition.3
Impact — Gas network operators lose financial security as they must bear the cost of unused infrastructure.4
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Response to Proposal for a legislative act on methane leakage in the energy sector

12 Apr 2022

IBERDROLA welcomes the “Fit for 55 Package” The Green Deal through the “Fit for 55 Package” offers a unique opportunity to set a proper regulatory framework that boosts momentum on the most efficient renewable alternatives to enable decarbonisation and the achievement of EU climate objectives. IBERDROLA welcomes the Regulation proposal on methane emissions reduction in the energy sector, considering an important step ahead to cope a very relevant environmental challenge. As addressed by the EU Methane strategy, methane follows CO2 as contributor to climate change. It has 80 times more effect on global warning on 20-year scale that carbon dioxide. According IEA, Methane is responsible for around 30% of the rise in global temperatures, being the energy sector responsible for 38% of methane emissions from human activity. In addition, methane is a strong local polluter that contributes to low atmosphere ozone formation, triggering serious health problems. Therefore, limiting methane emissions is key for the whole sustainability goals of the EU and particularly for climate neutrality by 2050. IBERDROLA fully supports the following aspects of the proposal: • Obligation to measure, report and verify methane emissions in the energy sectors (oil, gas and coal) as the first step to design the tools for their efficient reduction. • Methane is responsible not only for the rise in global temperatures but also affects air quality, so obligation to suppress uncontrolled methane emissions from venting and burning (except assessed cases), and leaks from infrastructures and deposits and mines are clearly welcome. • The efficient cost of the measures required by different operators to complain with this Regulation shall be included in the remuneration of the networks based on an ACER publicly available set of indicators. • Measure and control extended to methane emissions corresponding to renewable methane: any energy driver must be proven fully sustainable and compatible with targets of full decarbonisation of the EU to avoid any source of GHG lock-in. However, there are some topics that could be further improved: • Emissions associated with imports should not only be measured and reported but should also be required to be reduced. In this sense, the design of a benchmarking and labelling system would be key. • Ensure coverage of non-energy usage of methane for industry sectors, requiring them the same obligations that are required to operators in the energy sector where methane is used as feedstock in industrial processes. • Ensure full development of EU Strategy on methane emissions, adopting actions regarding not only methane emissions from energy sector, but also from agriculture and waste, according to the planned horizon, if not anticipated. • Penalties across all MSs must be harmonised applying a level playing field among Member States to avoid distortions towards the use of specific carriers. The EC should estimate specific parameters that reflect the environmental damage of failing to comply with this Regulation.
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Meeting with Ditte Juul-Joergensen (Director-General Energy)

12 Apr 2022 · Discussion on the energy transition and energy prices.

Meeting with Daniel Mes (Cabinet of Executive Vice-President Frans Timmermans) and Volkswagen Aktiengesellschaft and

7 Apr 2022 · Meeting with CEO Alliance on Digitising Energy Action Plan

Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

31 Mar 2022

IBERDROLA welcomes the “Fit for 55 Package” The Green Deal though the “Fit for 55 Package” offers a unique opportunity to set a proper regulatory framework that boosts momentum on the most efficient renewable (RES) alternatives to enable decarbonisation and the achievement of EU climate objectives IBERDROLA welcomes the revision of the EPBD IBERDROLA fully supports the following aspects of the proposal: • Decarbonisation of the building stock by 2050 • Phase out of fossil fuels by 2040 • The move to a mandatory Building Renovation Passport • A common Energy Performance Certificates (EPCs) system • Pre-cabling requirements for new residential buildings However, there are some topics that could be further improved: • Heat pump definition: the proposal does not highlight the role of electric heat pumps (eHPs) in the decarbonisation of the building sector. Instead, the proposal has removed the definition of “heat pump” • Zero-emission buildings o Definition: the proposal sets the vision for achieving a zero-emission building stock by 2050. However, what “zero-emission building” means is not properly defined, and it requires a reflection. The definition goes against the EEFP, centralised renewable production will in most cases be economically more efficient than decentralised production (access to best renewable resources; economies of scale; etc). Therefore, the possibility to cover a building’s energy needs with renewable energy from the grid must be recognised as equally compliant on the definition of “zero-emission buildings”. However, the benefits of decentralised renewable production could be recognised as part of each MS’s calculation of the primary energy factor (PEF) According to the proposal, eHPs will have to be connected to a RES production in a building in order to consider it a “zero-emission building”. However, a building could still be “zero-emission” and have a very high energy performance if it uses an eHP that extracts on-site energy from the environment and uses RES from the grid o Climatic zones: the proposal should maintain a unified EU wide classification of climatic zones however, each MS, based on its own analysis, shall determine the climatic zones of its different regions, as the whole surface of a country does not usually have the same climatic characteristics o New buildings & deep renovations: setting the obligation for new buildings to be “zero-emission buildings” from 2030 onwards seems too late. New buildings & deep renovations should be “zero-emission buildings” at least from 2025 (2024 public buildings) o Existing buildings: the proposal should introduce a deep renovation rate of at least 3%, applicable to the overall building stock (6% for public authorities) • EPCs: to enable that the building stock reaches its decarbonisation by 2050, it is important to ensure that all the building stock has an EPC by 2030 • Minimum Energy Performance Standards (MEPS): the proposal shall ensure that by 2025 all new buildings have the highest energy performance standard and set a trajectory for existing buildings • Recharging infrastructure o New buildings: although the ambition introduced in the proposal is welcomed, this could be further improved by considering a higher level of minimum recharging points and ducting infrastructure o Existing buildings: obligations on minimum recharging points and ducting infrastructure for existing buildings should be introduced urgently • PEF: according to the proposal, the calculations shall be set by each MS based on national, regional or local information and set on an annual, seasonal… basis. Although this is a positive proposal, it should be further improved ensuring a dynamic and forward-looking PEF value that adequately reflects the future increase of RES in the electricity mix, based on the NECPs. The alternative to opt for an average EU PEF defined by the EED should be removed
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Meeting with Kadri Simson (Commissioner) and

30 Mar 2022 · Discussion on Solar Power Europe views on how to boost the manufacturing and deployment of solar PVs in the EU.

Response to Energy labelling requirements for space and combination heaters (review/rescaling)

28 Mar 2022

IBERDROLA welcomes the “Fit for 55 Package” The Green Deal though the “Fit for 55 Package” offers a unique opportunity to set a proper regulatory framework that boosts momentum on the most efficient renewable alternatives to enable decarbonisation and the achievement of EU climate objectives. IBERDROLA calls for and ambitious revision of the labelling and ecodesign requirements for space and combination heaters We believe that the following are the main points that should be considered as part of this revision: • The electricity Primary Energy Factor (PEF) should be dynamic and forward looking and updated in line with the National Climate and Energy Plans (NECP) The current ecodesign and labelling class limits are still using the outdated PEF of 2.5 instead of the current one of 2.1 in accordance with the Energy Efficiency Directive 2018/2002/EC (EED). However, updating this value to existing regulation is not enough to reflect the real savings of electrification and implement what the Energy System Integration Strategy stated on this regard: “PEF is an important tool to facilitate comparison of savings across energy carriers. Most renewables are 100% efficient and have a low PEF. The PEF should reflect the real savings brought about by renewable electricity and heat”. Current default PEF for electricity set by the EED is one of the main barriers to promote the electrification of end uses and, hence, to calculate the corresponding energy efficiency gains. A default PEF of 2.1 for electricity seems to be clearly outdated as it does not consider how the increase of renewables in the electricity mix has reduced primary energy consumption, energy dependency and emissions in most MSs. The default PEF value for electricity should adequately reflect the future increase of renewables in the electricity mix, it should be dynamic and forward looking, taking into consideration the future energy mix of the MS that is set on its National Climate and Energy Plans (NECP). • Promotion of efficient and emission free alternatives phasing out fossil systems Only efficient and emission free alternatives that are in line with EU’s decarbonisation objectives, with no lock in effect or stranded costs shall be considered and promoted. In this context, the following measures should be set: o From 2025 all new heating systems sold shall be zero pollutant and CO2 free. o The new Ecodesign rules should not require gas boilers on the market to be hydrogen-ready or to replace existing gas boilers with hydrogen ones. Hydrogen may never become a reality for consumers. Residential heating is and easy to abate sector that could be easily decarbonised through direct electrification.
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Response to Ecodesign requirements for water heaters and tanks (review)

28 Mar 2022

IBERDROLA welcomes the “Fit for 55 Package” The Green Deal though the “Fit for 55 Package” offers a unique opportunity to set a proper regulatory framework that boosts momentum on the most efficient renewable alternatives to enable decarbonisation and the achievement of EU climate objectives. IBERDROLA calls for and ambitious revision of the labelling and ecodesign requirements for water heaters and tanks We believe that the following are the main points that should be considered as part of this revision: • The electricity Primary Energy Factor (PEF) should be dynamic and forward looking and updated in line with the National Climate and Energy Plans (NECP) The current ecodesign and labelling class limits are still using the outdated PEF of 2.5 instead of the current one of 2.1 in accordance with the Energy Efficiency Directive 2018/2002/EC (EED). However, updating this value to existing regulation is not enough to reflect the real savings of electrification and implement what the Energy System Integration Strategy stated on this regard: “PEF is an important tool to facilitate comparison of savings across energy carriers. Most renewables are 100% efficient and have a low PEF. The PEF should reflect the real savings brought about by renewable electricity and heat”. Current default PEF for electricity set by the EED is one of the main barriers to promote the electrification of end uses and, hence, to calculate the corresponding energy efficiency gains. A default PEF of 2.1 for electricity seems to be clearly outdated as it does not consider how the increase of renewables in the electricity mix has reduced primary energy consumption, energy dependency and emissions in most MSs. The default PEF value for electricity should adequately reflect the future increase of renewables in the electricity mix, it should be dynamic and forward looking, taking into consideration the future energy mix of the MS that is set on its National Climate and Energy Plans (NECP).
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Meeting with Pascal Canfin (Member of the European Parliament)

14 Mar 2022 · Fit for 55

Meeting with Mauro Raffaele Petriccione (Director-General Climate Action)

14 Mar 2022 · Energy prices and RePowerEU

Response to Review of the CO2 emission standards for heavy-duty vehicles

4 Mar 2022

IBERDROLA welcomes the “Fit for 55 Package” The Green Deal though the “Fit for 55 Package” offers a unique opportunity to set a proper regulatory framework that boosts momentum on the most efficient renewable alternatives to enable decarbonisation and the achievement of EU climate objectives. IBERDROLA calls for and ambitious amendment of the Regulation setting CO2 emission standards for heavy duty vehicles (HDV) We believe that the following are the main points that should be considered as part of this revision: • Ambitious intermediate and long-term emission reduction objective: given the difficulty of reducing emissions of aviation and shipping, it is necessary to focus efforts on the decarbonisation of road transport. Road transport must be required to reduce its emissions by -100% in 2050, which means that in 2030-2035 the last internal combustion vehicle must have been sold. In this context, intermediate and long-term ambitious emission reduction objective should be introduced also for HDV phasing out the polluting internal combustion engines (ICE) and setting a cost-effective path to road transport decarbonisation. • Stricter emission limits: the new proposal should set more ambitious limits for manufactures in line with the overall emission reduction ambition. • Move to “zero emission vehicle” (ZEV) definition: current Regulation defines “low-emission HDV” those with specific CO2 emissions of less than half of the reference CO2 emissions of all vehicles in the subgroup. At the same time, “zero-emission HDV” is defined as the one without ICE or with ICE that emits less than 1g CO2/km. However, to ensure that the EU climate and environmental objectives are achieved, these definitions should be replaced by “zero emission vehicles” (ZEV) referring to those with only 0 gCO2/km tailpipe emissions. • Set a robust zero emission vehicle incentive: the existing zero and low emission vehicle incentive should be replaced by a bonus-malus system for zero emission HDV. The existing 2% benchmark should also be revised in line with the ambition increase required to reach the updated emission reduction objective. • Fostering the introduction of renewable fuels in the transport sector should be left as an aim of the Renewable Energy Directive. However, it needs to be taken into account that road transport is not a niche hard to abate sector, and therefore, the introduction of less efficient and most expensive alternatives such as renewable synthetic fuels should be left for those sectors where there is no other economic alternative.
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Meeting with Pascal Canfin (Member of the European Parliament)

3 Mar 2022 · Energy

Meeting with Kadri Simson (Commissioner) and

21 Feb 2022 · Spike of energy prices and EC's toolbox, Fit-for-55 proposals and EU taxonomy.

Meeting with Damien Carême (Member of the European Parliament)

15 Feb 2022 · Paquet gazier

Meeting with Nils Torvalds (Member of the European Parliament, Rapporteur)

8 Feb 2022 · RED III

Meeting with Damien Carême (Member of the European Parliament, Rapporteur for opinion)

1 Feb 2022 · Mécanisme d'Ajustement Carbone aux Frontières

Meeting with Susana Solís Pérez (Member of the European Parliament)

1 Feb 2022 · Taxonomy and nuclear waste

Meeting with Susana Solís Pérez (Member of the European Parliament, Shadow rapporteur)

31 Jan 2022 · Alternative Fuels Infrastructure

Response to Act amending Implementing Regulation (EU) 2018/2066 on the monitoring and reporting of greenhouse gas emissions

11 Jan 2022

Iberdrola welcomes the application of the sustainability and emission reduction criteria established by the Renewable Directive for biofuels, bioliquids and biomass fuels, and the alignment of bioenergy policies with other environmental objectives, including those pursued by the EU ETS Directive. Thus, delays in implementing the REDII through its delegated and/or implementing acts or in its transposition in some Member States should not jeopardize the objectives pursued by said sustainability criteria. In this sense, allowing a biofuel, bioliquid and/or biomass fuel that does not meet the sustainability criteria to benefit from zero carbon status in the EU ETS is a perverse incentive, even when such a situation is limited to just a year. More specifically, it could incentivise behaviours that, although for a relatively short time, would be very harmful to the environment. Additionally, biofuels, bioliquids and biomass fuels benefit from support schemes, so delaying their legitimate access to zero carbon status in the EU ETS for a year is not really going to harm their deployment. All in all, the costs due to this proposal are higher than its benefits. Therefore, only biofuels, bioliquids and biomass fuels that are consumed in Member States that – in line with the Treaty principle of the Polluter Pays – use market-based instruments and tools (e.g. taxation) to ensure that the use of unsustainable biomass in the ETS sectors is discouraged, should be allowed to benefit from the derogation from paragraph 5 of article 38 proposed. In this cases, Member States must notify it to the EC no later than 31/01/2022, accompanied with a specific implementation schedule and an impact assessment of the biofuels quantity that may be affected to avoid harmful behaviours. Please find Iberdrola's complete feedback attached.
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Response to European Strategy on international energy engagement

20 Dec 2021

IBERDROLA welcomes the call for evidence on the European strategy on international energy engagement This strategy is an opportunity to (1) foster decarbonisation outside Europe and build a solid leadership in green labelled products; (2) export EU technology; and (3) make sure that the energy imported into the EU complies with the EU 2030 & 2050 objectives. 1. Foster decarbonisation outside Europe This EU strategy should promote, both in the EU and globally, energy efficiency, the introduction of new renewable energy capacity and the uptake of those technologies that would make the EU, and the whole world, reach carbon neutrality in 2050. This would, at the same time, reduce the carbon leakage risk of EU industries and develop new markets for EU industries’ green labelled products. Finally, it is important to note that a fair energy transition will only be achieved if access to reliable and affordable electricity is ensured, since this is critical to improve the competitiveness of the economies globally. 2. Export European technology This strategy would be an excellent opportunity for European industries to export their technology globally. This would accelerate their economies of scale, reducing technology costs and creating quality jobs both in the EU and in countries abroad. Extending EU technology globally would expedite decarbonisation and social acceptance. 3. Import energy that complies with the EU 2030 & 2050 objectives A European strategy on international energy engagement should enable the exchanges of sustainable energy between EU and non-EU countries. However, it is important to note that, to ensure carbon neutrality, the energy that is exchanged shall never incur an emission increase in the country of origin. It makes no sense decarbonising EU by increasing carbon emissions abroad. In this context, the following points shall be considered: • Additionality The sustainable energy exported from a foreign country into the EU shall be additional to the sustainable energy that the foreign country needs to reach its own decarbonisation. This is the only way to ensure that importing energy into the EU does not hamper the decarbonisation of the exporting country. • Same requirements for all products The requirements that the EU produces need to comply shall be extended to imported products as well. Otherwise, there would not be a level playing field. For instance, according to the Renewable Directive, renewable hydrogen produced in the EU must comply with 70% emission reduction criteria, together with additionality, geographical correlation and temporal correlation. Therefore, if Europe imports hydrogen, this hydrogen will need to comply with those same requirements to be deemed renewable. Hence, a collaborative approach for certification should be a basic pillar for this strategy. • Infrastructure Energy assets have very long lifespans that can extend well beyond 30 years. This means that 2050 is only one investment cycle away. If we want to reach net zero emissions by 2050, investments today must be based on those alternatives in line with the long-term decarbonisation objectives, avoiding transitional solutions in line with the “do not significant harm” principle. Consequently, all infrastructure investments must be supported by a cost benefit analysis that internalises all costs, including environmental impacts in the long-term. The dimensioning of those assets should also be an outcome of the cost benefit analysis. • Renewable hydrogen made in Europe Europe must ensure the development of renewable hydrogen made in Europe in the very first instance, before importing it from outside the EU. This would be the unique way to make sure that Europe maintains its technological leadership on the complete value chain of renewable hydrogen industry, achieving maximum impact on local employment and investments and avoiding a future new energy vector dependency.
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Meeting with Cláudia Monteiro De Aguiar (Member of the European Parliament, Shadow rapporteur)

15 Dec 2021 · Refuel Aviation

Response to Methodology for calculating the quantity of renewable energy used for cooling and district cooling

25 Nov 2021

Iberdrola’s comments on Commission Delegated Regulation amending Annex VII of Directive (EU) 2018/2001 as regards a methodology for calculating the amount of renewable energy used for cooling and district cooling 1. Electricity accounting in Heating & Cooling (H&C) Space H&C and domestic hot water could be massively decarbonised through electric heat pumps (eHP). It is a real, competitive, and mature decarbonisation alternative at lowest cost that contributes to all the energy and climate targets. In addition, (a) electric heaters can be the most efficient solution in geographical areas with a mild weather (i.e. low annual utilization of heating means and related dedicated infrastructures), and (b) renewable electricity-based cooling is in most cases the most efficient alternative. However, the RES sub-target in H&C (RES-H&C), which is defined in terms of “gross final consumption of energy from renewable sources”, excludes the renewable electricity (RES-E) supplied for H&C purposes (i.e. contrary to what is the case for the sub-targets for RES in buildings, industry or transport, which includes the RES-E supplied even when in some cases RES-E might not be the most efficient solution). Hence, such an exclusion for H&C is not justified and, more significantly, creates a perverse incentive as it does not adequately consider the benefits of electrification in H&C, goes against the level playing field of all energy carriers and might result in an inefficient penetration of RES-E. Consequently, the RES-H&C sub-target should include the RES-E supplied (which should be deducted from the RES-E in the power sector to avoid double counting). This would allow e.g. for considering the electricity employed in an eHP. 2. Calculation of renewable energy quantity for cooling This comment assumes that RES-E remains excluded from the counting towards the RES-H&C sub-target. In this case, the formula in section 3.1 Part B Annex VII should be amended for the following reasons: - The term QCSupply, determined as the difference between QCSource and EINPUT, represents the total amount of ambient / geothermal / etc. energy supplied for cooling. Hence, it should not be multiplied by any renewable share (SSPFp). - Additionally, the non-electricity renewable share of EINPUT (hereafter EINPUT RES) should also be taken into consideration when determining ERES-C. - Finally, it would be possible to redefine SSPFp as a fraction of the cooling sourced rather than as a fraction of the cooling supplied, which should somehow incorporate EINPUT RES. Therefore, the formula should be amended as follows (see anex): ERES-C = QCSupply + EINPUT RES = QCSource x SSPFp 3. Calculation of the cooling supply that can be considered as renewable Section 3.2 Part B Annex VII establishes how to calculate SSPFPp, i.e. the share of renewable cooling. - The formula assumes a linear relation between SSPFPp and SPFp, i.e. between renewable energy content and efficiency. - However, a highly efficient equipment (i.e. with a high SPFp) can be fed with a non-renewable. Therefore, assuming a linear relation between SSPFp and SPFp could lead to a significant error as it does not consider in any manner EINPUT RES. 4. Calculation of SPFp Section 3.3 Part B Annex VII defines standard SPFp using EU default primary energy factors (PEF), i.e. 2.1 for electricity. However, there is no real need for using EU default PEFs for this calculation, as updated and verified data on the mix of each MS is available, allowing for calculating specific SPFp for each MS. In addition, and considering that the EU's RES target must be achieved through the voluntary contributions of MSs, using the default PEF would penalize the most ambitious MSs and favors those that make less efforts to introduce renewables – i.e. a counterproductive approach.
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Meeting with Pascal Canfin (Member of the European Parliament)

18 Nov 2021 · Fit for 55

Response to ReFuelEU Aviation - Sustainable Aviation Fuels

17 Nov 2021

IBERDROLA welcomes the “Fit for 55 Package” The Green Deal though the “Fit for 55 Package” offers a unique opportunity to set a proper regulatory framework that boosts momentum on the most efficient renewable alternatives to enable decarbonisation and the achievement of EU climate objectives. IBERDROLA welcomes the ReFuelEU Aviation Regulation IBERDROLA fully supports the following aspects of the proposal: • Scope of the regulation: o The introduction of an obligation on jet fuel suppliers to blend a growing share of Sustainable Aviation Fuels (SAFs). o The regulation applies to all fuel sold in the EU, thereby covering all flights arriving to and departing from the EU. o The requirement on airlines to uplift from EU airport 90% of the fuel to prevent airlines avoiding the mandate. However, there are some aspects that could be further improved: • How will EU reach climate neutrality in 2050? This proposal sets a SAF obligation of 63% by 2050. Therefore, the Commission should clarify how the aviation sector will achieve net zero emissions by 2050. This is key to avoid the risk of carbon lock-ins and stranded assets due to new investments (including in extending the lifespan of existing assets) in fossil fuels to supply the aviation sector. • Need to clarify definition of SAF. The proposed Regulation defines SAF as either liquid advanced biofuels that comply with the sustainability criteria of the Renewable Directive or, liquid Renewable Fuels of Non-Biological Origin (RFNBOs) as defined in the Renewable Directive, which would include liquid renewable H2. However, the Impact Assessment (IA) that accompanies this proposal states that the fuels considered in the proposal are only liquid fuels that can be blended with conventional kerosene and are compatible with aircraft engines that are currently in operation – i.e. liquid renewable H2 out of the scope of this Regulation. Consequently, the EC should clarify if liquid renewable H2 is included or not in the SAF definition. • SAF targets: o New SAF target for liquid H2 aircrafts. The proposed blending SAF target excludes the development of alternatives that cannot be blended with existing kerosene. Liquid renewable H2 could also be an alternative to decarbonise the aviation sector. For the time being, there are no commercial liquid H2 airplanes. Therefore, it is important for the EC to ensure that any new liquid H2 aircraft is fuelled with SAF (liquid renewable H2). Otherwise, this type of aircrafts will use fossil H2 as they will not have any obligation or incentive to run on SAF. This could be avoided by introducing a SAF mandate for these types of aircrafts as well. o Increase e-fuel sub-target. The proposal sets a minimum share of SAF and a sub-target for e-fuels and the gap between both figures is supposed to be covered by advanced biofuels. However, e-fuel produced from renewable electricity is the alternative with the larger quantitative potential to replace fossil kerosene used in the aviation sector. Therefore, the proposal should be further improved by reducing the gap between the share of advanced biofuels and of e-fuels. In this sense, the e-fuel sub-target should be 50% of the SAF target, thus giving at least the same incentive to advanced biofuels and e-fuels.
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Response to Revision of the Energy Tax Directive

17 Nov 2021

IBERDROLA welcomes the “Fit for 55 Package” The Green Deal though the “Fit for 55 Package” offers a unique opportunity to set a proper regulatory framework that boosts momentum on the most efficient renewable alternatives to enable decarbonisation and the achievement of EU climate objectives. IBERDROLA welcomes the revision of the Energy Taxation Directive (ETD) The EC’s proposal on the revision of the ETD is fully compliant with the objectives of a) assimilating the role of climate tool to energy taxation, b) avoid the fragmentation of the Internal Market, and c) preserve tax revenues in MSs. Despite the failures to update this Directive in the last years, it is necessary to eventually find a constructive consensus across the European Council on the above objectives. Such a consensus should in any case preserve the following key elements of the Commission’s proposal: • Taxation scales of minimum rates to apply in every country based on the energy content and the environmental performance of each energy vector and different uses. More limited capacity for MSs to apply exemptions and reductions. • Obligation to every MS to keep the ranking established in the tax scale for each use in the national transposition. • Recognition of environmental performance of electricity through minimal tax rates and the environmental low performance of all fossil liquid and gaseous energy vectors. In addition, certain aspects of this proposal could be further improved: • Excessively long transition period (10 years) to adapt minimum rates of fossil or not fully sustainable energies. It does not seem to be justified to freeze minimum rates during the whole transition period for the so called “low carbon” energies. The concept of “low carbon” energy is itself ambiguous as far as linked to Taxonomy legislation expected to be regularly updated (e.g. could consumers/producers of “low carbon” energies get a kind of grandfathering if taxonomy changes the definition of “low carbon”?). • Incentives to best performing energies in air and waterborne transport are not applied to road mobility. • The whole of “renewable fuels of non-biological origin” (essentially renewable hydrogen and its synthetic derivatives) are treated the same, while the environmental performance (efficiency in production and use) is radically different among them. It does not seem to be not justified to maintain the “minimal taxation rates” together with electricity.
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Response to Revision of Alternative Fuels Infrastructure Directive

17 Nov 2021

IBERDROLA welcomes the “Fit for 55 Package” The Green Deal though the “Fit for 55 Package” offers a unique opportunity to set a proper regulatory framework that boosts momentum on the most efficient renewable alternatives to enable decarbonisation and the achievement of EU climate objectives. IBERDROLA welcomes the proposal for an Alternative Fuel Infrastructure Regulation (AFIR) IBERDROLA fully supports the following aspects of the proposal • The move from a Directive to a Regulation • The introduction of new targets for electric recharging infrastructure (RI) o Timeframe: from the entry into force of the Regulation new targets are introduced for to LDV, and from 2025 for HDV o All new targets are binding o LDV targets: we welcome the minimum RI objectives based on coverage and demand criteria. We find a big step forward moving from the previous recommendation of one recharging point (RP) per 10 electric vehicles to the new criteria o HDV targets have been introduced for first time. This new step forward demonstrates that electric trucks are not only a thing for the distant future and that the roll out of chargers needs to start now • Targets for shore-side electricity supply in maritime ports, in inland waterways and the targets for supply of electricity to stationary aircrafts However, there are some aspects that could be further improved: • Energy Efficiency Directive (EED) revision proposal sets that the Energy Efficiency First Principle (EEFP) must be the basis of the planning, policy, and major investment decisions. Alternative fuel infrastructure is not an exemption and as such, there must be and explicit link between the EED and the AFIR • Although the new definition for “alternatives fuels” is welcomed, it could be further improved o “Renewable fuels” definition neither considers explicitly renewable electricity nor renewable hydrogen produced with it o “Alternative fossil fuels for a transitional phase” is defined, which includes CNG, LNG, LPG... This definition should be removed, as no infrastructure should be promoted for alternatives not in line with the 2050 objectives • “Mobility service provider” and “operator of a recharging point” definitions should be replaced by those already implemented in the ISO 15118-Road vehicles standard • RI pricing policy o The proposal should be more flexible on the electronic payment methods allowed, in other not to obstacle future alternatives o Flexibility must be given on how to comply with the automatic authentication requirement, not to obstacle future alternatives o The proposal should not restrict the possibility that market agents have to set the price according to different units o Facilitating cross-border continuity when providing the recharge service has an additional cost that must be reflected in the price however, these prices shall not be abusive. o Digitally-connected RP definition contemplates different technical requirements, each one having a different maturity. Compliance with this requirement depends on each requirement’s technological maturity in each country • RP objectives for the TEN-T network o The proposal does not set any requirements in cities for RI for LDV, while it does for electric truck charging o RP distance for HDV in the comprehensive TEN-T network should be 60km as for the core network and the whole TEN-T for LDV o Setting objectives for the TEN-T comprehensive network for both LDV vehicles in 2030 is too late. These should be advanced to 2025 and 2030 respectively o The minimum individual power output for HDV for 2030 and 2035 should be increased in line with the latest CHAR-IN potential estimates from 350kW to 1000kW • E-fuel infrastructure for shipping and aviation: the introduction of objectives in this proposal could be premature however, the EC should review this approach in 2026 revision process
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Response to Carbon Border Adjustment Mechanism

17 Nov 2021

IBERDROLA welcomes the “Fit for 55 Package” The Green Deal through the “Fit for 55 Package” offers a unique opportunity to set a proper regulatory framework that boosts momentum on the most efficient renewable alternatives to enable decarbonisation and the achievement of EU climate objectives. IBERDROLA welcomes the opportunity to give feedback to the EC’s proposal on the Regulation setting a Carbon Border Adjustment Mechanism (CBAM) CBAM is expected to incentivise the generalisation of climate ambitions across the nations while preserving EU industry competitiveness under increasing carbon prices. In this context, a successful implementation of CBAM depends on the following factors: • The CBAM, expected to replace the free allocation, must be effective to stop carbon leakage. This is linked to its capacity to generalise climate tools in the medium term and, in the short term, to (a) charge effectively the cost of carbon emissions corresponding to imports, (b) to avoid circumvention, and (c) most importantly, to protect EU exporters. • The WTO must declare that the CBAM is compliant with trade rules. Although CBAM seems to be an extension of a domestic regulation to trade partners, o the coexistence with free EUA allocation (though set to decrease) would be problematic, even under the compensation rules to imports proposed; and o the assessment of carbon content for countries and importers and, very specially the design of compensations based on different carbon prices (eventually different climate measures) is extremely challenging to put in place (possibly more than the coexistence with free allocation). Even the green light by the WTO could not totally avoid the risk of trade wars. • The EC must achieve within a reasonable timeframe enough consensus to develop the very complex regulatory frame to operate the CBAM. Iberdrola supports the implementation of CBAM to further generalize the carbon price signal and, hence, consolidate the carbon neutrality target. The main positive elements of the proposal would include: • In a context of asymmetrical decarbonisation efforts, CBAM’s role to protect the competitiveness of the EU industry and to stimulate climate action among third countries. • Complementary role to EU-ETS replacing very gradually the current free EUA allocation. • Avoid the distortion of the ETS by setting the price of certificates in accordance with the auctions of EUAs, without taking direct part in the market. • The incorporation of the power sector to the CBAM would have a low relevance in the whole of the EU, although not in certain regions (e.g. in Eastern countries and somehow in the Iberian Peninsula). As far as the CBAM materialises in the form of a “virtual ETS” and not of an excise tax on electricity consumption, unintended effects on electric consumption and decarbonisation are not foreseen. There are also some aspects of the CBAM that could be further improved: • Ensure the protection of EU exporters under the decreasing and (ultimately) full absence of the current free EUAs allocation. • Hydrogen production and its derivatives is absent among the CBAM sectors. This industry should be included in order to enable the generation of clean hydrogen and balance the situation between the “grey hydrogen” (currently receiving free EUAs) and renewable hydrogen.
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Response to Review of Directive 2012/27/EU on energy efficiency

17 Nov 2021

IBERDROLA welcomes the “Fit for 55 Package” The Green Deal though the “Fit for 55 Package” offers a unique opportunity to set a proper regulatory framework that boosts momentum on the most efficient renewable alternatives to enable decarbonisation and the achievement of EU climate objectives. IBERDROLA welcomes the revision of the Energy Efficiency Directive IBERDROLA supports the following aspects of the proposal: • The introduction of the Energy Efficiency First principle (EEFP) in the planning, policy and major investment decisions will help to avoid investments in possible stranded assets. • Excluding fossil-based efficiency measures from counting towards the energy efficiency target from 2024 is a very positive step forward in terms of avoiding the corresponding carbon lock-in and, hence, ensuring an efficient transition towards a net-zero system. However, there are some aspects that could be further improved: • Governance system for the EEFP. While introducing the EEFP is a very positive move, it is necessary to further detail its governance (methodology, accountability, reporting, etc.). • Ensure the EEFP is applied to all infrastructures. The introduction of the EEFP should not only be limited to gas and electricity networks but should be applied to hydrogen and district heating networks as well. • Network losses. Smart grids will be able to maximize their capacity factor (delivering more kWh by the same infrastructure) in a context of increasing electrification and the use of decentralised resources. Efficient losses benchmarks must take these issues into account. • Remove barriers for an efficient energy system integration (ESI). The Energy Efficiency Directive should incorporate provisions preventing national regulatory schemes applied to the power grid from limiting the full roll out of their potential for the sake of the ESI goals. As an example, consider the case of Spain, where an investment limit is applied to the distribution grid independently from the investment needs corresponding to an efficient ESI. • Exemplary role of public buildings. In line with the Renovation Wave, the renovation rate objective should be doubled to 6% with the objective to have a “zero energy building” stock in 2050. • Foster electrification as the main vector for energy efficiency gains o Review electricity Primary Energy Factor (PEF). The default value of the PEF for electricity has not been updated from its current value of 2.1. However, such default PEF is one of the main barriers to promote electrification – a must for the implementation of the ESI Strategy. It should rather be a dynamic forward-looking value, taking into consideration the future energy mix (dominated by renewable power) and, hence, really incentivising long-term energy efficiency gains. o National obligations should be set in terms of primary and final energy. This is key to ensure that energy conversion losses are duly considered (i.e. “hidden” if national obligations set in terms of final energy only). o The determination of the future efficient network losses benchmarks should not be based exclusively on historic data but should take also into account the comparison of the actual use of the grid in the context future increasing flows from decentralised generation and from demand electrification. o Enhance customer information. Consumers’ energy bills should include information on the standardised energy savings that could be achieved with other alternatives (e.g. heat pumps). o Clean the electricity bill of costs not linked with the supply of electricity. • High efficiency cogeneration. The role of natural gas must be aligned with the EU energy and climate targets and with the Taxonomy Regulation, which gives a role for fossil-fuelled facilities only in case they do not hamper the development of renewable sources and do not cause a carbon lock-in.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

17 Nov 2021

IBERDROLA welcomes the revision of the Renewable Energy Directive (RED) IBERDROLA supports the following aspects of the proposal: • Increase of the RES target to 40%, in line with the highest ambition for 2030. • Introduction of an explicit supportive framework for renewable electricity Power Purchase Agreements, especially for dealing with credit risk. • Introduction of binding targets for renewable hydrogen both in the industry (including feedstock) and transport sectors. However, the level of such targets and the manner to achieve them deserve further reflection (see below). • Role of Guarantees of Origin limited to consumer disclosure only. • Extension of the Union Database based on a mass-balance system to all liquid and gaseous renewable fuels and Recycled Carbon Fuels and to all sectors. • Reduction of biofuels and biogas 2030 share in transport to 2.2%. • Introduction of a credit system for electricity suppliers in the transport sector. • Extension of the definition of RFNBOs (additionality, geographic and temporal correlation, minimum GHG savings) to all sectors. • Considering RFNBOs rather than renewable electricity when counting towards the overall renewables target, as it appropriately considers the loss of efficiency due to indirect electrification. However, crediting RFNBOs to the MS where they are consumed deserves further reflection (see below). However, there are some aspects that should be further improved: • The RFNBOs target in transport should be built considering the needs of those niches where electrification is not feasible – basically aviation and maritime – and its level adjusted accordingly – from 2.6% to approximately 1.6%. This adjustment should not translate into increasing the RFNBOs ambition in industry. • RFNBOs credited to the MS where they are consumed only after agreeing a statistical transfer, joint projects or joint support schemes when so required – e.g. when the renewable electricity employed to produce the RFNBOs, or the RFNBOs themselves, are produced in a different MS (i.e. the producing MS hereafter). In such cases, the producing MS should retain the credit for the corresponding renewable energy unless an agreement with the consumed MS is reached. This is key to ensure that all the costs due to integrating renewables into the system for the producing MS are appropriately allocated to the consuming MS – i.e. prevent free riding / cross-subsidies between MS. • Make it explicit that MSs can employ statistical transfers, joint projects and joint support schemes to fulfil their respective 50% renewable hydrogen in industry sub-target – especially important for overall efficiency when hydrogen infrastructures are at a nascent stage and additional renewable power might not be equally available across the EU due to congestions. • Need for guidelines on permitting, including mandatory national strategies for implementation, Key Performance Indicators to track progress and incentives for those MSs performing appropriately (e.g. priority on CEF allocation for renewable projects). • Measures in building sector should be left open to the updated EPBD • The definition of the renewable H&C sub-target should include electricity, and its level should be adapted accordingly. When counting towards the overall renewables target, the renewable power consumed in the H&C sector should be deducted from that in the power sector to avoid double counting. • No increase in biofuels produced from food and feed crops should be allowed. • Private recharging should be integrated within the boundaries of renewables in transport, and the level of this sub-target adapted accordingly. In addition, some flexibilities when counting the renewable power used in recharging should be possible for going beyond the grid mix (e.g. use of smart recharging).
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Meeting with Kadri Simson (Commissioner) and

11 Nov 2021 · Round-table discussion on the regulation for the hydrogen market.

Response to FuelEU Maritime

8 Nov 2021

IBERDROLA welcomes the “Fit for 55 Package” The Green Deal though the “Fit for 55 Package” offers a unique opportunity to set a proper regulatory framework that boosts momentum on the most efficient renewable alternatives to enable decarbonisation and the achievement of EU climate objectives. IBERDROLA welcomes the revision of the FuelEU Maritime Regulation IBERDROLA fully supports the following aspects of the proposal: • Objective and purpose: o The introduction of new GHG intensity targets until 2050 that increase in ambition over time, requiring ships calling at EU ports to reduce the carbon footprint of the energy used onboard. o The obligation to use “on-shore power supply” in ports under the jurisdiction of a Member State. However, there are some aspects that could be further improved: • How will the maritime sector reach climate neutrality by 2050? The EC proposes in this Regulation a new emissions intensity target of -75% in 2050 for maritime sector. While the introduction of a so far inexistent target is per se a very positive step, the EC should clarify what are the next steps planned for the maritime sector to ultimately achieve net-zero emissions by 2050. • Need for a multiplier for e-fuels. Considering that e-fuels are the only alternative that can be sustainably scaled up to meet the energy demand of the sector, its use should be incentivised. Despite its potential, e-fuels are at present least mature and cost-competitive. Consequently, this Regulation should grant them a multiplier of at least 5 for the sake of boosting their use and facilitating the development of both the technology and supply chain. • Need to mitigate as much as possible the risk of carbon lock-ins. To make this regulation “Fit for 55”, it is necessary to (a) progressively increase its ambition and, at the same, time, (b) avoid the risk of carbon lock-ins due to transitional solutions. To this end, the EC should: o Increase the 2050 objective. The -75% emission intensity reduction target proposed for 2050 is far from net-zero and, apparently, would be easily achievable considering just the renovation of the ship fleet by 2050. To be consistent with the Green Deal targets, this Regulation should set at least a -95% emissions intensity target for 2050. o Increase the 2045 objective. By 2045 a large part of the current ship fleet would have been renovated. Consequently, the EC should send a strong message to ensure that the new fleet is suitable for total decarbonisation. Hence, this Regulation should set at least a -70% emissions intensity target for 2045. o Increase the 2035 and 2040 objectives. From 2035, it is expected that renewable maritime fuels have significantly reduced their competitive gap, even outcompeting low carbon fuels. Hence, in the absence of ambitious objectives from 2035 onwards, there is a risk of a carbon lock-in due to overinvesting in transitional solutions, which would at the same time hamper the ramp-up of the e-fuels production. To avoid this, this Regulation should set an emissions intensity target of at least -20% from 2035 and -40% from 2040. • Implement a robust and transparent penalty system. Setting a robust penalty system is needed to ensure agents are appropriately incentivised to comply with the targets and provisions in this proposal. To this end, the Regulation should ensure that the cost of the penalty is higher than the cost savings due to a non-compliance. Hence, the principles to determine the penalty in such a manner should be part of this Regulation, together with (a) the monitoring of the cost of renewable and low-carbon fuels vis-à-vis that of the fossil fuels substituted and (b) the circumstances under which a review of the penalty level would be immediately triggered by the EC (i.e. when the penalty is lower than the savings due to a non-compliance).
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Response to Revision of the CO2 emission standards for cars and vans

8 Nov 2021

IBERDROLA welcomes the “Fit for 55 Package” The Green Deal though the “Fit for 55 Package” offers a unique opportunity to set a proper regulatory framework that boosts momentum on the most efficient renewable alternatives to enable decarbonisation and the achievement of EU climate objectives. IBERDROLA welcomes the revision of the Regulation on CO2 emission standards for cars and vans IBERDROLA fully supports the following aspects of the proposal: • The introduction of an ambitious emission reduction objectives for new cars and vans in 2035 of -100%. This strong and welcomed proposal substantially phases out the polluting internal combustion engines (ICE), setting a cost-effective path to road transport decarbonisation However, there are some topics that could be further improved: • Intermediate emission reduction objectives in 2025 and 2030: in order to achieve the -100% emission reduction objective for new cars and vans in 2035, the introduction of ambitious intermediate objectives is crucial. We believe that the emission reduction objectives should be increased to -30% in 2025, -45% in 2027 and -80% in 2030 for cars and -22% in 2025, -42% in 2027 and -78% in 2030 for vans. • Zero emission vehicle incentive: o Update definition: this Regulation defines as “zero and low emission vehicles” (ZLEV) those with tailpipe emission below 50 gCO2/km. However, to ensure that the EU climate and environmental objectives are achieved, this definition should be modified to “zero emission vehicles” (ZEV) referring to those with only 0 gCO2/km tailpipe emissions o Update the benchmark system: the current 15% benchmark for 2025-2030 should be increased to 22% 2025, 37% 2027 and 67% 2030, in line with electric vehicle sales quotas needed to achieve the -100% objective in 2035 (according to BloombergNEF’s recent analysis) o Remove multiplier for low emission vehicles: the multiplier of 0.7 on the ZLEV system for cars should be removed. This multiplier increases the value of more polluting cars disincentivising those with 0 gCO2/km
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Response to Updating the EU Emissions Trading System

8 Nov 2021

IBERDROLA welcomes the “Fit for 55 Package” The Green Deal though the “Fit for 55 Package” offers a unique opportunity to set a proper regulatory framework that boosts momentum on the most efficient renewable alternatives to enable decarbonisation and the achievement of EU climate objectives. IBERDROLA welcomes the revision of the Emission Trading System Directive (EU ETS) IBERDROLA fully supports the following aspects of the proposal: • A more ambitious emission reduction target of 61% and the necessary tools to fix the emissions’ new cap. • The use of 100% of revenues generated from the auctioning of allowances for climate issues and to address social aspects. • The requirement that biofuels must meet the sustainability criteria to be considered emission neutral, in line with the Renewables Directive. • Exclusion of the financing of any fossil fuels through the Modernisation Fund, strengthening the consistency with EU’s climate targets. • EU ETS extension to maritime transport’s emissions, introducing a CO2 price signal from 2026. • The application of a more effective price on aviation emissions due to the phase out of allocation of free allowances for airlines by 2027, and the reduction of the number of allowances as of 2023 by an increased Linear Reduction Factor. • CBAM as a complementary element to the ETS, replacing progressively the free allocation and providing a long-term visibility to industrial investment decisions. • Setting a separate EU-wide ETS with specific allowances for road transport and buildings, aligned with Effort Sharing Regulation target, will send the proper decarbonisation price signals while mitigating the impact on consumers of higher carbon price. • Maintaining the increased withdrawal rate of Market Stability Reserve in 24% till 2030 will reduce the existing surplus or any new one as fast as possible. However, there are some topics that could be further improved: • Expand the scope of the EU ETS to extra EU flights, as price signal must be extended putting all transport options on level playing field. • Expand the scope of the EU ETS to 100% of emissions of imports from a port outside the EU, and exclude European exports. • Move the benchmark system revision data from 2026 to 2024, and make it binding to remove as soon as possible the competition distortion between the polluting and non-polluting technologies (i.e. fossil and renewable hydrogen). • Include the production of hydrogen whose capacity is above 20 MW instead of 25 tons per day in EU ETS scope to allow small electrolysers to participate in the reviewed benchmark system. • A greater and binding harmonisation of indirect costs aids to avoid deep pockets distortions. • Market Stability Reserve should reduce its thresholds setting a more stringent upper bound as emissions are reduced. • Member States shall cancel an amount of EUAs equal to the avoided emissions due to national carbon abatement measures beyond RES and EE objectives to avoid impacts on the ETS. • The MSR’s Price Containment System for road transport and buildings’ ETS, should include measures to manage excessively low prices, which do not give a sufficient signal, so that it becomes a symmetrical tool.
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Response to Updating Member State emissions reduction targets (Effort Sharing Regulation) in line with the 2030 climate target plan

8 Nov 2021

IBERDROLA welcomes the “Fit for 55 Package” The Green Deal though the “Fit for 55 Package” offers a unique opportunity to set a proper regulatory framework that boosts momentum on the most efficient renewable alternatives to enable decarbonisation and the achievement of EU climate objectives. IBERDROLA welcomes the revision of the Effort Sharing Regulation (ESR) IBERDROLA fully supports the following aspects of the proposal: • Increase the EU-wide emission reduction target for the ESR sectors from -30% (vs. 2005) to -40% as well as Member States’ targets for those sectors in order to achieve the European climate ambition of 55% emission reductions in 2030 • Maintain the scope of the ESR (including road transport and buildings). With this proposal, national objectives will not be jeopardized, and will contribute to 1) the adoption of national climate policies – i.e. ending subsidies for polluting company cars –, and 2) EU policies – i.e. cars CO2 standards – will not be in danger since the motivation of the Council (countries) to adopt ambitious EU sectoral measures will not be altered. In addition, there are some aspects that could be further improved: • A review of the carbon budget in the middle of the decade should be included. The EC should take into account real emission levels in 2020 in the calculation of the carbon budget both to ensure that the overall emission reductions in the ESR are not artificially inflated and not to weaken the efforts that these sectors must make to decarbonise themselves in the second part of the period • Flexibilities based on banking and transfers to cover up any gap in the national binding targets are welcomed. However, borrowing should be limited as it could delay the implementation of mitigation measures, accumulating most of the effort by the end of the period, which could jeopardize the achievement of the objectives. • The LULUCF flexibility should be removed. Net removals in the land use sector cannot be considered directly equivalent to emission reduction in other sectors. Besides, this flexibility adds 280 million tonnes to the 225 million tonnes limitation established by the Climate Law, going against the essence of its mandate (i.e. beyond the said limitation). • The additional reserve should be removed. The formula distributing national targets already takes into account different national circumstances and, as it is the case with the LULUCF flexibility, net removals in the land use sector cannot be considered directly equivalent to emission reductions in other sectors and goes against the essence of its mandate. • In the event of countries exceeding their Annual Emission Allocations, transparency of corrective action plans should be improved. In addition, economic penalties should be introduced and mandatory review of NECPs should be implemented.
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Meeting with Pascal Canfin (Member of the European Parliament)

4 Oct 2021 · Green Deal

Response to Revision of Non-Financial Reporting Directive

21 Jun 2021

Iberdrola welcomes the revision of the Non-financial Reporting Directive leading to the Corporate Sustainability Reporting Directive. Reinforcing reporting requirements will lead to more consistency and comparability in non-financial reporting, which is crucial for a level playing field. Sustainable reporting mean that the undertakings, specially the reporting organizations, will face a huge challenge of adapting their processes and controls to widen the number of contents and KPIs. We believe it is important to keep in mind the increasing costs for reporters, and the need to reach a balance between achieving those goals and the expected increase of costs. In any case, we request a reasonable deadline for its full implementation. Iberdrola’s thought is that materiality needs to influence the scope of contents and KPIs. So, we propose to narrow the universally compulsory reporting requirements to a limited number of indicators. Furthermore, sector specifics should be considered when developing the standards, but narrowed to the material issues for the industry. Moreover, the required prospective information to report should be limited. Differently to financial information, that focuses on past performance, some stakeholders require that non-financial information includes prospective description and even estimates. This expectation does not consider the additional and costly complexity when it comes to elaborate, control and verify prospective information. Consequently, Iberdrola’s proposal is to minimize requirements to report prospective KPIs. Regarding the future evolution for the verification, and the uprising requirements in order to reach a reasonable assurance, this will have a huge impact on the amount of resources dedicated by the undertakings: internal assurance model deployment, business dedication to reporting activities…In order to put a limit on the impact of the process, we propose: (i) to set a longer transition period and (ii) to reduce the indicators subject to limited assurance process: keep those considered key within a limited number (5-10). We attach in a specific note our comments focusing the elements pointed above as reflected in certain recitals of the Directive proposal the depict the principles of the reform. We will be happy to discuss any comment and extend in depth our views.
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Response to Commission Delegated Regulation on taxonomy-alignment of undertakings reporting non-financial information

2 Jun 2021

Iberdrola thanks the opportunity to provide comments to the draft Delegated Act on Taxonomy Reporting Obligation regarding the following six main issues. A more detailed note is annexed to the consultation response. We will be happy to supplement any additional explanation or hear about any comment. 1. Requirements to report information for the previous 5 years Requiring companies to publish the KPIs for the previous 5 years (article 9.3) constitutes an excessive and complex burden without proven benefit for the potential end-user. Technical screening criteria are bound to evolve, reporting over a 5 years-period would entail complex and recurring re-assessment leading to non-comparable/ inconsistent table over time. The focus should rather be on reporting annual data from the previous year which is conform to financial reporting standards and explain (in qualitative manner) the main changes occurred. For these reasons, we propose the Delegated Act to be amended to only require 2 years of comparable data (N and N-1) starting to apply in the second year of application of the disclosure requirements. 2. Requirements to implement the requirements in such a short period of time The time for preparation is seen as too short (the first reporting year has started while the requirements are yet not published; financial data is not yet processed in a way compatible with the newly provided requirements; changing data structures or implement work-arounds is never a good solution from a governance and audit perspective). We require the postponement of the mandatory reporting by one year. Similar concerns will need to be considered for the reporting on the four remaining environmental objectives. 3. Requirements for OPEX information The guidance is still unclear for OPEX. As described in 1.1.3.1/2, OPEX is a mere listing of expenses, leaving wide room for interpretation and therefore compromising the target of a uniformly applied classification. Furthermore, whilst the Commission has previously made clear that OPEX should only be disclosed “when relevant”, this disclaimer is not included in the draft DA, suggesting that all companies should disclose the three metrics (Turnover, OPEX, CapEx). 4. Requirements for CAPEX Plan approval • Remove the requirements for which the plan should be disclosed. Sustainable investments are often strategically important and commercially sensitive projects, and premature disclosure may impact the competitive advantage of the undertaking planning the investment. • Remove the requirement for which the plan should be disclosed and approved by the Management Board of non-financial undertakings. • Remove the 7-year maximum time limit for activities to become Taxonomy-aligned. Companies may invest in transformation efforts with a larger timeframe. 5. Clarity of how to report turnover for undertakings vertically integrated The DA should clearly explain, supported by reference to appropriate accounting standards for consolidation, how to report activities metrics (Turnover, OPEX, CapEx) in those cases where activities are part of a vertically integrated company. This is a situation very common in the energy industry, where, for instance, technologies linked to green assets would sell their production to Retail/Sales divisions who would finally sell it to end-customers. 6. Clarity on how the CAPEX value should be obtained The DA should clearly explain, supported by reference to appropriate accounting standards, how to clearly report activities metrics (mainly CapEx).
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Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

22 Mar 2021

IBERDROLA calls for and ambitious revision of the EPBD based on electrification Energy efficiency (EE) and direct electrification go hand in hand and offer the best possible benefits to achieve cost-effective decarbonisation. Any measure that boost electrification will automatically boost EE as well. Promotion of efficiency on heating and cooling (H&C) Only efficient and emission free alternatives that are in line with EU’s decarbonisation objectives with no lock in effect or stranded costs should be analysed and promoted: • From 2025 all new H&C system sales must be zero pollutant and CO2 free o The EC should implement new regulation to establish efficiency, emission and pollution standards (CO2, NOx, PM…) for all H&C systems (as for cars) • Set a timeline to restrict inefficient and polluting installations in buildings and replace them with efficient and non-emitting systems (such as electric heat pumps): o New buildings: fossil fuel phase out by 2025. All new buildings must install the most efficient and least-polluting alternative (such as electric heat pump, eHP) o Existing buildings: fossil fuel phase out by 2035. All existing buildings must renovate their systems with the most efficient alternative (eHP) o Industry: all low and medium temperature industries that go through major renovations should, through an independent cost benefit analysis, evaluate electrification as a potential decarbonisation alternative Promotion of efficient buildings •Set ambitious renovation targets for the whole building stock o Set an annual deep renovation rate of at least 3%, applicable to the overall building stock, making sure that these renovations reduce the average energy consumption by at least 60% • Set a harmonised and ambitious EU building performance certification system o Set a harmonised building performance certification system across the EU, establishing the basis for possible grants or benefits - The best category should be reserved for those buildings with zero primary fossil fuel energy consumption (zero fossil/renewable energy buildings) o New buildings - Set a binding trajectory for implementing a minimum energy performance category ­ By 2025 new buildings must have the highest energy performance category (zero fossil/renewable energy buildings) - Pre-installation for eHPs in all new buildings (air/water ducts, including radiant floor ducts) o Existing buildings - All existing buildings must have an energy performance certificate by 2024 - Set a binding trajectory for implementing the minimum energy performance category: ­ By 2030 MSs must improve the average energy performance of their building stock by at least two levels vs 2021 ­ By 2040 MSs must ensure that at least 70% of existing buildings meet the highest energy performance category (zero fossil/renewable energy buildings) to achieve 100% by 2050 Promotion of efficient transport •Establish a plan for the development of recharging points (RPs) in buildings: o New buildings and deep renovations - From 2024 buildings must have the ducting infrastructure (DI) - From 2024 non-residential buildings must have RPs in at least 15% of their parking spaces and at least 1 RP o Existing buildings: by 2030 50% of existing buildings with more than 10 parking spaces must have DI - From 2025 non-residential buildings must have RPs in at least 15% of their parking spaces and at least 1 RP Exemplary ambition for public administrations •Measures should affect not only to central governments, but also to regional and local governments •H&C sector: public administration must phase out fossil alternatives in new buildings by 2022 and in existing buildings by 2025 •Renovation rate: the current 3% renovation rate for public bodies should be doubled to 6% in 2030 in line with the Renovation Wave ambitions Make sure that all new public administration buildings have the highest energy performance category (zero fossil/renewable energy buildings) by 2022, and all the building stock by 2030
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Meeting with Frans Timmermans (Executive Vice-President) and Volkswagen Aktiengesellschaft and

18 Mar 2021 · European Green Deal as a growth strategy

Response to Revision of EU rules on Gas

10 Mar 2021

• This package should be framed within the 2030 and 2050 goals. Hence, it must: o be consistent with the goals and principles of the Green Deal; o respect the basic principles of liberalisation; o be aligned with the decarbonisation-enabling initiatives of the CEP; o be realistic regarding the contribution of hydrogen and gas to carbon neutrality (i.e. hard-to-electrify sectors); o enable an efficient energy sector integration, also regarding the allocation of decarbonisation costs. • This package should prepare the gas and hydrogen markets for their expected dual role: (a) Supply decarbonised energy to hard-to-electrify sectors. Carbon neutrality means abandoning natural gas. Methane (also from renewable sources) is the second biggest contributor to climate change. Hence, direct electrification must be prioritised. (b) Provide additional flexibility options to the energy system where and when efficient. Ensuring a level playing field between all flexibility options should be a major goal for this package (e.g. design of grid tariffs and system charges; tackle the issue of gas storage depending on planning decisions vs electricity storage depending on market signals). • According to the Energy System Integration (ESI) Strategy, applying the energy efficiency first principle (EEFP) across sectoral policies is at the core of system integration. Thus, this package should incorporate the elements required for allowing for a coordinated planning and operation of the energy system. Especial attention shall be paid to applying the EEFP to hydrogen infrastructures (join scenarios, priority to non-infrastructure solutions, CBA methodology ensuring a level playing field between short- and long-lived projects, etc.). Although at EU level this is an issue for the TEN-E, similar provisions should be applied at national level. •While RES are promoted within the RED framework (under revision), this package should enable an efficient integration of those RES into the market. In this sense, the Hydrogen Strategy described the limitations of blending (i.e. less efficient, diminishes the value of hydrogen, changes the quality of the gas consumed affecting the design of gas infrastructure, end-user applications and cross-border interoperability). Therefore, rules are needed to avoid the fragmentation of the gas market (i.e. EU-wide gas quality requirements), while allowing blending only in case of (i) renewable hydrogen production, (ii) in a transitional phase (e.g. no long-term access rights conferred), and (iii) consistent with the existing uncertainties on hydrogen supply and demand (e.g. close to well-identified existing hydrogen demands). •In addition, the future of the gas and hydrogen systems are dominated by uncertainty (demand, technology, competitiveness, potential imports, etc.). Thus, a no-regret approach should be applied: start by prioritising the replacement of current fossil-based EU hydrogen consumption with renewable hydrogen. An uncontrolled deployment should not be facilitated (risk of stranded assets and of conditioning the future development of efficient infrastructures – see the proposed limitations for blending). •This package should reinforce the key principles of liberalisation. Regarding unbundling, it should be made clear that emerging technologies such as electrolysers are not natural monopolies and, hence, cannot be owned or controlled by TSOs / DSOs. •An efficient energy sector integration is also about the allocation of the decarbonisation costs. Cross subsidization between e.g. power and hydrogen consumers must be avoided. – this would be contrary to the EEFP. All energy carriers should contribute to financing the decarbonisation in a fair manner. •Carbon leakage measures (CLM; e.g. free allocation of EUAs) should not distort competition between technologies. However, production of hydrogen from fossil fuels benefits of such measures. Hence, until CL measures are not redesigned, a transitional solution is needed.
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Response to Revision of the guidelines for trans-European Energy infrastructure

8 Mar 2021

IBERDROLA welcomes this proposal, that contributes to creating an energy infrastructure consistent with the Green Deal’s goals. The removal of the oil and gas categories, the mandatory sustainability criterion for eligibility or the increased oversight of the EC on the TYNDP are all very positive. However, further improvements are needed, especially to: a) Further shape the sustainability criteria: • Smart gas grids (SGGs) that serve to integrate unsustainable low-carbon gases should not be eligible. A definition should be included. • SGGs that serve to integrate H2 into the gas grid should be eligible under specific circumstances only, in line with the Hydrogen Strategy: o SGGs eligible if the hydrogen to be injected is renewable only. o The amount of hydrogen that can be injected should be determined considering the future gas demand (expected to decline; preserve the future security of the grid). A later gas grid repurposing cannot be taken for granted, neither conditioned by an inefficient early deployment of hydrogen injections. o The CBA methodology should only deem beneficial hydrogen injections in branches that will surely be repurposed. • Eligibility of electrolysers should not require a “network-related function”. It is arbitrary (not defined; not a result of the TYNDP). Electricity or underground hydrogen storages are not subject to a comparable requirement. • The sustainability of CO2 infrastructures should not be taken for granted. It depends on the associated carbon capture facilities: If not aligned with the Green Deal’s goal (e.g. carbon lock-in; more energy efficient option), the CO2 infrastructures should not be eligible. • Creating a hydrogen backbone should not be assumed an aim ex-ante. Such aim should be a result of the planning to be carried out. Uncertainty on hydrogen demand and supply is very high and, hence, the real need for a backbone. Similarly, it is too early to define specific priority corridors: rather treat hydrogen grids as a thematic area (like cross-border CO2 networks). b) Make the Energy Efficiency First Principle (EEFP) more operational: • Include an explicit definition of the EEFP (see recital 64 Regulation 2018/1999). • The EEFP should be embedded in the eligibility criteria of every categories: o Electricity transmission, storage and smart grids contribute to sustainability also by electrifying the economy. o Hydrogen, electrolysers and SGGs contribute to sustainability only when focused on the supply of hard-to-electrify end-uses. • The EEFP should be embedded in the TYNDP joint scenarios, which should assume (i) end-users take full advantage of cost-efficient, technically and environmentally sound energy efficiency measures, (ii) energy is produced in the most efficient manner, and (iii) administrative barriers are removed (e.g. permits). •The CBA methodology should: o not penalise the most efficient solutions in the longer-term: Need for an appropriate discount methodology; o correct for “myopia”: Fair comparison between “transitory” (not reaching 2050; non-carbon neutral) and “durable” projects (reaching 2050; carbon neutral). “Transitory” projects should bear the cost of any additional measure needed to achieve carbon-neutrality by 2050. •The EEFP must guide the infrastructure gaps identification: o Ensure all potential non-infrastructure solutions have been analysed: The infrastructure draft reports should be public, describe the non-infrastructure solutions analysed and subject to a consultation. o Prioritise infrastructures solutions that enable the highest energy efficiency as a second-best. •Joint responsibility on hydrogen planning and joint infrastructure gap report by ETSOE and ENTSOG to ensure they are as aligned as possible in the new Energy System Integration context. •None of the new infrastructure categories introduced (H2, electrolysers, SGGs) should be eligible for the first Union list under this TEN-E revision as they would not be analysed yet part of the TYNDP.
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Response to Revision of EU Ambient Air Quality legislation

13 Jan 2021

Air pollution is the biggest environmental risk to health in the European Unión According to the World Health Organization (WHO), air pollution is the biggest environmental risk to health in the EU. 96% of EU citizens living in urban areas were exposed to levels of air pollutants considered by the WHO as damaging to health. Air pollution tends to affect city dwellers more than inhabitants of rural areas because the density of people living in cities means that air pollutants are released on a larger scale (for example, from road transport and local heating systems) and because dispersion is more difficult in cities than in the countryside as pollutants are emitted closer to the ground. Consequently, each year in the EU air pollution causes about 400 000 premature deaths, and hundreds of billions of euro in health related external costs. Climate change and air pollution share the same origin, fossil fuel combustion; consequently, the solution is the same: the decarbonisation of the current energy model. EVs and eHPs are the most efficient, sustainable mature solutions to both decarbonise and combat air pollution in the heating and transport sectors. Taking into consideration that road transport and local heating systems are the main cause of environmental pollution, electrification of both sectors through electric vehicles (EVs) and electric heat pumps (eHP) will play a major role on a zero pollution future. EVs and eHPs are the most efficient, sustainable mature solutions to both decarbonise and combat air pollution in the heating and transport sectors. IBERDROLA welcomes the Revision of the Ambient Air Quality Directives The Green Deal offers a unique opportunity to set the basis to solve EU’s air pollution problem and review the 2008 Air Quality Directive. We believe that the following are the main points that should be considered: • Establish stricter air pollution limits in line with the WHO guidelines: according to an analysis by the European Environment Agency, if the concentration limits for the most harmful pollutant (PM2.5) was the same as that recommended by the WHO, premature deaths caused by this pollutant would be reduced by 30% • Set zero emission zones from 2025 in cities/towns >50,000 habitants • Increase and adequately regulate the sampling points • Establish common guiding principles to define consistent Air Quality Plans in polluted areas of the MS to combat air pollution in a coordinated way Set a robust Governance system • Assure the completion of the limits set by the Directive, adopting legal actions and penalizing the MS that exceed them • Clearly inform citizens about air quality, promoting the air quality awareness Finally, we believe that a tax reform based on the ‘polluter pays’ principle will also enable the internalisation of the environmental cost associated with each energy product and foster a better air quality. will be happy to answer any question about its positions and extend the explanations addressed in this document.
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Response to Revision of Regulation on Union guidelines for the development of the trans-European transport network (TEN-T)

18 Dec 2020

IBERDROLA calls for and ambitious revision of Regulation on Union Guidelines for the development of the Trans-European Transport Network (TEN-T) In order to promote the development of electric vehicles, we believe that the following are the main points that should be considered as part of the TEN-T Regulation: • Prioritise the infrastructure for zero tailpipe emission alternatives, taking into consideration that from 2030-2035 all new cars and vans will need to be zero tailpipe emission in order to achieve EU’s climate objectives. • Set minimum basic charging infrastructure mandatory objectives for 2025 and 2030 based on coverage and demand criteria and with a concrete and realistic implementation plan: o For light duty electric vehicles:  Minimum coverage infrastructure to be set no later than 2025 both in the Core and Comprehensive TEN-T Network: 1 charging station of a minimum total installed capacity of 450kW (with charging points from 50 to 350 kW and at least one over 150kW)* every 60km.  Set, no later than 2025, the necessary charging infrastructure both in the Core and Comprehensive TEN-T Network in line with the electric vehicle fleet objective of each Member State’s National Energy and Climate Plans (NECP). Applying the previous to Spain (5 million electric vehicles by 2030 according to the NECP), we estimate approximately 3 GW* of infrastructure. o For heavy duty electric vehicles:  Minimum coverage infrastructure to be set no later than 2027 in the Core and Comprehensive TEN-T Network: 1 charging station of a minimum total installed capacity of 2.4MW (with charging points from 350kW to 1.2MW)* every 60km. • Contemplate the potential role of electric distribution companies as infrastructure providers of last resort in cases where market initiatives have failed to provide enough public charging coverage, in accordance with the electricity directive and regulation. • 90% of interurban fuel stations along the roads of the TEN-T Core and Comprehensive Network to be equipped with publicly accessible high-power fast charging points for electric vehicles by the end of 2027. • Remove interoperability barriers making sure that electric vehicles, charging points and all kind of systems for charging and additional services are compatible. Iberdrola will be happy to answer any question about its positions and extend the explanations addressed in this document. *NOTE: we believe that setting an objective based on the number of recharging points with no associated infrastructure capacity is not correct. As a consequence, in this document we base our analysis on infrastructure capacity.
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Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

Iberdrola fully supports the EU initiative to implement a Taxonomy to facilitate the funding of clean activities and increase their visibility. Although the Commission’s draft Delegated Act (DDA) is generally well oriented and aligned with the feedback provided by the TEG, we note that certain critical aspects are ambiguous, come into conflict with the Taxonomy Regulation itself and do not respect the EU acquis. This response contains the general arguments. A document with detailed evidence and proposals is attached to the consultation. Emissions intensity threshold While the draft Delegated Act incorporates the TEG-recommended emissions intensity threshold of 100 g CO2e /kWh, which also relates to transitional activities, it does not acknowledge a precise review schedule ending in net-zero emissions in 2050. The absence of a reduction schedule for the emissions threshold associated with an admissible explicit operations life (coherent with decarbonisation path), opens the application of technical screening criteria to uncertainty, something incompatible with attracting investment, and leaves the concept of “transitional activities” undefined. Manufacture of hydrogen Clean hydrogen is expected to play a very significant role in the path to EU carbon neutrality. However, the EC DDA does not fully acknowledge the difference between fully decarbonised and hydrogen which has a carbon footprint (produced with the intervention of carbonic feedstock or fuels). In addition, the Draft does not provide either a reduction schedule for the emissions threshold of the carbonic hydrogen, or the requirements for the CO2 emissions involving other transitional activities. Networks for renewable and low-carbon gases To ensure consistency with the Regulation (EU) 2020/852 and the principle of efficient investment the criteria should: • make clear that only facilities 100% dedicated to hydrogen and low-carbon gases are taxonomy eligible, • provide that the facility should be operational and (100%) dedicated to taxonomy-compliant gases within 5 years from initial classification in the taxonomy • remove reference to blending (which is considered inefficient by the EC) Storage of electricity Pumping hydro is today the most efficient 0-emissions technology which meet the challenge, and the only able to respond for sufficiently long periods. Revert the exclusions from the "electricity storage category" both (i) open-loop pumped hydro-storage systems and (ii) any pumped hydro-storage installations « connected to river bodies », without providing a precise definition of a "river body". Hydropower The current DNSH conditions proposed for hydropower do not respect the current EU acquis, are inconsistent with other elements of the Draft and difficult to apply. The governing regulations for water management should be the Directive 2000/60/EC, as reported by the TEG report and acknowledged by the EC Joint Research Center. In particular, current facilities 0-emission hydro facilities should be encouraged to improve their efficiency and not excluded from taxonomy. T&D of electricity The whole electricity grid is supporting the energy transition through the connection to renewable and distributed resources an effective integration of them, or enhancing energy efficiency, while ensuring the quality and security of supply. • Delegated Act should define all investments in the electricity grid infrastructure as taxonomy eligible, including reinforcements • Smart meters and their digital infrastructure should be explicitly included Adaptation We suggest to simplify the requirements of Mitigation activities established for DNSH to climate change adaptation, avoiding that the criteria might lead to a lock-in of carbon-intensive assets.
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Meeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness)

1 Dec 2020 · EU Green Bond Standard

Meeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness)

1 Dec 2020 · EU Green Bond Standard

Response to Updating Member State emissions reduction targets (Effort Sharing Regulation) in line with the 2030 climate target plan

24 Nov 2020

Decarbonisation price signals and a level playing field for all the available options are essential to tackle emissions and increase efficiency, both for consumers and emitters side. Products must internalise the total environmental cost through a set of consistent climate tools, so that consumers are incentivised to buy those with a lower carbon footprint, as they will be cheaper. But ‘polluter pays principle’ is not generally applied and fossil fuels have a competitive advantage against clean options. EU must ensure a level playing field between energy carriers, so suppliers include all the costs in their offers of electricity, gas, diesel… From the emitters side, they need the correct price signals to reduce emissions and undertake efficiency gain measures. CO2 price has only been transferred to the ETS sectors and total ETS emissions have fallen by 27% vs 2005, accounting for less than 40% of total emissions (vs 45% in 2005). However, the Effort Sharing Regulation (ESR), don’t foresee any CO2 price signal Non-ETS sectors. Thus, transport sector has increased its emissions since 2005 by +20%, and although the building sector has decreased them by -25% since 1990, they have increased by +4% since 2014 due to economic activity. Besides, as the electric vehicles are incorporated into the vehicle fleet, the imbalance among these and conventional vehicles will grow. The electric vehicle (cars, trains, buses …) will be paying for EU ETS’ CO2 price while gasoline / diesel / gas vehicles will not be paying for the environmental damage they cause. Thus, the principle of "level playing field" among energy carriers will not be fulfilled and will be accentuated. Likewise, the imbalance among energy carriers for heating in buildings will also rise as electrification increases. During next decade, EU ETS carbon price signal may not be enough to decarbonise these sectors to the level required by the new 2050 net-zero emission target. Other ambitious regulations (both at EU and national level) should be applied in a combined and consistent way to achieve the necessary emission reduction efficiently and on time. Iberdrola believes that UE must o Transfer the correct price signals (based on “polluter pays” principle) to transport and building sectors: decarbonisation and energy efficiency will be promoted, and a “level playing field” among all types of energy carriers will be set.  Either through including transport (road and shipping) and buildings in EU ETS - taking into account their specificities - or through a dedicated tax based on the carbon footprint o Keep current ESR sectoral scope in parallel to extending EU ETS, in order to keep the national emission reduction objectives and boost countries to introduce additional measures to decarbonise transport and building sectors o Increase 2030 ESR ambition level and Member states’ targets in accordance with the overall GHG ambition.
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Response to Updating the EU Emissions Trading System

24 Nov 2020

Decarbonisation price signals and a level playing field for all the available energy supply options are essential to tackle emissions and increase efficiency, both for consumers and emitters. The price of products must internalise their total environmental cost so those with a lower carbon footprint become more competitive. But polluter pays principle is not generally applied, giving fossil fuels a competitive advantage. A level playing field among energy carriers is a must for an efficient energy sector integration. From the emitters side, they need the correct price signals to reduce emissions (including by gaining efficiency). But only ETS sectors are exposed to an explicit carbon price, with the electricity sector delivering most of the emission reductions. Besides, as electrification becomes a real option for the transport and building sectors, the distortion caused by the discrimination between electricity and fossil fuel-based options in terms of their exposure to an explicit carbon price turns more harmful. Hence, while progressing in the much-needed sectoral abatement measures (e.g. standards), the transport and building sectors should also be subject to a comparable explicit carbon price. Finally, the Green Deal requires a higher CO2 price to promote renewables and phase-out carbon-intensive alternatives. However, the CO2 price is subject to a significant downside risk. The solution would be an EU-wide carbon price floor-cap together with a renewed MSR able to act in support, acting as a safety net for investors. In any case, the solution to a shock on the ETS caused by a MS’s market interventions other than support for RES should not be socialised: accelerated phase-out of thermal generation should be tackled by a binding cancellation of the corresponding emission rights. Iberdrola believes that UE must strengthen the EU ETS by: - Increasing the 43% emission reduction target in 2030 vs 2005 in line with the new 2030 target, and consequently adjust the Linear Reduction Factor - A carbon cap and floor price that causes switching to clean technologies should be established, with a predefined annual increase - Reviewing MSR parameters to adjust them to ETS actual situation and new target: predefined range (more stringent upper bound as emissions are reduced) and percentage rate (maintain the injection quota of24%). Furthermore, the MSR should be redesigned in order to act in support to that price floor. - While progressing in the much-needed sectoral abatement measures (e.g. stricter CO2 vehicles emission standards, Energy Taxation Directive and ESR national targets), widen the correct price signals (i.e. include in the ETS) to as many sectors as possible to transfer them a homogeneous explicit carbon price signals (polluter pays principle) to promote a level playing field among all the energy supply options available: o Maritime sector o Road transport o Buildings o International aviation: include all flights, departing and/or arriving to EU The effectiveness of a steady ETS extension or other carbon pricing tools must be assessed: synergies among EU and national policies & taxes, impacts on ETS and mitigate any policy overlap with the ETS. - Gradual phase out of free allowances allocation to aviation sector in EU ETS - Countries phasing out emitters from the ETS sectors should be responsible for mitigating the corresponding shocks on the ETS – i.e. obliged to cancel the corresponding CO2 allowances in order not to depress the CO2 Price - Ensure the effective protection for the sectors exposed to significant risk of carbon leakage while incentivising the uptake of low carbon technologies by updating emission benchmarks and allocation rules, ensuring a harmonised approach to indirect cost compensation: o A well-designed CBAM represents a very promising way forward and key to ensure a level-playing field among energy carriers. (e.g. see the case of hydrogen currently protected by carbon leakage measures)
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Response to Revision of the CO2 emission standards for cars and vans

24 Nov 2020

Electrification is the most effective, efficient and sustainable way to decarbonise the transport sector, achieve EU’s long-term climate objectives and reduce air pollution. The electric vehicle (EV) is the real, competitive and mature alternative to decarbonise road transport at least cost, contributing at the same time to ALL the energy and climate objectives: renewable, energy efficient (2-3 times more efficient than a conventional vehicle), and does not emit CO2 or other pollutants. Despite the benefits, EVs accounted only for 3% of vehicle sales in Europe in 2019. This is mainly due to: • The lack of a “level playing field” among the different energy carriers. • The cost of the vehicle. A cost parity is expected in 2025. • The lack of charging infrastructure. Mainly caused by the regulatory and administrative barriers that private initiative is facing when developing their plans. Consequently, while short term incentives and regulatory changes are of a vital importance to trigger a faster market shift, a long-term strategy is also necessary to foster electrification and the deployment of EVs and its infrastructure. In this context, the Green Deal offers a unique opportunity to set the proper regulatory framework: • Foster electrification: updating the Primary Energy Factor to reflect the real savings brought by renewables; removing taxes and levies from the electricity bill that have no relation with the electricity supply; and introducing a correct price signal based on the “polluter pays principle” (including the transport sector in the EU ETS and/or setting an environmental tax reform based on the carbon footprint). • Promote EVs and its infrastructure: reviewing the Clean Mobility Package (CO2 emissions standards for cars/vans, HDV and Clean Vehicle Directive for administrations) to introduce more ambitious regulation and fostering the deployment of charging infrastructure by removing barriers and setting minimum and mandatory basic charging infrastructure objectives. In this context, IBERDROLA calls for and ambitious amendment of the Regulation setting CO2 emission standards for cars and vans In order to promote the development of EVs, we believe that the following are the main points that should be considered as part of the revision of the CO2 emission standards for cars and vans: • Given the difficulty of reducing emissions of aviation and shipping, it is necessary to focus efforts on the decarbonisation of light duty vehicles. These must be required to reduce its emissions by -100% in 2050, which means that in 2030-2035 the last internal combustion vehicle must have been sold and all new cars and vans will need to be zero tailpipe emission. • Increase the emission reduction objective of new cars and vans to at least -60% in 2030 vs 2021. • The “zero and low emission vehicle” concept should be redefined as “zero-emission vehicle” in consistency with EU climate objectives and EU Taxonomy, referring just to those vehicles with no tailpipe emissions. • Set zero-emission vehicle sales quotas with bonuses and penalisations for manufactures (bonus/malus system), achieving 100% sales quota in 2030-2035. • Stricter emission limits for manufacturers in line with 100% zero-emission vehicle sales objective in 2030-2035. • A fuel crediting system should not be considered as part of this review, as it will work against the objective of this regulation. • Tighter pollution standards for vehicles. New vehicles from 2030 to have zero pollutant emissions. • Exemplary ambition for public administrations. Iberdrola will be happy to answer any question about its positions and extend the explanations addressed in this document.
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Meeting with Kadri Simson (Commissioner) and

10 Nov 2020 · Green Deal, Iberdrola strategic plan on clean energy investments including in renewable energy and hydrogen, economic recovery

Response to EU Action Plan Towards a Zero Pollution Ambition for air, water and soil

27 Oct 2020

Air pollution is the biggest environmental risk to health in the European Union According to the World Health Organization (WHO), air pollution is the biggest environmental risk to health in the EU. 96% of EU citizens living in urban areas were exposed to levels of air pollutants considered by the WHO as damaging to health. Air pollution tends to affect city dwellers more than inhabitants of rural areas because the density of people living in cities means that air pollutants are released on a larger scale (for example, from road transport and local heating systems) and because dispersion is more difficult in cities than in the countryside as pollutants are emitted closer to the ground. Consequently, each year in the EU air pollution causes about 400 000 premature deaths, and hundreds of billions of euro in health related external costs. Climate change and air pollution share the same origin, fossil fuel combustion; consequently, the solution is the same: the decarbonisation of the current energy model. EVs and eHPs are the most efficient, sustainable mature solutions to both decarbonise and combat air pollution in the heating and transport sectors. Taking into consideration that road transport and local heating systems are the main cause of environmental pollution, electrification of both sectors through electric vehicles (EVs) and electric heat pumps (eHP) will play a major role on a zero pollution future. EVs and eHPs are the most efficient, sustainable mature solutions to both decarbonise and combat air pollution in the heating and transport sectors. IBERDROLA welcomes EU’s Action Plan Towards a Zero Pollution Ambition for air, water and soil The Green Deal through the EU’s Action Plan “Towards a Zero Pollution Ambition for air, water and soil – building a Healthier Planet for Healthier People” offers a unique opportunity to set the basis to solve EU’s pollution problem. We believe that the following are the main points that should be considered as part of this action plan: • Review the 2008 Air Quality Directive to: o Establish stricter air pollution limits in line with the WHO guidelines: according to an analysis by the European Environment Agency, if the concentration limits for the most harmful pollutant (PM2.5) was the same as that recommended by the WHO, premature deaths caused by this pollutant would be reduced by 30% o Set zero emission zones from 2025 in cities/towns >50,000 habitants o Increase and adequately regulate the sampling points o Establish common guiding principles to define consistent Air Quality Plans in polluted areas of the MS to combat air pollution in a coordinated way Set a robust Governance system o Assure the completion of the limits set by the Directive, adopting legal actions and penalizing the MS that exceed them o Clearly inform citizens about air quality, promoting the air quality awareness • Strengthen heating and cooling regulation: o Establish emission and pollution standards (CO2, NOx, PM…) for all heating & cooling systems. Set a timeline to restrict inefficient and polluting equipment. From 2025 all new equipment must be zero pollutant and CO2 free • Strengthen road transport regulation o Greater exemplary ambition for public administrations. 100% of cars, vans and buses to be zero-emission from 2030, in line with technological availability o Tighter standards for vehicles. New vehicles from 2030 to have zero pollutant emissions and tests closer to real driving conditions • Review the Energy Tax Directive: o Tax reform based on the ‘polluter pays’ principle to enable the internalisation of the environmental cost associated with each energy product (generation and consumption) • Reduce carbon footprint of agriculture and animal production: o Develop Farm to Fork Strategy initiatives: deploying programs and updating regulation for more sustainable farming and livestock production
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Meeting with Kadri Simson (Commissioner) and

20 Oct 2020 · Discussion on the future adoption of the Offshore Renewable Energy Strategy. Presentation of the sector coordinated by Wind Europe.

Meeting with Frans Timmermans (Executive Vice-President) and Volkswagen Aktiengesellschaft and

1 Oct 2020 · Discussion on Green Recovery

Response to Review of Directive 2012/27/EU on energy efficiency

21 Sept 2020

The 2030 energy efficiency (EE) objective was set at 32.5% based on a GHG emissions reduction target of 80-95% by 2050. Consequently, in order to reach carbon neutrality by 2050, the 2030 EE objective should be increased accordingly. Iberdrola strongly supports the proposal to increase this value to 36%. Decarbonisation through direct electrification based on electric vehicles (EV) and electric heat pumps (eHP) would help to achieve the 2030 EE objective, as electrification has a double EE character:  - RES-E is 2-3 times more efficient than electricity produced from coal, nuclear or CCGT  - EVs and eHPs are 2 and 3 times more efficient respectively than other alternatives such as conventional vehicles and fuel cells, or gas boilers In consequence, and as stated in the recently published Energy System Integration (ESI) Strategy, the electrification of a large share of our consumption can cut primary energy demand by 1/3 thanks to the efficiency of electrical end-use technologies. But EVs and eHPs are not just efficient alternatives, they are also renewable and with no CO2 or other pollutant emissions. Consequently, direct electrification is a real and competitive alternative to decarbonise road transport and the heating and cooling sector at least cost, while at the same time contributes to ALL the energy and climate objectives. Despite its benefits, the penetration of eHPs in Europe is currently less than 1% for the building sector. This is because its CAPEX is very high due to the cost of the machines as well as the necessary reforms to install the new equipment, which make the replacement cost 3 times higher than a gas boiler. The same occurs with EVs, which account only for 3% of vehicle sales in Europe in 2019. This is mainly due to the cost of the vehicle (a cost parity is expected in 2025 according to the EC), but also due to the lack of public charging infrastructure. In this context, the Green Deal offers a unique opportunity to set a proper regulatory framework that boosts momentum on electrification. Iberdrola believes that the following aspect should be taken into consideration for the revision of the EED:  - The increase of wind and solar in the electricity mix will reduce primary energy consumption, improving energy independency and reducing emissions. The 2018 EED estimated a default Electricity Primary Energy Factor (PEF) of 2.1 for the next decade, but this value does not take the future increase of renewables in electricity into account. As concluded by the ESI Strategy, “Most renewables are 100% efficient and have a low PEF. The PEF should reflect the real savings brought about by renewable electricity and heat.” Consequently, Iberdrola believes that the default PEF value should be updated based on the actual and the upcoming energy mix, every 2 years and taking into account real and foreseen electricity production data, in order to correctly recognise the savings brought by renewable based electrification giving proper signals to the market. Additionally, the electricity in those MSs with a renewable electricity consumption > 60% during a period of 2 years should be automatically rewarded with the recognition of an improved PEF<1.  - The EED and RED should encourage the use of EVs and eHPs to achieve their objectives by introducing a multiplier of at least x5 that values the savings generated.  - Set incentives to promote switching from fossil and inefficient sources of energy to renewable and efficient alternatives.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

21 Sept 2020

Incept Impact Assessment: Revision of Directive 2018/2001 on the promotion of the use of Energy from renewable sources Renewables are the essential driver of decarbonisation. We have come a long way, with significant efforts to incorporate these energies in different sectors to achieve the EU’s 2020 objective of 20%. The latest figures show good progress (18% in 2018), mainly derived from the large contribution of the electricity sector, as it is the one which best integrates renewables. Renewables have also registered a significant gain of technology maturity and competitiveness, especially in relation to onshore wind and photovoltaic panels, which makes them not only the best solution to decarbonise but also the most economic one. Their exponential and global growth will lead to a further cost reduction of 30% in the next decade. In this context, the Renewables Directive will have to be updated in line with the objective of achieving carbon neutrality by 2050. The current RES objective is 32% in 2030, which was based on a GHG emissions reduction of 80-95% by 2050. To reach carbon neutrality, the RES objective should be increased accordingly in 2030 Iberdrola strongly supports the proposal to increase this value to 38,5%. However, as important as an ambitious objective and good governance rules, is the establishment of a good regulatory framework that removes barriers to renewable energy deployment (such as long and complex permitting processes) and enables the achievement of whatever the objective is. The electrification of the economy through renewables does not only contribute to the objective of GHG emissions reduction and air quality but contributes to ALL the objectives of energy and climate (renewables, efficiency and emissions). The Green Deal offers a unique opportunity to fine tune a proper regulatory framework that boosts momentum on electrification and enables the achievement of EU 2030 objectives. Electric vehicles (EVs) and electric heat pumps (HP) are realistic and mature technologies to electrify the economy that should be prioritised, as they still require regulatory support to remove current barriers. At the same time, the review of the Renewable Directive should always be aligned with the strategies that have been and are about to be published. This include the Energy System Integration and the H2 Strategy, the Renovation Wave, the Sustainable and Smart Mobility Strategy and the Offshore Strategy. In this context, Renewable Directive, should encourage the use of EVs and HPs to achieve their objectives i.e. by introducing a multiplier of at least x5 that values the savings generated. Finally, the revised Renewables Directive should maintain the technological neutrality, avoiding sub-objectives, keep progress on banning 1st generation biofuels, streamline administrative and environmental procedures of the new facilities to foster renewable energy while enhancing the certification system of renewable liquid and gaseous transport fuels of non-biological origin’ and recycled carbon fuels to comply with requirements set in REDII.
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Response to Revision of the EU Emission Trading System Directive concerning aviation

31 Jul 2020

The full internalisation of the environmental costs is required to give consumers a price signal to incentivise the purchase of products with the lower carbon footprint (cheaper) and reduce GHG emissions efficiently. To this end, it is also important that emitters receive correct price signals to reduce emissions and undertake effective measures to reduce emissions. However, carbon price has only been transferred to the ETS sectors (electricity, aviation and part of the industry), reducing its emissions by 27% vs 2005. The emissions reduction has been met thanks to the performance of the electricity sector (emissions -30% vs 1990), based on two factors: the integration of RES-E and the coal-to-gas switching triggered by the internalisation of the CO2 price. Unlike the electricity sector (not receiving any free allowance), the European domestic aviation is one of the ETS sectors receiving free allowances (along with industry). Free allowances have mitigated the incentive to invest in carbon reduction technologies and is one of the factors explaining 25% emission increase since its incorporation to the EU ETS in 2012. Besides that, international aviation is exempted from EU ETS till 2024, with the hope that Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA) stabilises its emissions at 2019 levels by requiring airlines to offset the growth of their emissions after 2020.However, offsetting is far from the level of ambition required to other sectors to achieve climate neutrality by 2050 as it means essentially “moving emissions elsewhere” and not suppressing them. Finally, aviation, the most carbon intensive mode of transport, is heavily subsidised(1) . Aviation receives direct subsidies for operation and infrastructure developments, and is exempt from the basic consumer tax, VAT, leading to a shortfall in EU member state budgets. In addition, almost everywhere in the world, aviation fuel for international aviation is exempt from taxes: MSs in EU could tax kerosene for domestic flights, but not one has done so. Together, all these subsidies are distorting price signal and hindering decarbonisation vs. less emitting alternatives. Fiscal tools are supporting conventional aviation demand vs. train or innovative more sustainable aircraft or fuels (consumers end up taking one-hour flights because they are cheaper than two-hour train trips). Iberdrola considers the CO2 price is the key tool for switching into cleaner technologies, so it supports the following general principles: • Gradual phase-- out of free allowances allocation to aviation sector in EU ETS • Include all flights, departing and/or arriving to EU Member States and all EFTA States (2), in the EU ETS, combined with its participation in CORSIA, supporting the unique system that regulates emissions from international aviation • Environmental Tax reform at European level, phasing out exemptions and subsidies which favour aviation over other transport options, and including taxes on aviation fossil fuels in accordance with the "polluter pays" principle. This should be considered in the revision of the Energy Taxation Directive. Such a measure would have a significant revenue generation potential which will be contributing also to further climate action, compensation of negative unintended consequences of fossil fuel subsidies as well as helping a revenue neutral fiscal reform. (1) Source: Transport & Environment (2) Iceland, Liechtenstein, Norway and Switzerland
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Response to Sustainable and Smart Mobility Strategy

27 Jul 2020

Electrification is the most effective, efficient and sustainable way to decarbonise the transport sector, achieve EU’s long term climate objectives and reduce air pollution. The electric vehicle (EV) is the real, competitive and mature alternative to decarbonise road transport, which allows the achievement of the decarbonisation of the transport sector at least cost and contributes to ALL the energy and climate objectives: renewable, energy efficiency (2-3 times more efficient than a conventional vehicle), and does not emit CO2 or other pollutants. Despite the benefits, EVs accounted only for 3% of vehicle sales in Europe in 2019. This is mainly due to the cost of the vehicle (a cost parity is expected in 2025), but also to the lack of public charging infrastructure (mainly due to regulatory barriers, administrative barriers, etc.). Consequently, while short term incentives and regulatory changes are of a vital importance to trigger a faster market shift, a long term strategy is also necessary for the deployment of EVs and its infrastructure. IBERDROLA calls for and ambitious Sustainable and Smart Mobility Strategy based on electrification The Green Deal through the Sustainable and Smart Mobility Strategy offers a unique opportunity to set a proper regulatory framework that boosts momentum on electrification of the transport sector and enables the achievement of EU objectives. We believe that the following are the main points that should be considered as part of this strategy in order to promote electrification: • Given the difficulty of reducing emissions of aviation and shipping, it is necessary to focus efforts on the decarbonisation of road transport. Road transport must be required to reduce its emissions by -100% in 2050, which means that in 2030-2035 the last internal combustion vehicle must have been sold and all new cars and vans will need to be zero-emission. • Review the “alternative fuel” definition in consistency with EU long term climate objectives. The updated definition should only take into consideration zero tailpipe emission options from 2030 onwards. • Zero-emission vehicle sales quotas with bonuses and penalisations for manufactures (bonus malus), achieving 100% sales quota in 2030-2035. • Stricter emission limits for manufacturers in line with 100% zero-emission vehicle sales objective in 2030-2035. • Establish mechanisms to detect and remove main barriers (regulatory, administrative or other) for the deployment of charging infrastructure. • Greater exemplary ambition for public administrations. 100% of cars, vans and buses to be zero-emission from 2030, in line with technological availability. • Set a minimum and mandatory basic charging infrastructure objective for 2025 and 2030 based on coverage and demand criteria and with a concrete and realistic implementation plan. • 90% of fuel stations along the roads of the TEN-T Core & Comprehensive Network to be equipped with public accessible high-power fast charging points for electric vehicles by end 2027. • Establish a plan for the development of CPs in existing buildings, with the objective that by 2030 50% of existing buildings with more than 10 parking spaces have the necessary basic charging infrastructure. • Tighter standards for vehicles. New vehicles from 2030 to have zero pollutant emissions. • The default Primary Energy Factor value should be updated based on the actual and the upcoming energy mix, taking into account real and foreseen electricity production data. • Tax reform based on the ‘polluter pays’ principle to enable the internalisation of the environmental cost associated with each energy product (generation and consumption) • Progressively including road transport and shipping in the CO2 market from 2025 onwards. Reduction of free allowances for aviation to incentive its decarbonisation. Iberdrola will be happy to answer any question about its positions and extend the explanations addressed in this document.
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Response to Establishment of a smart readiness indicator for buildings

16 Jul 2020

Iberdrola is happy to provide feedback to this consultation and give, once again its support to the concept of “smart readiness indicator” as a tool to facilitate the adoption of smart and efficient solutions and promote the electrification of buildings as a path to a cost-effective decarbonisation. Two lessons learned: • The starting point for a credible indicator is the availability of smart meters. The rollout of such devices should be a precondition for any energy driver, following the benchmark of resolution and reliability of the facilities deployed among the electricity consumers. • At the same time, electric solutions for heat (electric heat pumps), vehicle recharging and self-producer solar power are more efficiently adapted to smart solutions (and already sufficiently mature) than any other technology. We understand that the optional character of the smart readiness indicator of the Implementing and Delegated Regulations in consultation is directly transposed from the text of the DIRECTIVE (EU) 2018/844 on the energy performance of buildings. However, from a forward looking approach and having in mind the expected ambitions of the announced renovation wave, this optionality should be put into question, as a mean to promote efficiency in buildings and “ensure a degree of consistency… across the EU” (see recital 4 Delegated Regulation), with a model of robust efficiency certification. Detailed Comments Delegated Regulation supplementing Directive (EU) 2010/31/EU of the European Parliament and of the Council by establishing an optional common European Union scheme for rating the smart readiness of buildings Annex I “Calculation of smart readiness indicator scores”: Calculation processes are complex and initially unclear even for experts. Annexed examples and more extensive complementary documentation should be necessary to provide informed opinion. Annex II “Smart readiness impact criteria”: We suggest a “preliminary impact criteria” based on the availability/reliability of the energy consumption measures (i.e. the capacity to meter electricity, hot water/air, gas, etc.) as a first step. Information on occupation and on equipment are also important, but for the matter of efficiency, quality data on energy is first step as said above. Annex IV “Technical Domains”: We do not fully share the (a) – (i) list of elements of very different nature. We suggest rather to simplify into three very generic concept families: energy uses (heating, cooling, etc.), energy infrastructures (building envelope, equipment, etc.) and energy vectors (PV, self-generation, etc.).
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Meeting with Kadri Simson (Commissioner) and

10 Jul 2020 · Exchange of views on energy system integration and hydrogen strategies.

Response to Modernising the EU’s batteries legislation

8 Jul 2020

Iberdrola is glad to provide feedback to this consultation sharing with the Commission and views on the critical importance of setting a forward looking framework on sustainable batteries based on their exponential growth as a driver for climate neutrality (notably in electrification of transport as shown is chart attached). This is supported by our projections addressed in 2019 “Public consultation on sustainability requirements for batteries”, suggesting that “The second use of batteries always has a positive environmental impact, but it is too early to confirm if this second application will have a positive business case. In any case, the amount of batteries removed at the end of their first life in EVs might be greater than the demand for stationary energy storage. Thus, the main focus should be put on recycling”. Actually, all batteries will ultimately end their life being recycled. Few remarks to the current consultation document: • Sustainability “trilemma”: the document highlights the conditions of Durability, Reusability and recyclability to define sustainability. However, we find not a simple issue to conclude on each of the components of such trilemma independently of the destination of the battery or the development of the technology. It is difficult to set sustainability trade-off between, for example “cheap batteries with relatively few cycles”, or “very long duration batteries but difficult to recycle”, or “find a business case for long duration and easy recyclable batteries”. In fact, for each application it seems that we could find different duration and recyclability properties. • Producer responsibility: since batteries are considered to be hazardous waste, their collection, shipping, treatment, disposal and decommission once they reach the end of their lifecycle should be subject to strict traceability requirements. However as for any kind of consumer or technology product, the responsibility of manufacturer should be adequately framed and closed uncertainties of unintended effect on production, technology advances and prospect prices. • Extended Producer Responsibility (EPR): Car OEMs are required to assist in collecting and recycling EV batteries at the end of vehicle life. But the battery can have a second life, and the workshops responsible for repurposing batteries are likely to be a different entity than OEMs. Because of that, future legislation must ensure a fair transfer of the EPR upon the purchase of the used battery by the workshops from the OEMs so that workshops would be responsible for recycling the repurposed batteries they would place on the market. • Battery tracking and identification must be encouraged: A European battery registry and standardized labelling could help reduce recycling costs, resolve the problem of orphan batteries, speed-up the repurposing process and reduce testing times since the state of health of the battery and its history would be digitally available. • Recycling targets of EV batteries should be defined: Taking into account the high number of EVs that, predictably, will be on the European roads in the coming years, recycling objectives for this batteries should be defined, and recovery targets should be set in line with the best available technology (BAT)
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Response to New competition tool

29 Jun 2020

Please find attached Iberdrola's observations on the "New Competition Tool".
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Meeting with Riccardo Maggi (Cabinet of Executive Vice-President Frans Timmermans)

16 Jun 2020 · Decarbonisation policies and economic recovery plans

Response to A EU hydrogen strategy

5 Jun 2020

Although green H2 is called to be a relevant energy carrier in the decarbonisation, it is still immature, with low energy efficiency and presents limitations in terms of production and transport. Its current cost is more than double the cost of RES-E and its future still depends on solving the technological uncertainties of H2. Energy Sector Integration is intended to be the EU’s tool to ensure decarbonisation is achieved at the lowest possible cost, which should optimise the use of RES-E as the main energy carrier for decarbonisation along with other carbon neutral options in those niche sectors where electrification is not yet possible. The EU’s H2 Strategy should take into consideration all these circumstances and establish an adequate framework for its development, avoiding a massive implementation too early and making sure that it is consistent with the decarbonisation strategy. Iberdrola believes that this strategy should: a) Guarantee that H2 is green, from 100% renewable electricity and has no carbon footprint. Considering that the EU must be carbon neutral by 2050, it is not consistent to use grey or blue H2 as they originate from fossil fuels and emit CO2. These alternatives should not even be used as a transitory measure to kick off a future green H2 market. A robust certification system will be required to ensure this (the current GO system is not appropriate due to its lack of geographical and locational correlation) and the additionality principle of the RED2 must be respected. b) Preserve the technology neutrality principle and guarantee a level playing field between the decarbonised energy carriers, in order to promote competition and efficient end uses at the lowest possible cost. • Set energy and climate objectives (emissions reduction, renewables and energy efficiency) to meet EU’s long term decarbonisation objectives. Sub-objectives for each energy carrier should not be established, as this would encourage their development regardless of their technological maturity • The carbon leakage industry must be protected and, at the same time, it must be ensured that it contributes to decarbonisation. The industry that produces grey H2 currently receives free carbon allowances, leaving green H2 at a competitive disadvantage. In this context, a Carbon Border Tax or Adjustment at EU level is required • All investments must be supported by a CBA that internalises all costs. i.e. for a blue H2 plant, account should be taken not only the cost of H2 production, but also the cost of transporting and storing CO2, the investment needed to adapt the current gas grid and the stranded costs involved as these assets cannot be used beyond 2050) c) Promote efficient decarbonisation using green H2 in those final uses where it has most value: • Promote the technological development of green H2 in demonstration projects to improve its maturity and competitiveness with R&D grants from European funds • Ensure that possible support schemes for RES-E used to produce green H2 are included in the general renewable framework. A specific scheme for RES-E dedicated to green H2 production would be discriminatory • In the short term green H2 should be used to decarbonise industries that currently use grey H2 as feedstock (ammonia, refining industry) • In a second phase (medium/long term), with a substantial cost reduction, green H2 could be used as an energy carrier to decarbonise niche sectors where electrification is not yet an alternative. In this sense, we consider that the viability of blending as an efficient alternative for decarbonisation should be analysed in detail. Green H2 is a very scarce and valuable product. Injecting green H2 into the current gas grid dilutes its decarbonisation power. For example, with 20% blending in Spain we could avoid 6 MtCO2, but with the same green H2 needed for that blending percentage, we could decarbonise all the residential heating and domestic hot water in Spain (113 TWh/y) and avoid 28 MtCO2.
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Response to Union renewable Financing mechanism

3 Jun 2020

Gap filling function: (1) The award criterion should not be the price, but maximising the statistical transfers to contributing MS: a) A significant share of the RES integration cost / impact is not borne by RES investors, but socialised (e.g. deep vs. shallow connection charges; impact on adequacy and flexibility; etc.). As such share is not homogeneous across the EU, the price bids submitted by the RES investors are not comparable across the host MS. A similar issue occurs with taxes, levies or grid charges on generators. Therefore, an award process based exclusively on price would be inefficient. b) A host MS can make up for e.g. RES integration cost / impact not allocated to RES investors exclusively through adjusting the sharing of statistical transfers. Hence, the statistical transfers for the contributing MS is a key award criterion. In fact, the gap filling function’s priority should be to provide the contributing MS with a suitable opportunity to amend their RES deficit. Hence, the award criterion should rather be maximising the statistical transfers to contributing MS. (2) In addition, maximising the statistical transfers to contributing MS should not lead to an unbalanced distribution of RES along the EU. A RES-based system has a basic decentralised nature – i.e. collective effort of all MS. Thus, the maximum amount of RES to be allocated to each host MS should be limited by its interconnections and RES penetration vis-à-vis that of its neighbours. Hence, the objective of maximising the statistical transfers to contributing MS should be subject to a balanced distribution of RES production along the EU. (3) Host MS must be allowed to define their minimum statistical transfer threshold for each call (reserve price), which must be respected in any case in the award process. (4) When defining its NECP, a MS’ ambition is not just to achieve a certain minimum national RES penetration, but also e.g. modernise its energy sector. If EU funds and private contributions are used to support the deployment of mature RES in that (host) MS, then its own efforts will be disincentivised even when no statistical transfer associated to such funds were received. Therefore, RES projects associated to the gap filling function (i.e. all but demonstration projects which are associated to the enabling function) should be financed exclusively by contributing MS. (5) The UREFM should not be used by MS to make up for avoidable delays in their RES deployment (e.g. due to lingering difficult energy transition decisions / actions). In order to deal with this, a disincentive should be introduced. If a MS misses its reference point beyond a certain threshold (e.g. 5%), then a proportion of the statistical transfers that corresponds to its contribution could turn into an addition to the EU target of at least 32%. Such a proportion could increase with the MS’ RES deficit vis-à-vis the reference point. Enabling function: As proposed in recital (6), this function should be limited to letter (a) and (d) of Art 3.5 Directive 2018/2001 ( reduce the cost of capital; enhance regional cooperation). However, little detail is given on how they would be implemented. Regarding (a), according to recital (12) and article 23, EU instruments might be used to reduce the cost of capital of any RES project under the UREFM. However, the UREFM should not be used by MS to make up for avoidable delays in national RES deployment (e.g. due to lingering difficult energy transition decisions / actions) – see (5). If RES projects in the sphere of the gap filling function are favoured with a lower cost of capital, then there would be an additional incentive for such a behaviour. Alternatives to tackle this issue would include: • RES projects in the sphere of the gap filling function financed exclusively with funds from contributing MS – see (4). • Allow EU instruments for all RES projects under UREFM, but reinforce the disincentive scheme for the behaviour described – see 5
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Response to Commission Communication – "Renovation wave" initiative for the building sector

2 Jun 2020

Please find Iberdrola's comments to the "Commission Communication – "Renovation wave" initiative for the building sector" Sincerely Eva Chamizo
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Response to Development of Euro 7 emission standards for cars, vans, lorries and buses

2 Jun 2020

Please find attached Iberdrola's feedback to "Development of Euro 7 emission standards for cars, vans, lorries and buses" Sincerely Eva Chamizo
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Response to Strategy for smart sector integration

2 Jun 2020

Please find Iberdrola's comments to the "Strategy for smart sector integration" Sincerely, Eva Chamizo
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Response to Evaluation of the Commission Notice on market definition in EU competition law

14 May 2020

Iberdrola, a Spain-based energy group and the leading producer of wind power in the world, welcomes the European Commission’s initiative to assess whether the Relevant Market Notice from 1997 is still fit for purpose more than twenty years after its adoption. In its Roadmap, the Commission mentions the need to consider how the economy as evolved since the 1990s, in particular with respect to digital markets and globalisation without forgetting the importance to keep a level playing field across the EU and the integration of the internal market. The enormous transformative potential of digitalisation and the smart use of data is well-known. To help unlocking this potential, Iberdrola believes that EU competition policy must adopt a dynamic, forward-looking approach. The traditional approach to defining markets has often relied on binary demarcations between different activities that fails to capture the nuances and complexities of real-life markets. This is indeed an area where an updated Relevant Market Notice will be able to make a valuable contribution consolidating a level playing field in the EU markets. However, digitalisation is far from being the only trend that illustrates the fluid nature of markets and their boundaries. Climate challenge and innovation in renewables, energy-saving and battery technology, and the growth of e-mobility are key drivers of change in the energy sector. The electrification of demand in areas such as transport and heating is causing energy markets to converge to an extent never seen before. Nevertheless, competition policy, regulation and taxation in Europe are still largely trapped in a compartmentalised mindset where each source of energy is seen to exist in a separate universe, where the reality is that they are at present competing for the same market. The evaluation of the Relevant Market Notice offers the Commission an opportunity to revisit this approach. We also welcome that the Commission will look at the geographic dimension of markets. A narrow Europe-centric approach is ill-suited to a world where it is pivotal for European companies to be able to compete at scale with US and Chinese rivals. However, this is not the only area that deserves attention. Iberdrola is surprised by the fact that competition authorities in Europe still havesuch a strong tendency to define national markets. In the energy sector, successful cross-border market coupling is a fact in many parts of Europe, but this is not reflected in day-to-day competition law enforcement. Iberdrola looks forward to taking part in the Commission’s consultation process and to discuss these important issues.
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Response to References to ESG factors enabling market participants to make well-informed choices

6 May 2020

The Commission proposal enacts the voluntary attribute of the weighted average ESG /environmental/ social rating of the benchmark. We very welcome the inclusion of the ESG ratios for benchmarks to be voluntary. If there should be a change in the requirement around the rating of benchmarks, its implementation shall always be voluntary. The Commission proposal enacts the following definitions relative to the ESG factors: • Environmental: “Exposure of the benchmark portfolio to climate-related physical risks, measuring the effects of extreme weather events on companies’ operations and production or on the different stages of the supply chain (based on issuer exposure).” o Iberdrola considers that the lack of standardized methodologies to implement physical risk analysis make this disclosure requirement expensive and useless. • Social: “Number of benchmark constituents subject to social violations (absolute number and relative divided by all index constituents), as referred to in international treaties and conventions, United Nations principles and, where applicable, national law”. o This disclosure requirement is not well defined and, as a result, it would involve difficulties in its application:  A social violation should be defined only from a legal approach. The presumption of innocence must be respected. Consequently, the definition should include a reference to a competent court final ruling. The for words are relevant: competent, court, final, ruling.  In the absence of a legal definition for “social violation”, the lack of legal certainty should be sufficient for avoiding this type of disclosures, because it can influence the access to capital markets for potentially unfair reasons.  The difficulties appear when the “social violation” is in respect to voluntary standards that have no competent bodies to rule compliance. Then, the risk for issuers is to suffer judgments from un-official agencies, bodies or even consultants that without proper methodologies and legitimacy put in question companies’ performance.
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Response to Minimum standards for benchmarks labelled as EU Climate Transition and EU Paris-aligned Benchmarks

6 May 2020

Article 1. Definitions We consider that the ratio ‘enterprise value including cash’ or ‘EVIC’ is extremely dynamic and linked to the market volatility. It may vary significantly from one year to another, independently on company development and results (or environmental performance). We suggest a moving average for this index for the past three years, or at least two years, in order to have a more stable reference. Article 6. Companies setting and publishing GHG emission reduction targets The article states that the administrators of the CTB and of the PAB “may increase in those benchmarks the weight of companies that set and publish GHG emission reduction targets”, where the conditions (a) and (b) following are fulfilled. It is unclear whether the expression “may increase” indicates that: • Administrators should in a certain way focus higher weighting in companies complying (a) and (b); or • Companies that do not fulfil (a) and (b) cannot increase their weight in the benchmarks. That would be significantly more restrictive. On the road to climate neutrality it is important to establish an ambitious reduction path for future emissions (IPCC-scenario) but also to acknowledge the progress made by first movers on reducing their GHG emissions intensity. In this sense: • The annual reduction of 7% should be primarily placed on the portfolio not on the individual constituents of the benchmark; and • The reduction of “at least 7% per annum for at least three consecutive years” set in (b), should also comprise years previous to the entry into force of the Delegated Regulation. Article 11 Exclusions for Paris-aligned Benchmarks (c) companies that benchmark administrators find in violation of the UNGC principles or the OECD Guidelines This exclusion criterion is not well defined and, as a result, it would involve difficulties in its application: • A violation should be defined from a legal approach. The presumption of innocence must be respected. Consequently, the definition should include a reference to a competent court final ruling. The four words are relevant: competent, court, final, ruling. • In the absence of a legal definition for “violation”, the lack of legal certainty should be sufficient for avoiding this type of exclusions, because it can influence the access to capital markets for potentially unfair reasons. • The difficulties appear when the “violation” is in respect to voluntary standards that have no competent bodies to rule compliance. Then, the risk for issuers is to suffer judgments from un-official agencies, bodies or even consultants that without proper methodologies and legitimacy put in question companies’ performance. (g) companies that derive 50 % or more of their revenues from electricity generation with a GHG intensity of more than 100 g CO2 e/kWh It is unclear whether the exclusion is to be applied over: • Companies obtaining 50% or more of their whole revenues from electricity generation with GHG intensity above 100 g CO2 e/kWh; or • Companies consolidating an electricity generation branch with revenues obtained with facilities emitting more than 100 g CO2 e/kWh. That would be significantly more restrictive.
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Response to Revision of Alternative Fuels Infrastructure Directive

4 May 2020

Review of the “alternative fuel” definition Given the difficulty of reducing emissions of aviation and shipping, it is necessary to focus efforts on the decarbonisation of road transport to achieve carbon neutral economy by 2050. Road transport must reduce its emissions by -100% in 2050, which means that in 2030-2035 the last internal combustion vehicle must have been sold and all new cars and vans will need to be zero-emission. AFID does not support the full decarbonisation of road transport, as most of the alternative fuels that are allowed in AFID are emitting too much CO2. It defines electricity as an alternative fuel, but also hydrogen (no matter if its origin), biofuels (even palm oil), natural gas or liquefied petroleum gas. We believe that the new “alternative fuel” definition should only take into consideration zero tailpipe emission alternatives from 2030 onwards. Minimum and mandatory objectives AFID requires MSs to set up NPF that include minimum public infrastructure coverage by 2022, 2025 and 2030. As concluded by the CE in February 2019, there are great differences between the plans at national level and these do not adequately reflect the estimated development of EV market as do not take into account future technology development and announcements made by car manufacturers. In order to improve current infrastructure development, we believe that the revised AFID should set a minimum and mandatory basic charging infrastructure objective for 2025 and 2030 based on coverage and demand criteria and with a concrete and realistic implementation plan. Priority should be given to foster the deployment of a critical-mass network of recharging points and the removal of all the barriers that still persist for a normal behaviour of a competitive market. For that end, the installation of recharging points by private initiative should be fostered. In the absence of private interest, MSs will have flexibility to allow DSOs to participate in the deployment of the recharging infrastructure for EVs. Applying the previous to Spain (5M EVs by 2030 according to the NECP), we estimate: - Urban deployment: 1CP of at least 50 kW by km2. 1CP of at least 50kW by 30,000 habitants. 15km between CPs. - Interurban deployment: 1 charging station of 3 CPs of 150kW every 60km in high capacity motorways. 1CP of at least 50kW every 200km in conventional roads. Finally, AFID should also set the framework for the development of high-power fast charging points along roads of the TEN-T Core & Comprehensive Network. In this context, we believe that 90% of fuel stations along the roads of the TEN-T Network should be equipped with public accessible high-power fast charging points for electric vehicles by end 2027. Interoperable infrastructure AFID should ensure interoperable EV charging infrastructure and encourage demand-driven mechanisms in order to add greater value for customers and improve their experience. To achieve this, the revised AFID must facilitate aspects related to billing, price transparency and accessibility harnessed through principles for shared data and open standards. The electricity grid is ready One of the main concerns about electrification is its impact on the electricity system. A greater EV and heat pump (HP) penetration will lead to increased demand in electricity growth however, this should not be a problem for many systems, especially in the short and medium terms, as their transmission network is robust and meshed. Some reinforcements will be needed in the distribution level, but this network is under continuous update to meet new demand requirements. An internal study focused on the Spanish electricity network and based on the electrification figures of its NECP (4M HPs & 5M EVs) shows that the Spanish distribution network is ready. The reinforcements needed in designated areas could be part of the usual investment plans. The DSOs have already successfully faced similar challenges in the past.
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Response to Climate Law

1 May 2020

• Iberdrola welcomes the Climate law proposed by the European Commission (EC) since it sets, in general, robust goals and guidelines to align EU and member state climate policies with both 2050 climate neutrality goal and Paris Agreement. • It is especially remarkable that the EU climate law gives the 2050 climate neutrality goal a legally binding character, which will contribute to discipline Member States when setting climate targets and policy frameworks. • It integrates an important part of the governance elements of the Paris Agreement within the European policy cycles and dynamics. Both the guidelines for policy alignment with the 2050 target and the ambition review process (five-year review cycle and 2023 as a key milestone to start the stocktaking process) are key examples on this regard. • However, despite the above-mentioned ambitious approach tackled by the EC in the Climate Law, setting the impact assessment for a new 2030 target of 50 to 55 % emission reductions by September 2020 makes it very difficult for the EU lead the global national climate plans (NDC, Nationally Determined Contributions) revision process in 2020. A political agreement on an upward revised 2030 EU emission reduction target well ahead the end of 2020 will be key both to showcase global leadership on climate action and to engage other jurisdictions in the needed “ambition loops” within this review process that will take place under Paris Agreement framework. • Considering that decarbonization runs at different speed amongst Member states, setting intermediates binding targets – aligned with climate neutrality goal by 2050- would have been a good approach to help balancing out discrepancies. On this regard, it will also be critical a robust Governance Regulation to monitor the development and fulfilment of the National Energy and Climate Plans (NECPs), to foster the achievement of European energy and climate objectives. The EC must monitor and ensure that countries are ambitious and realistic enough in their NECPs, specifying how they will achieve the goals set out (including details on financing). If MSs deviate from their announced trajectories, the EC should use all the tools at its disposal to correct the deviation. If more ambitious targets are set, the Governance Regulation should evolve accordingly, introducing binding rules to ensure the achievement of objectives and a strong legal basis in case infraction procedures are required when MSs do not achieve them. • Additionally, it is important to reiterate, in the context of the climate law, the need of robust guidelines on: o Clear and stable energy sector under a “level playing field” among all energy carriers and cross-cutting policies aimed at providing predictability, well-functioning markets, and fostering long-term investments, in the current context of climate emergency. o An environmental tax reform based on the “polluter pays” principle as a crucial tool to ensure effective and efficient decarbonisation, thus sending out correct signals to clean consumption, investment and operation (CO2 and other external factors). o Industrial sector roadmaps: taking into account opportunities and challenges, ensuring that all sectors play their part and preserving their international competitiveness. o Fair transition: the process will involve all economic sectors, particularly energy, thus a fair and orderly transition must be designed in collaboration with all stakeholders to ensure that the affected sectors are given a reasonable period in which to adapt. o R&D&i policies targeting the development of cutting-edge, valuable technology for the new future. o Coordinated Policy instruments to promote the development of practices, products, processes and technologies fully aligned with climate goals, both on mitigation and adaptation.
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Response to Report on the application of the General Data Protection Regulation

29 Apr 2020

IBERDROLA welcomes the opportunity to give feedback to the European Commission’s Report on the application of the General Data Protection Regulation. As regards, the cooperation mechanism between national data protection authorities, we consider it is very important to reinforce the cooperation mechanism between national data protection authorities in order to: - Produce more common GDPR guidelines and supporting material, agreed by all DP authorities, minimizing the number of local guides, which in some cases might be seen as contradictory. As a multinational company with operations in several EU countries, we have deployed one GDPR compliance model, with the objective to have the same approach deployed across the different countries where we operate. It is difficult to make this compatible with so many local guides issued by the local DPAs. - This cooperation mechanism needs to operate in an efficient and timely way. The evolution of technology is very fast, and the use of the technology is posing many challenging questions related to data protection that needs a common and timely answer. IBERDROLA will be happy to answer any question about its positions and extend the explanations addressed in this document.
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Response to 2030 Climate Target Plan

15 Apr 2020

IBERDROLA is a company operating in the field of electricity and renewable energy and is the first integrated utility in Europe by market capitalization. Iberdrola is playing its part in tackling climate change as we are the world’s leading renewable generation company with almost 70% of our global installed capacity in renewabels (almost 32,000 MW). Since 2000 we have reduced by 74% our CO2 emissions per MWh (24% over the last 5 years). IBERDROLA welcomes the opportunity to give feedback to the European Commission’s Inception Impact Assessments. Iberdrola supports the implementation of an impact assessment for a 2030 Climate Target Plan consistent with the climate neutrality ambitions for 2050. Given the technological availability and maturity and the uncontested cost-effectiveness, electrification based on renewables is the most efficient solution to tackle climate change and air pollution in the years to come and also helps achieving the other objectives of the EU policy (energy efficiency and GHG emissisons). Other solutions based on decarbonised energy carriers, such as hydrogen produced through electrolysis using renewable energy, do not appear to be a competitive solution for a massive deployment at 2030 horizon. For 2030 horizon two main non-regret paths seem the best suited: 1) decarbonisation of the electricity sector through renewables 2) electrification of end uses (through electric vehicles and heat pumps). This approach as a starting point, leads to the need for the 2030 Impact Assessment to consider the following parameters in order to reach the welcomed more ambitious 2030 targets in the most economically efficient and effective manner: 1. The latest National Energy and Climate Plans (NECPs) should be the baseline of the analysis 2. Incorporate update state-of-the-art costs of different technologies (renewables for electricity generation, electric vehicles) and its foreseeable evolution to 2030, including a sensitivity analysis for a quicker technology evolution based on more ambitious R+D policies. 3. Different penetration degrees of the following parameters • Renewables in the EU’s electricity sector • Electrification of final demand • Electric Vehicles in road transport • Electric heat pumps in buildings • Reducing free allowances to aviation sector, and 4. A Carbon Border Adjustment to ETS industry designed to incentivise emission reductions and efficiency gains while protecting their international competitiveness and avoiding emission leakage. 5. Progressively including road transport, shipping, buildings and industry in the CO2 market 6. Reduction of free allowances for aviation to incentive its decarbonisation 7. A Carbon Price Floor as a reserve price in the EU ETS auctions to dampen the effects of high variability of prices, particularly downwards, give visibility to renewables investors and promote the shift to cleaner technologies 8. Transforming energy taxation into a climate tool. This conveys a tax reform at European and national level, based on the ‘polluter pays’ principle to enable the internalisation of the environmental cost associated with each energy carrier (generation and consumption). Removing charges unrelated to supply costs from the electricity bills is requested to facilitate electrification of the economy and to ensure a level playing field between energy vectors. 9. A faster energy transition based on the alignment of the stimulus arising from the current health crisis with the Green Deal policies. This would lead to faster and more intense investment environment in industries and sectors that contribute to a more resilient and decarbonized economy. Iberdrola will be happy to answer any question about its positions and extend the explanations addressed in this document.
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Meeting with Frans Timmermans (Executive Vice-President) and Eurelectric aisbl and

15 Apr 2020 · Risk-prepardness in electricity sector, impact of crisis on clean energy investments, priorities of electricity sector for the upcoming energy initiatives under the Green Deal.

Meeting with Kadri Simson (Commissioner) and

15 Apr 2020 · Risk-preparedness in electricity sector, impact of crisis on clean energy investments, priorities of electricity sector for the upcoming energy initiatives under the Green Deal

Response to Carbon Border Adjustment Mechanism

31 Mar 2020

Iberdrola welcomes the EU initiative to assess the proposal of a Carbon Border Adjustment Mechanism (CBA) to enhance EU climate targets, reduce the risk of carbon leakage and avoid distortions on international trade ensuring that the price of imports reflect accurately their carbon content, preserving World Trade Organization-WTO rules and other international obligations of the EU. The introduction of a CBA in the UE under the compliance of WTO rules has to deal with five practical challenges: • Ensure equal treatment for internal and external products coexistent with the ETS and the EU energy taxation. This may convey the discussion on certain critical issues such as a) the integration of importers into the ETS, b) the existence of carbon taxes for final consumers, and inevitably c) the compatibility with the free allowance to industries in risk of carbon leakage. • Introduce climate change into international trade rules: Climate change is a global environmental risk, but climate protection or climate change mitigation are not so far explicitly quoted. The Paris Agreement subscribed by 195 countries opens the time to considerate climate issues into the international trade rules, either as the basis for a standard or technical rule or as an exception. The OMS addressed in COP24 climate change as a risk for human health. • The imposition of a CBA based on the carbon content of an import. The current interpretation of trading rules understands that 2 products are equivalent as far as they are perfect substitutes and respond to the same consumer demand. From this perspective, a CBA based on actual carbon content would require agreement at WTO level. However, the introduction of WTO standards and/or technical rules relative to carbon content may facilitate the differentiation of the products and accordingly their treatment vis-à-vis border taxes. Standards on carbon emission best practices and climate friendly products could be explored to support CBA. • The treatment of different countries with different commitments in climate action. The WTO rules impose equal treatment for all the countries which may be controversial when dealing with States with radical different positions relative to environmental targets and tools. Hence the elaboration of transparent and validated technical standards may provide a tool to implement CBA. • The destination of the funds raised through the CBA. The WTO rules exclude explicitly the use of export subsidies. However, nothing excludes to allocate part/all the funds towards general budget needs and more specifically, towards decarbonistation and sustainability targets. Earmarking a relevant part of the funds to transfer to developing countries for decarbonisation purposes in the context of the Paris Agreement is not only compliant with WTO rules but would help offsetting the controversies around the CBA. Full internalisation of industry’s GHG emission cost is key to ensure that such cost is passed through the value chain setting up strong incentives from the producers to the consumers. Tackling the carbon leakage issue through free allocation of CO2 allowances in the most exposed industries has been effective in terms of protecting the sectors in risk of transferring emissions from unfair international competition through relocation, but ineffective in terms of preserving the incentives to decarbonise because is neither of universal application for other sectors under unfair international competition (eg electricity sector) nor avoids effectively carbon emissions. The CBA represents a new approach which could either fully replace the existing carbon leakage measures or complement them while global robust CO2 mechanisms develop. Besides, indirect CO2 costs (like those internalised in electricity costs) could also be tackled through the CBA. Additionally, this approach should be framed in within an intense climate diplomacy activity – leaded by the EU – and aligned with UNFCCC climate negotiations.
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Response to Revision of the Energy Tax Directive

31 Mar 2020

Iberdrola shares with the Commission the views that energy taxation should be a tool for climate policy and preserving the internal EU market requires harmonised energy tax framework across the MSs as one of the keystones of the Green Deal to achieve climate neutrality in the EU by 2050. Decarbonisation is a must for the whole society involving all economic sectors. Taxation must become a relevant tool to achieve climate neutrality by 2050 and should be one of the main enablers to meet the targets. At present, energy taxes in Europe are not designed with this approach, as neither the current taxation system incentivises the replacement to most environmentally friendly energy sources facilitated by technology evolution, nor it provides a significant price signal on carbon content to end-users. In this sense the review of the Directive must consider a thorough review of current fiscal and “parafiscal” schemes (policy charges) burdening unevenly electricity consumers vs. other energy sectors. These charges that also act as indirect subsidies to emitting sources. Disregarding “parafiscal” charges distorts comparisons across energy products and countries. Reverting current tax schemes not aligned with climate targets becomes even more critical as to not distort competitive advantages between energies. Implementing the polluter pays principle entails that all energy sectors (electricity, coal, gas, and oil derivatives) must be subject to taxes according their carbon content and other air pollution emissions. This will ensure that taxation borne by the energy products and services is proportional to their environmental impact: the greater the impact, the higher the tax. In this sense, the EU framework should set minimum taxes on each energy product according their carbon content and MSs should not be entitled to modify the relative charges of the tax levels. The Energy Taxation Directive should enforce a level playing field for all energies and avoid unintended effects that penalise decarbonisation. Hence, MSs should neither be entitled to exempt the charges contemplated in the EU framework. Current framework essentially based on minimum tax levels is no longer fit for EU climate ambitions because MSs, using their power to modify taxes and implement new levies and charges, tend to disturb the price signal and undermine the correct functioning of the internal market. These changes also affect the climate and environmental signals and avoid consumption, production and generation decisions to be aligned with the climate objectives. However, in order to avoid distortion of the market and discrimination of electricity, the exemption of energy products used to produce electricity has to be maintained, irrespectively of the taxation of those energy products when used in other activities. Regarding electricity, its minimum rate shall reflect the decarbonisation of its generation mix and its contribution to EU climate neutrality targets. Besides, MSs should keep their right to reduce TVA levels on residential customers. Therefore, the Directive should make sure that any new tax, levy or charge implemented by a MS should not distort the price signal of the various energy products, and ensure the relative taxes based on carbon content are kept regardless of the State. A harmonised system of energy taxation in all MSs will create a true internal energy market avoiding the distortion of competition. Finally, the authorisation of the Commission of any MS specific supporting framework notified in the context of State Aid filing and monitoring, should be conditioned to the implementation of the polluters pay principle in the energy taxation, meaning any energy product is charged according its carbon content.
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Meeting with Damyana Stoynova (Cabinet of Executive Vice-President Frans Timmermans)

16 Mar 2020 · Discussion on the Green Deal and Climate Law

Response to Climate Law

6 Feb 2020

•Iberdrola welcomes the launching of the legislative process to pass a Climate Law that incorporates climate neutrality at the core of the EU policy developments that will take place within the implementation of the “European Green Deal”. •The achievement of the EU net-zero emissions target by 2050 is not only possible, but highly desirable both economically and environmentally. •However, clear and consistent goals and polices are needed to make the most of these economic and social opportunities. In this context, the Climate Law should include some robust guidelines on: •Legally binding Intermediate targets aligned with climate neutrality by 2050 and scientific findings of the International Panel on Climate Change (IPCC). oIberdrola considers that, as soon as possible, new political agreement should be reach to update EU GHG reduction target for 2030 to at least 55%. •Clear and stable sector and cross-cutting policies aimed at providing predictability, well-functioning markets, and fostering long-term investments, in the current context of climate emergency. oEnsuring fair competition between energy providers through the sound functioning of the markets will be essential to meet efficiently climate goals. •An environmental tax reform based on the “polluter pays” principle is crucial to ensuring effective and efficient decarbonisation, thus sending out signals to consumption, investment and operation (CO2 and other external factors) and freeing the electricity tariff from charges that do not correspond to it to ensure “real” technological neutrality and that the level playing field required for the most efficient options to be developed is created. •Industrial sector roadmaps: taking into account opportunities, threats, the competitive benefits of European industry, ensuring that all sectors play their part. •Fair transition: the process will involve all economic sectors, particularly energy, thus a fair and orderly transition must be designed in collaboration with all stakeholders to ensure that the affected sectors are given a reasonable period in which to adapt. •R&D&i policies targeting the development of cutting-edge, valuable technology for the new future. •Policy instruments to promote the development of practices, products, processes and technologies fully aligned with climate goals, both on mitigation and adaptation. •To achieve a climate neutral Europe by 2050 a complete transformation of the economy as a whole is required. Particularly, a changeover to a decarbonised energy model is needed; one based on energy efficiency, on renewable energies, practically eliminating the use of fossil fuels, first coal and oil and, subsequently, natural gas. •A climate neutral economy will entail the decarbonization of final energy uses (transport, building heating/air conditioning, industry, etc.) through cost efficient solutions and achieving full electricity generation through renewable energies by 2050, given the rapid and sustained technological and cost evolution of renewables. Moreover, replacing energy systems based on fossil fuels will make it possible to significantly enhance the efficiency of the entire system on account of the greater energy efficiency in electrical usage. •The electricity sector is fully prepared to face into this future; one in which it shall be the pivoting factor in decarbonisation given that it has already embarked on the wide-scale development of renewable energies and the modernisation and reinforcement of electricity grids, among other actions aimed at providing business solutions aligned with climate goals. •Finally, taking into account the thorough transformation of the EU economy that will take place to follow the deep emission reduction pathways required, building alliances and solid dialogue platforms will be crucial. On this regard, the Climate Law could include some guidelines to create a “climate dialogue platform” to promote an open and inclusive debate on climate
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Meeting with Olivier Smith (Cabinet of President Ursula von der Leyen)

6 Feb 2020 · European Green Deal

Meeting with Kadri Simson (Commissioner) and

9 Dec 2019 · European Green Deal, renewable and energy efficiency, research and innovation and accompanying the clean transition

Meeting with Frans Timmermans (First Vice-President) and

20 Nov 2019 · COP 25

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

10 Jul 2019

The Guidelines for trans-European energy infrastructure (TEN-E Regulation) provide a key framework to promote the deployment of an interoperable network enabling the integration of the internal market. The backbone of this framework is the development of the Projects of Common Interest (PCI). Iberdrola agrees broadly with the roadmap proposed by the Commission. The present document is a very preliminary view of some aspects to be covered in detail in the further consultation. In particular, we would like to bring the attention on certain elements around the adoption of the PCIs’. From a forward looking approach we consider that the evaluation should also comprise sector coupling, that means the cost effective integration of the gas and electricity aiming the EU carbon-neutrality by 2050. • Fails in Cost-Benefit Analysis (CBA) methodologies: Current CBA methodologies do not consider relevant elements such as the tax asymmetries among EU countries, that may distort the projection of flows through the interconnections, as alerted in all consultations. In addition, CBA for gas infrastructures should be supported by market tests, through for instance open season processes. Finally, the CBA methodologies should end up giving a priority list of projects for a certain country/interconnection. • Lack of adaptation: TEN-E should be adapted to other relevant regulations and particularly to the gas target model. As an example, the gas target model considers that a market size lower than 20 bcma would not reach full market functionality in terms of liquidity, depth and competition. However, we are dealing with a PCI list with gas projects between Spain and Portugal (6 bcma total demand) that theoretically should be carried out at regional level. • Role of ACER and NRAs: Consultation should explore also whether ACER and NRAs might play a key a larger role in the definition of the CBA methodologies and ensuring that the ENTSOs’ TYNDP scenarios reflect the new realities in the energy markets and are compliant with Paris Agreement 2050 carbon-neutral and cost effective approach.  The Agency, supported by the ENTSOs’ may have a room to lead a more independent CBA assessment on the new EU infrastructure and new PCI projects.  2050 carbon-neutral approach conveys a dramatic decrease in final demand of natural gas and other fossil fuels. New methodologies should take account of new situation, facilitating the path to decarbonisation and avoiding the emergence of stranded assets burdening the bills of EU consumers.  EC scenarios are anticipating for 2050 the onset of new technologies that might contribute through sector coupling to the decarbonisation of sectors like heavy, marine or air transport and high industrial temperature and providing more sources of flexibility and storage. CBA methodologies shall make sure only hydrogen produced from renewable electricity or truly carbon-neutral gases may be considered in the PCIs.  The revised methodology shall monitor the maturity of these new technologies and the appropriateness of high level investments from strict cost-effectiveness criteria, making an efficient balance among low-carbon innovation and network costs.  The National Regulatory Authorities – NRAs’ in close cooperation with themselves and with the Agency and supported by the TSOs’ shall lead the assessment of the TYNDPs’ for gas and electricity, comprising sector coupling issues. Project selection shall be validated by market perspectives and tariff assessment to be provided by NRAs’, generally in regionally coordinated reports. The perspectives opened by the lower demand for fossil fuels and sector coupling issues highlight the relevance of certain issues such as the emergence of stranded assets, the promotion and facilitation of new technologies, and the need to maintain strict observance of unbundling principles and enabling the market to act.
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Meeting with Maria Cristina Lobillo Borrero (Cabinet of Vice-President Miguel Arias Cañete)

30 Nov 2018 · Long Term Strategy

Meeting with Telmo Baltazar (Cabinet of President Jean-Claude Juncker) and ELECTRICITE DE FRANCE and

9 Jul 2018 · Energy Union and Climate Strategy

Meeting with Joachim Balke (Cabinet of Vice-President Miguel Arias Cañete)

29 May 2018 · CEP trilogues

Response to Post 2020 light vehicle CO2 Regulation(s)

26 Mar 2018

In this consultation response IBERDROLA proposes: 1. More ambitious emission reduction objectives of at least 45% for cars and 40% for vans in 2030. 2. A threshold for low-emission vehicles of 25gCO2/km for cars and 40g CO2/km for vans in order to align both he Clean Vehicles Directive and the CO2 Regulation for cars and vans. 3. A sales quota of ZEV on manufacturers over 20% by 2025, 35% by 2030 reaching 100% by 2040 with a credit and penalty system. 4. Double counting only for those alternatives with zero emissions at tailpipe under the Clean Vehicle Directive. 5. Flexibility for DSO to deploy a critical mass recharging infrastructure for EVs. 6. Set a target to ensure by 2022 the implementation of a critical mass recharging infrastructure allowing the deployment of the EV.
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Meeting with Stephen Quest (Director-General Taxation and Customs Union) and Vodafone Belgium SA and

13 Mar 2018 · Discussion on CCCTB (also with representatives from BP and Wolters Kluwer)

Meeting with Pierre Moscovici (Commissioner) and Vodafone Belgium SA and

13 Mar 2018 · Discussion on CCCTB (also with representatives from BP and Wolters Kluwer)

Meeting with Miguel Arias Cañete (Commissioner)

2 Feb 2018 · Climate and enrgy policy

Meeting with Silvia Bartolini (Cabinet of Vice-President Miguel Arias Cañete)

1 Feb 2018 · Mobility Package

Response to draft proposal on the promotion of clean and energy-efficient road transport vehicles

23 Jan 2018

In this consultation response IBERDROLA proposes: 1. More ambitious emission reduction objectives of at least 45% for cars and 40% for vans in 2030. 2. A threshold for low-emission vehicles of 25gCO2/km for cars and 40g CO2/km for vans in order to align both he Clean Vehicles Directive and the CO2 Regulation for cars and vans. 3. A sales quota of ZEV on manufacturers over 20% by 2025, 35% by 2030 reaching 100% by 2040 with a credit and penalty system. .4. Double counting only for those alternatives with zero emissions at tailpipe under the Clean Vehicle Directive. 5. Flexibility for DSO to deploy a critical mass recharging infrastructure for EVs. 6. Set a target to ensure by 2022 the implementation of a critical mass recharging infrastructure allowing the deployment of the EV.
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Meeting with Maria Cristina Lobillo Borrero (Cabinet of Vice-President Miguel Arias Cañete)

23 Jan 2018 · Clean Energy package

Meeting with Maria Cristina Lobillo Borrero (Cabinet of Vice-President Miguel Arias Cañete)

6 Dec 2017 · State of play of Clean Energy Package

Meeting with Luis Romero Requena (Director-General Legal Service)

8 Nov 2017 · Opening of the new Iberdrola Brussels office

Response to Evaluation Energy Taxation Directive

26 Sept 2017

Please kindly refer to the attached document
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Meeting with Miguel Arias Cañete (Commissioner) and ENGIE

17 Jul 2017 · Winter Package

Meeting with Joachim Balke (Cabinet of Vice-President Miguel Arias Cañete)

12 Jun 2017 · Market design

Meeting with Miguel Angel Sagredo Fernandez (Cabinet of Vice-President Miguel Arias Cañete)

10 May 2017 · Climate change in Spain

Meeting with Miguel Arias Cañete (Commissioner)

7 Apr 2017 · Energías renovables

Meeting with Maria Cristina Lobillo Borrero (Cabinet of Vice-President Miguel Arias Cañete), Miguel Angel Sagredo Fernandez (Cabinet of Vice-President Miguel Arias Cañete)

6 Apr 2017 · Clean Energy Package- state of play in the European Parliament and the Council

Meeting with Joachim Balke (Cabinet of Vice-President Miguel Arias Cañete), Maria Cristina Lobillo Borrero (Cabinet of Vice-President Miguel Arias Cañete)

24 Jan 2017 · Market Design

Response to Commission Regulation establishing a guideline on electricity balancing

28 Dec 2016

IBERDROLA is a company operating in the field of electricity, gas and renewable energy which provides services within this sector under its own name and through all the companies included in IBERDROLA’s Group. Iberdrola is the largest European integrated utility and the third utility worldwide. Its main businesses are located in Continental Europe, United Kingdom, USA, Mexico and Brazil and comprise 44.3 GW of installed capacity, of which 26 GW in renewable sources, over 215 TWh of energy delivered. It serves in areas totaling a population of 110 million customers (electricity and gas). Iberdrola is happy to contribute to the consultation of Draft regulation of Commission Regulation establishing a guideline on electricity balancing (Reference Ares(2016)6785886) to submit through “Better Regulation” initiatives. This document summarises the main positions regarding the issues in discussion. The Imbalance Settlement Period -ISP- in Spain is 60 minutes. According to the “Proposal of Regulation establishing a Guideline on Electricity Balancing” this period should be equal to 15 minutes in all control areas by three years after its entry into force. This would be premature and non-cost-efficient as shown by careful analysis. A cost benefit analysis -CBA- on the harmonization of the ISP was performed by Frontier Economics in April of 2016 "CBA OF A CHANGE TO THE IMBALANCE SETTLEMENT PERIOD" (https://www.entsoe.eu/Documents/Network%20codes%20documents/Implementation/CBA_ISP/ISP_CBA_Final_report_29-04-2016_v4.1.pdf). This CBA assessed the consequences of the harmonization at national and European level. Four planning cases were analyzed: • Planning case 1 – full harmonisation to 15 minutes • Planning case 2 – harmonise to 15 minutes only those countries currently at 60 minutes • Planning case 3 – harmonisation by matching ISPs in neighbouring countries • Planning case 4 – full harmonisation to 5 minutes For each planning case, two different scenarios were considered: • Unadjusted stakeholder data: based on the information provided participants. • Profiling: considers that some of the reported costs can be avoided by profiling. At national level, results were summarized in the table "Exhibit 56. Planning case 1- net welfare country (profiling and high benefits)" of the Frontier report mentioned above, for the profiling scenario associated to planning case 1. The table shows that total cost significantly exceeds total benefit in many countries. In Spain, total cost (813.1€mn) doubles total benefit (409.8€mn). In UK, total cost (786€mn) triples the total benefit (282.4€mn). Note these two countries are expected to finish before 2020 smart meters roll-out. At European Level, results showed that net benefits of the different planning cases could be either weakly positive or strongly negative. The table "Exhibit 71. Net benefits by planning case and sub-case" of Frontier Report summarizes European results at aggregated level for all planning cases and scenarios. Considering the aforementioned, Iberdrola position is that the “Regulation establishing a Guideline on Electricity Balancing” should allow a deferred implementation of the harmonized ISP in those countries where total cost clearly exceeds total benefit. To allow a deferred implementation, articles 5 and 55 of the current proposal need to be modified as follows: • Section (i) of article 5.3 -concerning “the exemption in respect of the harmonization of the imbalance settlement periods pursuant to Article 55(2)”- should be moved to article 5.4. • Article 55 should be redrafted to allow exemptions at Member State level (instead of at synchronous area level).
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Meeting with Miguel Arias Cañete (Commissioner) and ELECTRICITE DE FRANCE and

22 Nov 2016 · ETS reform

Meeting with Joachim Balke (Cabinet of Vice-President Miguel Arias Cañete), Maria Cristina Lobillo Borrero (Cabinet of Vice-President Miguel Arias Cañete) and

15 Nov 2016 · Electricity Market Design

Meeting with Dominique Ristori (Director-General Energy) and ENEL SpA and

27 Sept 2016 · Energy policy

Meeting with Joachim Balke (Cabinet of Vice-President Miguel Arias Cañete)

7 Sept 2016 · Market design

Meeting with Jos Delbeke (Director-General Climate Action)

30 Jun 2016 · 2030 Climate and Energy Framework and revision of the EU ETS

Meeting with Miguel Arias Cañete (Commissioner) and WindEurope and

5 Jun 2016 · policy framework post-2020: review of the renewable energy directive and market design

Meeting with Luis Romero Requena (Director-General Legal Service)

26 May 2016 · Courtesy visit

Meeting with Maria Cristina Lobillo Borrero (Cabinet of Vice-President Miguel Arias Cañete)

26 May 2016 · State of play of ETS process

Meeting with Miguel Ceballos Baron (Cabinet of Vice-President Cecilia Malmström) and NOVE and

12 Apr 2016 · Trade agreement with Mexico

Meeting with Maria Cristina Lobillo Borrero (Cabinet of Vice-President Miguel Arias Cañete)

15 Mar 2016 · Electricity Market Design

Meeting with Miguel Arias Cañete (Commissioner)

22 Feb 2016 · General situation of the Energy sector and the outlook for 2016

Meeting with Maria Cristina Lobillo Borrero (Cabinet of Vice-President Miguel Arias Cañete)

8 Jan 2016 · Legislative activity in 2016

Meeting with Dominique Ristori (Director-General Energy) and Eni S.p.A. and

6 Oct 2015 · European energy policies

Meeting with Miguel Arias Cañete (Commissioner) and

1 Oct 2015 · RES

Meeting with Joachim Balke (Cabinet of Vice-President Miguel Arias Cañete), Maria Cristina Lobillo Borrero (Cabinet of Vice-President Miguel Arias Cañete) and

24 Sept 2015 · High-Level Group on Energy Infrastructure in Europe

Meeting with Pierre Schellekens (Cabinet of Vice-President Miguel Arias Cañete)

21 Sept 2015 · Energy Union

Meeting with Miguel Arias Cañete (Commissioner) and

17 Sept 2015 · Investment in Algeria

Meeting with Isaac Valero Ladron (Cabinet of Vice-President Miguel Arias Cañete)

15 Sept 2015 · COP21

Meeting with Miguel Arias Cañete (Commissioner) and

23 Jun 2015 · Internal Electricity Market

Meeting with Miguel Gil Tertre (Cabinet of Vice-President Jyrki Katainen)

6 May 2015 · Investment Initiative

Meeting with Maroš Šefčovič (Vice-President) and ENGIE and

21 Apr 2015 · Energy Union

Meeting with Maria Cristina Lobillo Borrero (Cabinet of Vice-President Miguel Arias Cañete)

15 Jan 2015 · Courtesy meeting

Meeting with Miguel Arias Cañete (Commissioner) and

14 Jan 2015 · Energy Union ans Internal Energy Market

Meeting with Pierre Schellekens (Cabinet of Vice-President Miguel Arias Cañete)

16 Dec 2014 · Energy and Climate Action

Meeting with Dominique Ristori (Director-General Energy) and ENEL SpA and

11 Dec 2014 · European Energy Policy priorities