innogy SE
innogy
Die innogy SE ist ein europäisches Energieunternehmen und Teil des E.ON-Konzerns.
ID: 569652431561-54
Lobbying Activity
Response to Revision of Alternative Fuels Infrastructure Directive
29 Apr 2020
To achieve the objectives set out in the Green Deal, all EU policies and sectors will need to make their contribution – notably the transport sector. As innogy, part of the E.ON group, explicitly advocates for electric mobility in road traffic, we welcome the Commission’s commitment to spur the action needed to keep the transition towards cleaner mobility and the EU on the path in meeting its Paris climate commitments. As such we welcome the Commission´s incentive to revise the Alternative Fuels Infrastructure Directive and have provided a more in depth analysis in the attached document.
Read full responseResponse to Report on the application of the General Data Protection Regulation
28 Apr 2020
We are enthusiastic about the GDPR and see high data protection standards as a chance to build trust and transparency with our customers. It has harmonized many existing rules across Europe, given clear instructions to businesses as to what is expected of them and helped customers feel protected. After two years’ working with GDPR we do believe there are some areas in which the Regulation could be improved to increase its effectiveness. These are as follows:
1. Harmonization of authorities` opinions: in the last two years we have found that the regulatory bodies across Europe can provide different legal interpretations of the GDPR. Even in a single member state there are often conflicting opinions from numerous data authorities. As a company operating in over 15 countries it is challenging and expensive to implement standardized processes across the company when there are differing regulatory opinions across the Union. It also creates considerable uncertainties that carry a potentially high financial risk. We would welcome stronger steering from the European Data Protection Board to ensure a more consistent approach across the EU.
2. Making information duties more customer friendly (allowing the so called “media break”): in certain contexts the need to provide information at the time when data are collected raises practical questions, especially for offline-communication. For example, when requesting a meter reading from a customer this simple procedure must now be accompanied by a lengthy and unwieldy letter. It is equally challenging where communication is verbal, and it is impractical to recite such information. A simpler and more customer friendly solution would be to provide a link to a webpage with the relevant information. However, the acceptability of switching communication channels during a customer contact (so called “media break”) is questionable. A clear statement from the relevant authorities on the permissibility of such actions would be welcome.
3. 72-hour breach notification (Art. 33): the GDPR stipulates that in the case of a personal data breach the data controller has 72 hours after having become aware of it to notify the regulatory authority. We support prompt reporting; however, the 72-hour window is challenging. In many cases frontline colleagues are essential to clarifying whether there has been a reportable breach. Their natural human reaction to the such enquiries is often defensive and it takes time to coach them through the process. This is further complicated for a larger company, such as ourselves, as there are numerous reporting lines and adjacent teams to align with and/or investigate. An extension of the window that factors in these challenges would be welcome.
4. Data protection by design (Art 25): Under the current rules the requirement for “Data protection by design” are directed towards the data controller. However, we are often reliant on hardware, standard operating systems and application software that is bought in. In some cases, the choices available to us in both the products and the way we use them are limited. As such there is little we can do to ensure data protection by design. Despite this lack of control we are held accountable for failing to deliver on this Article. A fairer and more comprehensive approach would be to make a wider group of parties subject to this requirement.
Read full responseMeeting 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 2030 Climate Target Plan
14 Apr 2020
We welcome the Commission’s commitment to greater climate ambition. The energy industry has been actively driving the energy transition for decades. For us higher ambition is not only good for the environment and society, but for our business too. We support the Commission's intention to publish an impact assessment on a potential increase of the EU’s 2030 greenhouse gas emission reductions target to 50%-55% by September 2020. This will be key to understanding the positive and negative impacts of such a change. If an adjustment of the 2030 target is to be carried out, this needs to be undertaken as soon as possible so that the policies needed to deliver it can be introduced. Thus, we support the Commission´s intention to review, and where necessary propose a revision of, all relevant climate-related policies by June 2021. However, any adjustments of existing legislation must be done in a manner that does not stall ongoing implementation.We support the European Green Deal and believe it’s focus should be on delivering concrete policies that place carbon-neutral electricity at its heart. Since 1990, CO2 emissions in the electricity sector have decreased by over 25%, and there is a clear ambition from the European power sector to achieve carbon neutrality before 2050. As the electricity mix decarbonizes, increasing the use of electricity in heating, cooling and transport can ensure a quick and efficient decarbonization of these sectors.As such the priority should be to address the missing price signals: 40% of EU emissions arise from transport and buildings, yet there is no price on carbon in these sectors. We therefore welcome the Commission's intention to propose extending the ETS to these sectors. However, a carbon price will not create the correct incentives alone, it must go hand in hand with a rapid reduction of the electricity price. This can be delivered by moving away from financing renewables via levies on the electricity price and moving to zero taxation on electricity. The money raised by those levies and taxes can be replaced by revenues arising from the expansion in carbon pricing. Increasing carbon prices for polluting fuels and lower electricity costs will make low carbon technologies, as competitive as more carbon intensive ones. The European Green Deal must not neglect the central role, and investment needs, of the distribution system. 90% of renewable energy generation is connected to the distribution grid, at the same time more and more consumers choose to produce and consume electricity. In addition, most of the charging infrastructure for electric vehicles and Power-to-X technology will be connected to the DSO. The distribution system is the thread that holds the green electricity system together and is the platform for the decarbonization of other sectors. Distribution grids need to become more intelligent, digital and flexible. To achieve this, incentives are needed to encourage network operators to make greater use of new technologies and activities, ensuring that they build a smarter European network, not just a bigger one.The European Green Deal will create significant investment needs. The magnitude of the investment challenge requires mobilizing both the public and private sector. In order to support this a reshaping of State Aid rules is needed. The Commission should consider turning the General Block Exception Regulation into a climate-neutrality instrument, allowing member states greater freedom to support technologies and solutions that can deliver on our climate objectives. Finally, the consequences of the current coronavirus pandemic must be considered. Some Member States and Members of the European Parliament are already expressing caution regarding the adjustment of the 2030 target due to the pandemic. Significant measures and stimulus packages will be needed after the crisis is over and we believe these necessary measures can, and should, contribute significantly to our climate objectives.
Read full responseResponse to Revision of the Energy Tax Directive
31 Mar 2020
We welcome the European Commission’s initiative to review the Energy Taxation Directive and make it consistent with the climate agenda of the Green Deal.
Taxation policy can become one of the most important and effective instruments to steer the European economy and consumer behavior patterns towards increasingly sustainable choices.
Net-neutrality by 2050 requires a timely re-alignment of the policy framework around the “polluter pays” principle. This means that energy taxation rates should better reflect carbon emissions-intensity of energy carriers all over Europe.
While industry has generally fared better to improve the energy intensity of their operations in order to reduce costs and stay competitive, little incentive exists for individual consumers. Tax rates that are proportional to the CO2 output are an essential to steer consumption patterns, promote fuel switching and the use of renewable energy.
The cost of externalities from fossil fuels (health, climate abatement, climate adaptation) should be factored into energy prices. The minimum rates provided in the current ETD are not based on any specific logic. These thresholds remained unchanged since 2003 and their relative value has decreased over time, making them ineffective and unfit to give an adequate price signal to energy users.
Zero tax on electricity to unlock potential for a net-zero future
Electricity generation has decarbonized at the fastest rate, reaching a RES share in the generation mix of 32.3% in 2018. As clean technologies reach maturity and costs go down, this trend is likely to continue. This makes electricity the best energy carrier to serve the mobility and heating needs of European citizens. Yet the electricity price still carries a disproportionate burden of the energy transition, with high level of taxes and levies, and other forms of fiscalization, like social tariffs.
The review of ETD must account for the developments in the generation mix, the potential of decentralized production, and stimulate further electrification of these sectors, by enabling a reduction of the taxes and levies on electricity to zero.
To incentivize investment in Power-to-Gas (P2G) facilities, the ETD should also provide that they are not be categorized as end-user and face input costs that include taxes and levies.
ETD revision should mitigate further market fragmentation
In some MSs, in addition to fulfilling its fiscal, energy taxation already has a role in addressing environmental challenges, taking into account the carbon content of different energy products. But having divergent national tax rates above the minimum threshold actually leads to the fragmentation of the internal market. New technologies, not covered under the 2003 ETD, allow for some MSs to apply their own classifications.
ETD should address the risk of growing distortion and prop up the internal market, to make the European economy fit for the bold transformation envisaged in the decades to come. Providing clear guidelines on how to set taxation rates based on environmental impact could mitigate this and improve coherence between MSs. This would also help all MSs differentiate between new lower-carbon energy carriers like biogas or hydrogen, from their fossil counterpart.
Lower taxes on electricity could be budget-neutral
Energy taxation is an important revenue stream for all countries. The reduction in electricity taxes should be recovered from higher rates for carbon-intensive energy carriers. Relieving the electricity prices can have two other important positive effects for the economy:
o foster the competitiveness of energy-intensive European industry, by covering the price differential compared with non-EU regions;
o address social aspects, by making electricity more affordable for all consumers.
Read full responseMeeting with Mauro Raffaele Petriccione (Director-General Climate Action) and E.ON SE
27 Nov 2019 · European Green Deal
Meeting with Silvia Bartolini (Cabinet of Vice-President Miguel Arias Cañete)
17 May 2018 · Transport Decarbonisation, 2nd & 3rd Mobility Package