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Ørsted A/S

Ørsted develops, constructs and operates offshore and onshore wind farms, solar farms, energy storage, renewable hydrogen facilities, and bioenergy plants.

Lobbying Activity

Meeting with Dan Jørgensen (Commissioner) and RWE AG and

1 Dec 2025 · Cross-border energy partnerships

Meeting with Mechthild Woersdoerfer (Deputy Director-General Energy) and Green Power Denmark and

1 Dec 2025 · Exchange of views on electricity market rules and electrification

Meeting with Tomas Baert (Cabinet of President Ursula von der Leyen)

17 Nov 2025 · Discussion on Ørsted’s offshore wind development activities in the United States

Response to Circular Economy Act

6 Nov 2025

Thank you for the opportunity to provide additional input to the Circular Economy Act. Ørsted supports the Commissions efforts to boost the circular economy as circularity can be a powerful tool towards decarbonization, environmental protection, competitiveness and supply chain resilience. Regulating circularity is complex as regulations have to consider market dynamics in long international supply chains, financial carrying capacity of sectors, life times of assets / products (which can span several decades) and product/material-specific characteristics. Without a thorough understanding of this complex reality and sufficient specificity in measures, circularity policies would fail to achieve their intended goals. We refer to the attached for our full contribution.
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Meeting with Monika Zsigri (Head of Unit Energy)

5 Nov 2025 · Exchange on protection of wind power installations from physical and cyber threats

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

24 Oct 2025 · Energy policies; industry challenges

Ørsted Urges Flexibility in Wind Blade Recycling Requirements

14 Oct 2025
Topic — Public procurement sustainability requirements for clean technologies including wind turbines.
Message — Ørsted requests clarification on the definition of recycling and what forms of material recovery qualify. They seek adjustments to the required Technology Readiness Level for recycling technologies, arguing current requirements are unclear and potentially impractical.1
Why — This would allow them to use emerging recycling technologies and reduce procurement compliance barriers.2
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Ørsted calls for stronger offshore wind protection against sabotage

13 Oct 2025
Topic — Revision of EU energy security framework after Russia's invasion exposed gaps.
Message — Ørsted requests stronger physical security for offshore wind infrastructure against sabotage and hybrid warfare. They emphasize that developers cannot address these threats alone and need clear coordination between defense authorities, intelligence sharing, and balanced cost allocation between industry and states.123
Why — This would reduce their exposure to unmanageable security risks from state-sponsored attacks.45
Impact — Taxpayers may bear costs for military protection that industry argues it cannot provide.67
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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 Kira Marie Peter-Hansen (Member of the European Parliament)

7 Oct 2025 · EU energy policy and sustainability omnibus

Meeting with Teresa Ribera Rodríguez (Executive Vice-President) and

1 Oct 2025 · Geopolitical and competitiveness landscape of wind industry.

Ørsted urges clarity on UK carbon price recognition before 2026

25 Sept 2025
Topic — Rules for converting third-country carbon prices into CBAM certificate reductions.
Message — The organization requests immediate clarity on how carbon prices paid in other countries will be recognized under CBAM, particularly for electricity imports. They emphasize the UK's ETS price and carbon price support scheme must be confirmed as eligible for CBAM reductions before January 2026. They argue uncertainty about CBAM costs will restrict electricity flows into the EU.123
Why — This would eliminate uncertainty threatening their UK electricity import business profitability.45
Impact — EU consumers face higher electricity prices and increased emissions without UK imports.67
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Ørsted urges flexibility in EU carbon removal certification rules

22 Sept 2025
Topic — EU regulation establishing certification methodologies for permanent carbon removal activities including BioCCS.
Message — The organization requests flexible monitoring requirements that allow design optimization until operation starts, quarterly or monthly credit issuance with annual audits instead of audits at each certification, and alignment of biomass sustainability rules with existing RED requirements. They argue current narrow technical requirements risk locking projects into suboptimal designs years before operation.1234
Why — This would reduce compliance costs and enable faster cash flow for their capital-intensive BioCCS projects.56
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Meeting with Niels Flemming Hansen (Member of the European Parliament)

22 Sept 2025 · Update on Ørsted situation

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament) and Confederation of Danish Industry and

18 Sept 2025 · Erhvervsnetværk - Sustainability omnibus

Meeting with Christian Ehler (Member of the European Parliament)

16 Sept 2025 · Energy policy

Ørsted Backs Wind Turbine Inclusion in CRM Recovery List

25 Jul 2025
Topic — Establishing a list of products with high critical raw materials recovery potential.
Message — The company supports including wind components like magnets and generators to strengthen supply chains. They urge EU-level coordination of national programs to ensure market scale for recycling. They advise caution on auction criteria to avoid unrealistic requirements and high costs.123
Why — This secures their material supply while preventing auction failures caused by impossible standards.45
Impact — Recycling startups lose a viable customer base if national recovery efforts remain uncoordinated.6
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Response to Industrial Decarbonisation Accelerator Act

8 Jul 2025

Ørsted's response to the Call for Evidence is based on an in-depth analysis of policy measures. The attached analysis portrays demand side measures that can complement supply side policies, enabling a competitive and resilient electrified European industry and economy. Please refer to the attached document for illustrations, analysis, data, and more information.
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Meeting with Christian Ehler (Member of the European Parliament) and DHL Group and

2 Jul 2025 · RFNBO und Wasserstoff

Meeting with Jan Hendrik Dopheide (Cabinet of Commissioner Maroš Šefčovič)

26 Jun 2025 · Brief exchange on international trade

Meeting with Matthias Jorgensen (Acting Director Trade)

25 Jun 2025 · EU-US trade relations

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament)

13 Jun 2025 · Ørsted reception

Ørsted urges aligned EU finance rules to reduce reporting burdens

29 May 2025
Topic — This consultation evaluates EU sustainable finance disclosure rules to improve transparency and usability.
Message — Ørsted recommends aligning disclosure rules with the EU taxonomy and reporting standards to reduce administrative burdens. They suggest restricting investors from requesting information on topics considered immaterial in company reports.12
Why — This would protect companies from high volumes of inconsistent and specific data requests.3
Impact — Investment fund managers would lose the flexibility to request bespoke sustainability data.4
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Meeting with Kira Marie Peter-Hansen (Member of the European Parliament, Shadow rapporteur)

28 May 2025 · Omnibus - CSRD and CS3D

Meeting with Aleksandra Kordecka (Cabinet of Executive Vice-President Stéphane Séjourné) and European Chemical Industry Council and

14 May 2025 · Implementation of Clean Industrial Deal

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament, Shadow rapporteur)

13 May 2025 · Sustainability omnibus

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

8 Apr 2025 · Wind energy, electrification, competitiveness, permitting, grids

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

4 Apr 2025 · Action plan for affordable energy, electrification, grid package, offshore wind, investments and supply chain

Ørsted warns of unlevel playing field from reporting thresholds

26 Mar 2025
Topic — This initiative aims to simplify sustainability reporting requirements for European companies.
Message — Ørsted requests elaboration on the 10% threshold to maintain a level playing field. They suggest improving templates to distinguish non-aligned from non-applicable activities. The company seeks clarification on how to report partial alignment effectively.123
Why — Exemptions for small activities would significantly reduce the company's regulatory assessment burden.4
Impact — Investors lose access to representative data from companies with diverse portfolios.5
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Meeting with Maria Luís Albuquerque (Commissioner) and

24 Mar 2025 · Dinner at the House of Danish Industry and roundtable discussion

Ørsted urges exempting renewable energy from EU procurement rules

7 Mar 2025
Topic — The Commission is evaluating the efficiency and relevance of public procurement directives.
Message — Ørsted requests exempting electricity generation, especially renewable energy projects, from specific tendering rules to reflect modern market competition. They also advocate for more flexible contract changes and higher spending thresholds for applying these rules.123
Why — Reducing these administrative requirements would lower costs and accelerate renewable energy deployment.4
Impact — Consumers may suffer if misapplied procurement rules distort markets and reduce efficiency.5
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Response to Implementing Act on non-price criteria in renewable energy auctions

21 Feb 2025

Ørsted warmly welcomes the primary objective of the Net Zero Industry Act (NZIA) of reducing risk of supply disruptions of net zero technologies and the additional specification in particular by identifying and supporting the scale up of the manufacturing capacity of net zero technologies and their supply chains (Net Zero Industry Act Regulation, Article 2(a)). The NZIA introduces very useful measures to facilitate that on the supply side. But implementing some measures on the demand side (i.e. access to markets) carries the risk of severely complicating the build out of renewable energy. Hence, the implementing acts following the Regulation need to be carefully designed and allow flexibility for member states and for further assessment. The introduction of the resilience contribution in public procurement and renewable energy auctions could lead to significant risks, including (i) cost increases, (ii) project delays, (iii) project cancellations, (iv) bid dissuasion, and (v) distortion of competition, if not well designed. When finalising the NZIA implementing acts related to resilience, Ørsted recommends the following: Carefully assess the current supplier landscape and the speed and cost at which alternative supply routes can be accessed. Publish the results before any technology, product or component is added to the list pursuant to article 29(2) of the NZIA regulation. Use a five-year average to assess the dependencies pursuant to article 29(2) to ensure that exceptional years do not distort the picture. In the assessment it should also be taken into account whether the dependency is trending downward. Enhance the methodology determining main specific components and cautiously re-assess the inclusion of (i) offshore substations, (ii) permanent magnets, (iii) rotor hubs, (iv) power transformers, in the list. The resilience contribution should be phased-in gradually. The list of main specific components should at the earliest apply to auction frameworks published 12 months after the publication of the resilience contribution list. This would avoid delays in renewable energy auctions due to abrupt amendments to the underlying legislation under which they are designed. By no means should the resilience contribution apply retroactively to existing commercial contracts or contracts entered to deliver renewable energy projects on which concession has already been awarded. This includes already awarded projects and public procurement of net zero energy technologies that is carried out to deliver projects already awarded at the time of the publication of the list pursuant to article 29(2). The resilience contribution should not apply to public procurement of net zero energy technologies that is carried out by entities participating in competitive markets, or for projects awarded through competitive renewable energy auctions. In renewable energy auctions, the resilience contribution should be applied through prequalification criteria rather than award criteria. The latter would incentivise bidding based on speculative assumptions on availability of sourcing options in a restricted geography. This could lead to increased risk of project delays or cancellations. Instead, thorough market dialogues should be used to reveal optimal setting of such requirements. The obligation in article 6 (1)e (ability to deliver) on providing information on service providers, suppliers and other contractors as a prequalification criterion, would significantly increase development costs (devex) and potentially lead to bid dissuasion. Most capex commitments are made after bid submission, thus if suppliers are to be identified ahead of bid submission, it would significantly increase cost of pre-contractual negotiations.
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Response to List of net-zero technology final products and their main specific components

20 Feb 2025

Ørsted warmly welcomes the primary objective of the Net Zero Industry Act (NZIA) of reducing risk of supply disruptions of net zero technologies and the additional specification in particular by identifying and supporting the scale up of the manufacturing capacity of net zero technologies and their supply chains (Net Zero Industry Act Regulation, Article 2(a)). The NZIA introduces very useful measures to facilitate that on the supply side. But implementing some measures on the demand side (i.e. access to markets) carries the risk of severely complicating the build out of renewable energy. Hence, the implementing acts following the Regulation need to be carefully designed and allow flexibility for member states and for further assessment. Especially the introduction of the resilience contribution in public procurement and renewable energy auctions bears the risk of causing significant (i) cost increases, (ii) project delays, (iii) project cancellations, (iv) bid dissuasion and (v) distortion of competition, if not well designed When finalising the NZIA implementing acts related to resilience, Ørsted recommends the following: Carefully assess the current supplier landscape and the speed and cost at which alternative supply routes can be accessed. Publish the results before any technology, product or component is added to the list pursuant to article 29(2) of the NZIA regulation Use a five-year average to assess the dependencies pursuant to article 29(2) to ensure that exceptional years do not distort the picture. In the assessment it should also be taken into account whether the dependency is trending downward. Enhance the methodology determining main specific components, and cautiously re-assess the inclusion of (i) offshore substations, (ii) permanent magnets, (iii) rotor hubs, (iv) power transformers, in the list. The resilience contribution should be phased-in gradually. The list of main specific components should at the earliest apply to auction frameworks published 12 months after the publication of the resilience contribution list. This would avoid delays in renewable energy auctions due to abrupt amendments to the underlying legislation under which they are designed. By no means should the resilience contribution apply retroactively to existing commercial contracts or contracts entered into to deliver renewable energy projects on which concession has already been awarded. This includes already awarded projects and public procurement of net zero energy technologies that is carried out to deliver projects already awarded at the time of the publication of the list pursuant to article 29(2). The resilience contribution should not apply to public procurement of net zero energy technologies that is carried out by entities participating in competitive markets, or for projects awarded through competitive renewable energy auctions. When applying the resilience contribution in renewable energy auctions, we would encourage that this is done through prequalification criteria rather than award criteria. The latter would incentivise bidding based on speculative assumptions on availability of sourcing options in a restricted geography. This could lead to increased risk of project delays or cancellations. Instead thorough market dialogues should be used to reveal optimal setting of such requirements. The obligation in article 6 (1)e (ability to deliver) on providing information on service providers, suppliers and other contractors as a prequalification criterion, would significantly increase development costs (devex) and potentially lead to bid dissuasion. Most capex commitments are made after bid submission, thus if suppliers are to be identified ahead of bid submission, it would significantly increase cost of pre-contractual negotiations.
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Response to The European Oceans Pact

17 Feb 2025

The European Commission has recently launched a Call for Evidence to gather input and ideas for its Oceans Pact communication, a communication that aims to promote sustainable ocean management and ensure the health, resilience, and productivity of the oceans and thus the prosperity of the EUs coastal communities. The Call for Evidence follows significant action on ocean governance, Marine Spatial Planning and nature conservation and restoration during the last Commission mandate. Ørsted as the global-leader in offshore wind, supports these actions and strengthening of these actions through the Oceans Pact. Sectors such as Renewable Energies, Carbon Capture and Storage, Shipping and Defence, have a growing need of space at sea. Growth of these sectors needs to, and can only, be realized in harmony with nature and in good cooperation with existing users of the seas. Such symbiotic growth can only be achieved with 1) effective seabasin level Marine Spatial Planning, 2) efficient and sustainable (co-)use of seabed space, and 3) unlocking public and private finance for nature restoration and conservation. We see significant potential for the Oceans Pact in helping to achieve these goals. We share our ideas for the Oceans Pact communication in the attached evidence.
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Meeting with Dan Jørgensen (Commissioner)

17 Feb 2025 · Offshore wind

Meeting with Joachim Balke (Head of Unit Energy)

20 Jan 2025 · Offshore wind

Meeting with Thomas Auger (Cabinet of Executive Vice-President Teresa Ribera Rodríguez)

20 Jan 2025 · Offshore wind and regional cooperation

Meeting with Niels Fuglsang (Member of the European Parliament)

15 Jan 2025 · Meeting on energy

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

13 Dec 2024 · Competitiveness and energy Transition

Meeting with Stine Bosse (Member of the European Parliament)

13 Dec 2024 · European 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

Meeting with Sigrid Friis (Member of the European Parliament)

5 Dec 2024 · EU climate policies

Meeting with Per Clausen (Member of the European Parliament)

4 Dec 2024 · Energipolitisk dagsorden

Ørsted Seeks Clarity on CBAM Fiscal Representation and Storage

28 Nov 2024
Topic — This consultation establishes the registry and authorization process for carbon border imports.
Message — Ørsted asks whether non-EU importers can use fiscal representatives for administrative duties. They also request clarity on using bonded warehouses and how storage penalties are calculated.123
Why — This would simplify logistics and reduce administrative hurdles for international goods shipments.4
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Ørsted urges EU to prioritize renewables for energy security

26 Nov 2024
Topic — This consultation evaluates the performance of the EU's current energy security legislative framework.
Message — Ørsted advocates for phasing out fossil fuel imports in favor of domestic renewable energy. They call for enhanced protection of offshore infrastructure against state-sponsored sabotage and hybrid warfare. They also stress maintaining integrated energy markets while avoiding disruptive price interventions.123
Why — This would make the company's energy production assets immune to global supply shocks.4
Impact — Fossil fuel exporters would lose market share as Europe transitions to domestic energy sources.56
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Meeting with Kira Marie Peter-Hansen (Member of the European Parliament) and Novo Nordisk A/S and

25 Oct 2024 · Speaker at network meeting with Danish companies on EU competitiveness

Meeting with Per Clausen (Member of the European Parliament) and Fortum Oyj and

16 Oct 2024 · Nordic MEPs Breakfast - Insights on Power Markets, Energy Transition and Nordic Competitiveness

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament)

15 Oct 2024 · NZIA and procurement, Draghi report

Response to Ex-post evaluation of the Connecting Europe Facility 2014-2020

24 Sept 2024

Thank your for the possibility to contribute to this call for evidence. Please find our feedback attached. Kind regards, Sebastian Schulte-Derne Head of EU Office, Ørsted A/S
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Meeting with Jutta Paulus (Member of the European Parliament)

18 Sept 2024 · Future of the Green Deal

Meeting with Niels Flemming Hansen (Member of the European Parliament) and Copenhagen Infrastructure Partners P/S

11 Sept 2024 · Energy policy

Meeting with Sigrid Friis (Member of the European Parliament)

15 Aug 2024 · Upcoming mandate

Meeting with Jens Geier (Member of the European Parliament)

24 Jul 2024 · Exchange on Wind Power

Meeting with Lena Schilling (Member of the European Parliament)

17 Jul 2024 · Offshore- und Onshore-Windparks, Solar-Parks and Energy Storage

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament)

3 Jul 2024 · Energy policy in light of European elections

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness) and Shell Companies and

10 Jun 2024 · review of the MiFID II commodities regime

Meeting with Barbara Glowacka (Cabinet of Commissioner Kadri Simson), Stefano Grassi (Cabinet of Commissioner Kadri Simson)

10 Jun 2024 · Offshore wind power

Meeting with Margrethe Vestager (Executive Vice-President) and

22 Mar 2024 · Discussion of current challenges facing the European Steel sector attended by private industry as well as Ministers and official representatives of Italy, Romania, Poland, Czechia, Belgium, Hungary and Luxembourg

Meeting with Maroš Šefčovič (Executive Vice-President) and

22 Mar 2024 · Clean Transition Dialogue with the Steel Sector

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

14 Mar 2024 · Energy market

Ørsted Urges Timely Implementation of Wind Auction Rules

1 Mar 2024
Topic — The consultation addresses new qualitative criteria and design elements for renewable energy auctions.
Message — The Wind Power Action Plan and NZIA must be implemented diligently and in due time. Auctions should include non-price criteria and limit the negative consequences of uncapped negative bidding.12
Why — These reforms provide the company with greater visibility and investment certainty for wind projects.3
Impact — Bidders relying on aggressive pricing strategies face new limits on uncapped negative bidding.4
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Meeting with Ditte Juul-Joergensen (Director-General Energy) and Confederation of Danish Industry and

1 Mar 2024 · Energy market Also present: ESABCC, Think Europa, the Danish Council on Climate Change

Meeting with Adam Romanowski (Cabinet of Vice-President Maroš Šefčovič), Helena Braun (Cabinet of Vice-President Maroš Šefčovič)

25 Jan 2024 · Biodiversity restoration and renewable energy deployment

Meeting with Maroš Šefčovič (Executive Vice-President)

18 Jan 2024 · Clean transition, clean energy, in particular wind energy

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament)

12 Jan 2024 · Energy policy in the EU

Meeting with Morten Løkkegaard (Member of the European Parliament)

12 Jan 2024 · Climate and Energy policies

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

10 Jan 2024 · Solar farms and energy storage facilities

Ørsted urges free carbon allowances for renewable hydrogen production

22 Dec 2023
Topic — The European Commission is revising rules for free emission allowances under the ETS.
Message — Ørsted advocates for including electrified processes in the free allocation scheme to create a level playing field. They support removing the fuel-electricity exchangeability factor and allowing early allowance claims for new entrants.123
Why — This change would help reduce the current price difference between green and fossil hydrogen.4
Impact — Incumbent fossil fuel producers lose their current competitive cost advantage over renewable alternatives.5
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Meeting with Ruud Kempener (Cabinet of Commissioner Kadri Simson)

12 Oct 2023 · Interpretation of hydrogen delegated acts and financing for renewable hydrogen

Meeting with Niels Fuglsang (Member of the European Parliament)

12 Oct 2023 · Power to X

Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

12 Oct 2023 · Discuss the Hydrogen energy in general

Meeting with Maroš Šefčovič (Executive Vice-President) and

10 Oct 2023 · Hydrogen

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

6 Oct 2023 · Energy Transition

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

6 Oct 2023 · Energy transition

Meeting with Ruud Kempener (Cabinet of Commissioner Kadri Simson)

18 Sept 2023 · Presentation of Orsted's ideas to support the European wind industry

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

6 Sept 2023 · Energy transition

Meeting with Niels Fuglsang (Member of the European Parliament)

5 Sept 2023 · Klima, energi og industri

Response to Carbon capture utilisation and storage deployment

31 Aug 2023

Ørsted identified five points that are critical to enable a regulatory framework making Europe a leader in industrial carbon management: Clear distinction between geospheric and atmospheric CO2 Enshrining the mitigation hierarchy in the strategy Differentiation between carbon removals and fossil CCS Holistic CO2 infrastructure planning Coherence with existing EU legislation for BECCS
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Meeting with Ditte Juul-Joergensen (Director-General Energy) and WindEurope and

31 Aug 2023 · Energy transition

Response to Report on the implementation of Article 5 of the Renewable Energy Directive

28 Aug 2023

The RES resources and the demand for electricity are very unevenly spread in Europe, e. g., German waters have limited space compared to the German energy need while neighbors like Denmark have more offshore wind potential than what they need themselves. Therefore, national silo-solutions will not work. One simplified example: In Germany, natural gas consumption in 2021 was around 1000 TWh decreasing to 850 TWh in 2022 due to the price increases caused by the tragic Russian invasion of Ukraine. How can the 850 TWh of fossil gas be replaced? The German target for offshore wind (70 GW) can replace around one third. Germany therefore needs to look to its neighbors for green energy supply. The opening up of support schemes is trying to address this national silo-solution, and creating the ground for more European approaches. This intention is highly needed and welcome. But forcing open support schemes is not the right medicine, as it does not address the needs of the governments involved. We believe the right medicine has the following traits (inter alia): - There has to be a physical grid connection between the receiver and host of the RES project, so that the electricity can help security of supply in the country receiving the RES credits; - The scheme helps member states to overcome differences in assessment of costs and benefits; - The decline in power prices due to the additional RES capacity is also felt in the country receiving the RES credits; - The scheme can also deal with a fair cost/benefit allocation for RES projects in case of negative bidding; - Grid connection costs are incorporated into the cost/benefit allocation. Europe will lose out on many opportunities for cross-border cooperation in the offshore wind sector unless workable solutions are found. There has not been much opening of support schemes in Europe so far. In assessing why, we believe one needs to look at the fundamentals and what are the needs of the governments. We encourage the European Commission to shift its attention away from simple opening of support schemes, to schemes that solve the underlying pain-points.
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Meeting with Niels Fuglsang (Member of the European Parliament)

21 Jun 2023 · EU's grønne omstilling

Meeting with Niels Fuglsang (Member of the European Parliament) and Novo Nordisk A/S

20 Jun 2023 · EU's grønne omstilling

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

31 May 2023 · Energy Market Directive

Meeting with Emma Wiesner (Member of the European Parliament)

16 May 2023 · vindenergi och den gröna omställningen

Meeting with Niels Fuglsang (Member of the European Parliament)

16 May 2023 · (APA) Electricity Market Directive

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

9 May 2023 · Energy markets; CEO meeting under the Baltic Offshore Wind Forum; Other participants: Litgrid, Latvenergo, AST, Gasgrid Finalnd, Suomen Hyötuuli

Meeting with Niels Fuglsang (Member of the European Parliament)

28 Apr 2023 · (APA) Electricity Market Design Reform

Meeting with Nicolás González Casares (Member of the European Parliament, Rapporteur) and ACCIONA, S.A.

25 Apr 2023 · Electricity Market Design

Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans) and RWE AG and

21 Apr 2023 · Hydrogen bank

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

30 Mar 2023 · Energy Market Directive

Ørsted urges differentiated standards for carbon removal certification

23 Mar 2023
Topic — The European Commission is developing a regulatory framework for certifying carbon removals.
Message — Ørsted proposes that the scheme reflects differences between nature-based and technological projects more explicitly. Sustainability requirements should align with existing legislation to avoid burdensome regulatory inconsistency. The framework should not assume carbon re-emission immediately after monitoring periods end.123
Why — Aligning with existing rules would reduce administrative costs and facilitate project deployment.4
Impact — Private certification schemes could face reduced competition from universal EU requirements.5
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Meeting with Ditte Juul-Joergensen (Director-General Energy)

24 Feb 2023 · Energy transition and energy markets.

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

Meeting with Morten Petersen (Member of the European Parliament)

25 Jan 2023 · Energy Market Directive

Meeting with Niels Fuglsang (Member of the European Parliament) and Eurelectric aisbl

24 Jan 2023 · Energy

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

20 Dec 2022 · Energy Platform. Bulgargaz, SPP, EPH, DEPA, Geoplin, Eesti Gaas, Enovos, DEFA, Conexus Baltic Grid and GOGC participated as well.

Meeting with Maroš Šefčovič (Executive Vice-President) and

20 Dec 2022 · EU Energy Platform; Bulgargaz, SPP, EPH, DEPA, Geoplin, Eesti Gaas, Enovos, DEFA, Conexus Baltic Grid, GOGC participated as well.

Meeting with Anne Funch Jensen (Cabinet of Executive Vice-President Margrethe Vestager), Stina Soewarta (Cabinet of Executive Vice-President Margrethe Vestager)

30 Nov 2022 · State Aid and Energy.

Meeting with Morten Petersen (Member of the European Parliament)

30 Nov 2022 · Renewable Energy Directives

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

21 Oct 2022 · Commission proposal on measures on energy prices and security of supply. Innogy Česká republika and Bulgargaz also participated.

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 Antoine Colombani (Cabinet of Executive Vice-President Frans Timmermans) and ELECTRICITE DE FRANCE and

21 Sept 2022 · Energy derivatives markets

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness) and ELECTRICITE DE FRANCE and

21 Sept 2022 · EMIR review, clearing threshold

Meeting with Morten Petersen (Member of the European Parliament)

7 Sept 2022 · Renewable Energy Directive III

Meeting with Niels Fuglsang (Member of the European Parliament) and WindEurope

6 Sept 2022 · Energy

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

14 Jul 2022 · Energy Performance of Buildings Directive

Meeting with Frans Timmermans (Executive Vice-President) and Copenhagen Infrastructure Partners P/S and Vestas Wind Systems A/S

30 Jun 2022 · Renewable energy on offshore wind

Response to Greenhouse gas emissions savings methodology for recycled carbon fuels and renewable fuels of non-biological origin

17 Jun 2022

The Delegated Act (DA) assessing GHG savings from R(T)FNBOs is needed to provide the necessary standard for the renewable PtX sector to ramp-up, to deliver and contribute to climate ambitions and to security of supply. To achieve this and to take final investment decisions on first-mover projects, regulatory and legal certainty is required as soon as possible. We therefore support a swift adoption going forward. In addition, Ørsted suggests the following: 1. Recital 11: A definition of what is considered “electricity used to produce renewable liquid and gaseous transport fuels of non-biological origin” is required. This equally applies to the definition of “installation producing renewable liquid and gaseous transport fuel of non-biological origin” in the DA on Art. 27. Parts of RFNBO installations need to be supplied with electricity on a 24/7 basis (e.g., safety equipment, cooling, etc.) – this physical necessity should not hinder a production of 100% RFNBOs. The electrolysis stack is the part of RFNBO production which can operate flexibly and follow temporal correlation requirements and is also the part of electricity consumption that forms the energy content of any RFNBO. 2. Annex A (1): Heavy-duty transport (such as shipping and aviation) has very limited options to decarbonize besides using liquid renewable fuels. We therefore question the exemption for GHG emissions accounting of compression and distribution when hydrogen is directly used in vehicles only, as this incentivizes the uptake of hydrogen in light-duty vehicles over the use of renewable fuels in hard-to-electrify heavy-duty vehicles. 3. Annex A (3): Similarly to point 1, “relevant renewable energy input” needs to be defined. The same applies to “total relevant energy input”. It is not clear whether it spans the entire production value chain from e.g., electrolysis, carbon/nitrogen capture, methanol/ammonia synthesis and further processing to other fuels or chemicals. It needs to be considered that if all electricity falls under the scope, a substantial amount would not be able to comply with the DA Art. 27 (particularly the hourly correlation criterion) as parts of the production needs to operate on a 24/7 basis. 4. Annex A (4): A detailed list of what is considered a rigid vs. an elastic input would be helpful. Additionally, the risk for RFNBO producer exists that a feedstock used changes its definition over their project lifetime – the definition should therefore be determined when the production asset comes into operation. Therefore, it should be clarified that CO2 sources for RFNBO production are considered to be “existing use or fate” and are not considered to become rigid inputs going forward. 5. Annex A (6): The DAs Art. 27 and Art. 28 deploy different concepts in their methodology – member state level under Art. 28 and bidding zone under Art. 27. Consistency should be ensured by assessing everything at a bidding zone level. Additionally, the DA Art. 28 disincentivizes procuring renewable electricity as no difference is made between the GHG footprint of (non-DA Art. 27 compliant) renewable electricity (e.g., when hourly temporal correlation cannot be met) and sourcing grey grid electricity. This is counterproductive and the use of renewable electricity beyond where equipment parts such as the stack can be compliant with the DA Art. 27 with regards to temporal correlation requirements needs to be incentivized and rewarded with a lower GHG emission value than non-renewable electricity sourced from the grid. Furthermore, referring also back to point 1 and 3 of this paper, Annex A (6) is also referring to both the full load hours of “the installation producing renewable liquid and gaseous transport fuel of non-biological origin” as well as the full load hours of the “electrolyser”. There, consistency is also needed. 6. Annex A (11) (d): A definition is required on what can be defined as “previously released naturally”.
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Meeting with Niels Fuglsang (Member of the European Parliament)

30 May 2022 · Energy

Meeting with Morten Petersen (Member of the European Parliament)

12 May 2022 · Ongoing work in ITRE

Meeting with Margrethe Vestager (Executive Vice-President) and

9 May 2022 · competition and Energy

Meeting with Morten Petersen (Member of the European Parliament)

27 Apr 2022 · REDIII

Meeting with Christel Schaldemose (Member of the European Parliament)

27 Apr 2022 · Biomass

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

26 Apr 2022 · Site visit to EEW- Ørsted monopile manufacturing facility in the US.

Meeting with Pascal Canfin (Member of the European Parliament)

30 Mar 2022 · Green Deal

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

1 Mar 2022 · RED III

Meeting with Morten Petersen (Member of the European Parliament)

16 Feb 2022 · RED / Fit for 55 Package

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

12 Jan 2022 · European Strategy for Offshore Renewable Energy

Response to European Strategy on international energy engagement

20 Dec 2021

Ørsted welcomes the opportunity to provide feedback on the upcoming strategy on international energy engagement. Continued international energy cooperation will be key to mitigate climate change. While import diversification remains an important issue to address, it would be desirable to see an increased focus on making use of European competences to assist and accelerate decarbonisation efforts in regions outside of Europe. Europe has been the global pioneer in electrification and renewable energy, such as offshore wind energy- a technology with strong potential to advance climate neutrality in third countries. Overall, Ørsted sees the European strategy on international energy engagement as a very welcome initiative to widen the benefits of ambitious climate mitigation to the rest of the world. Please see the attached document for Ørsted's detailed response.
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Response to Delegated Act on cross-border projects in the field of renewable energy

18 Nov 2021

Ørsted welcomes the Commission's consultation on rules for selecting cross-border projects in the field of renewable energy. Cross border renewable energy projects will play a crucial role in meeting EU’s long term climate and energy targets. Already today, the scoping of several such projects are under development – in particular in relation to offshore wind build out in the North Sea and the Baltic Sea. A specific funding mechanism for could be highly beneficial in getting such projects off the ground. It would in this context be beneficial, if the following text was added to article three of the draft regulation: c) Cross-border transmission grid, provided that they form an integral part of a renewable energy project, effectively enabling the integration of the renewables generation facility and increasing the integration of the European electricity market; Currently offshore hybrid projects (offshore wind farms connecting to two or more markets) are not well reflected in European legislation, which currently disincentivizes the development of such projects. This needs to be addressed in market regulation, but should also be better reflected in terms of access to funding under the CEF regulation. Further, it would seem conducive to incentivize a review of the list every year, instead of only every second. Projects are being developed at a significant pace these years, and it is important that funding opportunities are adapted to meet new needs.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

18 Nov 2021

Ørsted is encouraged by the proposal for the revision of the Renewable Energy Directive 2018/2001, which was put forward by the European Commission on the 14th of July. While there is some room for small improvements, we want to underline that we believe the proposal is very well suited to help cost-effectively decarbonise the European energy system. Our 3 key messages: 1) Quotas for RFNBOs are necessary to create a European hydrogen economy. Supplying renewables for electrolysis shouldn’t be burdensome. 2) An open-door approach for offshore wind alongside tenders can help accelerate the RES build-out and enable cost competitive electricity and hence hydrogen prices in Europe. 3) Joint planning per sea basin is needed to ensure efficient planning of sufficient maritime space is allocated for offshore wind.
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Meeting with Anne Funch Jensen (Cabinet of Executive Vice-President Margrethe Vestager), Kim Jorgensen (Cabinet of Executive Vice-President Margrethe Vestager)

18 Nov 2021 · Draft State aid Guidelines on Climate, environmental protection and Energy

Meeting with Morten Petersen (Member of the European Parliament)

13 Oct 2021 · Ongoing work in ITRE

Meeting with Anne Funch Jensen (Cabinet of Executive Vice-President Margrethe Vestager), Michele Piergiovanni (Cabinet of Executive Vice-President Margrethe Vestager)

20 Sept 2021 · Draft State aid Guidelines on Climate, environmental protection and Energy

Meeting with Laure Chapuis (Cabinet of Commissioner Kadri Simson), Stefano Grassi (Cabinet of Commissioner Kadri Simson)

25 Jun 2021 · Presentation by Orsted of their ambition on RES – Fit for 55 – RED 2 review – promotion of Offshore

Meeting with Thierry Breton (Commissioner) and

3 Jun 2021 · Clean Hydrogen Alliance; regulatory framework

Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski)

1 Jun 2021 · Revision of RED II - sustainable biomass

Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton)

4 May 2021 · Hydrogen projects and regulatory aspects

Response to Revision of the guidelines for trans-European Energy infrastructure

8 Mar 2021

Ørsted appreciates the opportunity to provide feedback on the proposal of the revised TEN-E Regulation and welcomes that the Commission has presented a proposal that is further aligned with the EU climate targets. We would like to highlight the following points, in order of importance: • To ensure a sufficient and coordinated build-out of offshore grids in each sea basin, an integrated network development plan is key, and we therefore warmly welcome the proposed formulation of Article 14. The current project-by-project transmission grid build-out will not be an efficient way to accommodate a quadrupling of renewable assets, including 20 times increase in offshore wind capacity. Planning of transmission grids should in the future be based not only on confirmed build-out of generation assets, but also on the projected build-out in a 10-, 20- and 30-year time horizon. Together with the bottom up maritime spatial planning conducted by the Member States, a top down approach where Member States jointly define targets for offshore generation capacities per sea basin for 2030, 2040 and 2050 is needed to ensure that the overall EU targets are being met in the most cost-effective manner. Since offshore generation, transmission and interconnectors will be even further integrated, cooperation between Member States is of utmost importance. This needs to be reflected in a joint planning process that should be immediately initiated. • The inclusion of sustainability criteria for all infrastructure categories is welcomed. However, we would like to see renewable energy integration or CO2 reduction as the sustainability measure for all projects, and that the sustainability criterion is used as the main criterion for the regional groups’ ranking of projects and for the development of the infrastructure gap report. This will ensure that the supported projects are the ones with the greatest contribution to reaching EU's decarbonization goals, which would bring the TEN-E regulation further in line with the objective of the revision. • Discontinuing the eligibility of fossil fuel infrastructure is necessary to reach the Green Deal objectives, and we therefore welcome the exclusion of these categories. Nevertheless, it should be ensured that only investments in renewable and fully decarbonized gasses, which significantly contribute to the decarbonization of the hard-to-abate sectors, are supported within the remaining gas infrastructure categories. • Ørsted furthermore supports the inclusion of relevant stakeholders in the scenario development process, as well as the increased role of ACER and the Commission. We would however like to see formulations that explicitly include a broader set of relevant stakeholders in the process, such as electricity producers, civil society, and other stakeholders. We would also welcome further elaboration on how the input from these stakeholders is to be taken into account.
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Response to Revision of the Communication on important projects of common European interest

18 Dec 2020

The Ørsted vision is a world that runs entirely on green energy. Ørsted develops, constructs and operates offshore wind farms, associated infrastructure and innovative waste-to-energy solutions, and provides smart energy products to its customers; we are also entering the market for renewable hydrogen production. Headquartered in Denmark, Ørsted employs 5,600 people across its locations in Europe and overseas. Ørsted welcomes the opportunity to contribute to the roadmap for the revision of the communication on important projects of common European interest (IPCEIs). We strongly support the intention to align the Communication with the Commission priorities, in particular all initiatives falling under the European Green Deal. The Union that European citizens want will reduce emissions by 55% by 2030, and will be climate neutral by 2050. In this context, it is of utmost importance that the uptake of renewable energy technologies is accelerated, as only renewables will deliver a true climate neutrality. We note particularly paragraph 23 of the Communication, which states that: “Environmental, energy or transport projects must either be of great importance for the environmental, energy, including security of energy supply, or transport strategy of the Union or contribute significantly to the internal market, including, but not limited to those specific sectors.” Future IPCEIs should contribute to both Union strategies and the internal market. Else we risk developing the internal market in the wrong direction. In this respect, we note that while decarbonisation in a wide sense is a central objective of the Union, the strategies in relation to energy (such as the Hydrogen Strategy and the Offshore Renewable Energy Strategy) introduce targets and objectives for renewable energy only (i.e. “low carbon” technologies are viewed as having a transitional role), in recognition of how renewables are the most appropriate technologies to achieve the long-term objectives of the Union. These strategies also introduce an “energy-efficiency first” principle, which is also critical for an effective achievement of the climate neutrality goal. We therefore urge the Commission to ensure that the updated Communication on IPCEIs aligns with the principles of energy efficiency and renewable energy-first, to ensure that the spirit of the European Green Deal also drives what going forward qualifies as common European interest.
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Response to Revision of the Energy and Environmental Aid Guidelines (EEAG)

10 Dec 2020

Ørsted's comments to the Inception Impact Assessment on State Aid Guidelines for Environmental Protection and Energy can be found in the attached file.
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Response to Updating the EU Emissions Trading System

26 Nov 2020

Consultation response in attached file.
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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.

Response to Revision of the Renewable Energy Directive (EU) 2018/2001

21 Sept 2020

The Ørsted vision is to create a world that runs entirely on green energy. Ørsted develops, constructs and operates offshore wind farms, associated infrastructure and innovative waste-to-energy solutions as well as providing smart energy products to our customers. We are also entering the market for renewable hydrogen production. Headquartered in Denmark, Ørsted employs 5600 people across its locations in Europe and overseas. Ørsted welcomes the opportunity to contribute to the consultation on the inception impact assessment on the revision of the renewable energy directive. The consultation response is structured around the headlines below. More details can be found attached. 1. Scope 2. Renewable energy target 3. Gap filling 4. Joint projects 5. Administrative procedures 6. Renewables in heating and cooling 7. Renewables in district heating and cooling 8. Renewables in transport 9. Sustainability criteria for biomass 10. Terminology for gasses
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Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans), Riccardo Maggi (Cabinet of Executive Vice-President Frans Timmermans)

8 Sept 2020 · Offshore energy stategy

Response to Revision of the guidelines for trans-European Energy infrastructure

8 Jun 2020

The Ørsted vision is a world that runs entirely on green energy. Ørsted develops, constructs and operates offshore wind farms, associated infrastructure and innovative waste-to-energy solutions, and provides smart energy products to its customers; we are also entering the market for renewable hydrogen production. Headquartered in Denmark, Ørsted employs 5,600 people across its locations in Europe and overseas. Ørsted welcomes to opportunity to contribute to the roadmap consultation on the upcoming revision of the TEN-E Regulation. We agree that the Regulation needs to be revised and brought in line with the EUs climate and energy targets. As such, only infrastructure projects that contribute to and are compliant with EUs decarbonization targets for 2030 and 2050 should be deemed eligible for support under the new Regulation. Promoting energy infrastructure build-out will be pivotal in reaching EUs climate and energy objectives. According to the EU long-term climate strategy (“A Clean Planet for all”), the increased use of electricity will be the most important single driver for a decarbonized energy system. It follows, that investments in electricity grids that deliver cross border benefits and underpins the integration of renewable energy should be a cornerstone in the TEN-E Regulation. In this context, Ørsted fully supports the European Commission’s focus on “offshore grids for hybrid assets”. We believe such projects will be necessary to reach EU’s energy and climate targets (elaborated below). A detailed consultation response can be found in the attached file structured around the following four headlines: 1. Address backlog in electricity transmission investments 2. Hybrid projects as an essential enabler of offshore wind expansion 3. Develop hydrogen grids to facilitate decarbonization of hard-to-abate sectors 4. Improve permitting processes
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Response to A EU hydrogen strategy

8 Jun 2020

Ørsted welcomes the opportunity to contribute to the EU’s hydrogen strategy. We believe that, while direct electrification can take us a long way towards climate neutrality, sector integration, and indirect electrification through Power-to-X in particular, has a great potential to deliver decarbonisation of hard-to-abate sectors. In this regard, we wholeheartedly support the approach of prioritising renewable hydrogen. We detail our position in the attached file.
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Meeting with Ditte Juul-Joergensen (Director-General Energy)

4 Jun 2020 · Call on the COM recovery package and the offshore renewable energy strategy

Response to Union renewable Financing mechanism

3 Jun 2020

Ørsted welcomes the opportunity to provide feedback on the renewable energy financing mechanism. The mechanism, if appropriately designed, can be a useful tool for enabling further investments in a carbon neutral European energy system, as well as playing an important role in supporting increased roll out of renewable energy projects as part of the post COVID-19 economic recovery plan. The mechanism provides the opportunity to be used as a tool for landlocked countries to access abundant offshore wind resources in other member states. The mechanism could also be used to support the development of cross-border hybrid offshore wind projects (projects where the offshore wind is connected to more than one market, and where the grid connections are used both for trade and for transport of electricity generated by the wind farm). Ørsted believes that calls for expression of interest that are technology or project specific will have a greater likelihood of being successful, and the preferences of the participating member states should be respected. Furthermore, we believe that a grant in the form of a 2-way CfD (contract for difference) is the most appropriate form of support. With a 2-way CfD, the difference between the market price and the strike-price is paid to/from the developer, meaning that it effectively becomes a price-hedge for both the developer and the consumer. If electricity prices increase above the strike-price, this will provide more funding for the renewable energy financing mechanism and hence enable further buildout of renewables. The statement regarding irrevocable and unconditional commitment is important and will ensure a higher level of certainty for all participants. The possibility for the mechanism to be combined with other sources of EU funding will likely increase its effectiveness and we welcome further clarity on how this will work in practice, and whether it will be linked to the COVID-19 economic recovery plan.
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Response to Strategy for smart sector integration

15 May 2020

While existing technologies, particularly direct electrification, can (and must) take us a long way towards climate neutrality, some segments of our economy need more complex solutions. Specifically, indirect electrification via Power-to-X (PtX) can help decarbonise hard-to-abate sectors such as industry and heavy transport (shipping, aviation, and some heavy road transport). While the rationale for PtX is precisely to decarbonise these sectors, rather than to support the energy system, PtX does offer benefits for the system as well, such as integrating a growing share of variable renewable electricity by providing flexibility in various forms. The premise for an integrated energy system that enables a climate neutral future should be indeed that the focus is decarbonisation, thus putting the system at the service of energy, and not the other way around. That means that PtX should not serve as a means to avoid the necessary infrastructure developments (although it can optimise them, as we will expand on in the attached), or to deliver other system objectives; consequently, it also means that PtX should be regarded as a market activity that beyond decarbonisation, delivers services to the regulated energy assets. It also means that system integration should be pursued to the extent that it is the most cost-efficient solution to reach climate neutrality: in particular, energy efficiency should be at the centre of this strategy – meaning that energy conversions should be minimised as much as possible; where electricity can be used directly, that should be the preferred option, and removals of regulatory barriers for direct electrification should be a cornerstone of sector integration policies (although infrastructure optimisation and sector integration should also take into account costs of hardware replacement needs, such as new engines or turbines). In short, for sector integration to deliver on climate neutrality, it should be planned and executed based on the following principles: 1. The system is at the service of energy to deliver decarbonisation together and should be designed and optimised accordingly. Specifically, necessary energy infrastructure developments should be assessed and planned in an integrated manner based on their ability to deliver cost efficient decarbonisation; 2. PtX is a market activity that delivers decarbonisation, but can also provide services to the system (including flexibility in various forms) that should be remunerated as appropriate; and 3. System integration must be pursued when/where it is the most cost-efficient solution to do so, which requires that an energy efficiency principle is at the centre of the strategy. We have chosen to structure our response based on the guiding questions provided in the attached document. We are at your disposal for any queries on our response. Yours sincerely On behalf of Ørsted, Adriana Guerenabarrena Senior Regulatory Advisor
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Meeting with Thierry Breton (Commissioner) and

4 May 2020 · Impacts of the COVID-19 Pandemic on the Renewable Energy Sector

Response to 2030 Climate Target Plan

15 Apr 2020

Climate change is the defining challenge of our century. By 2030, global greenhouse gas emissions need to be halved compared to current levels if we are to stay below a global temperature increase of 1.5°C above preindustrial levels. This is the threshold set by IPCC to limit the risk of irreversible tipping points in our global ecosystems. Significant change in the way we produce and consume energy will need to happen to reach the objectives of the Paris Agreement. But with political and industrial leadership it is possible – even within a relatively short time frame and at an affordable price. An ambitious 2030 climate plan - based on the objective of climate neutrality in 2050 – is a precondition for the necessary changes in Europe. And it will underpin the front runner status of European businesses to ensure long-term competitiveness and job creation in the European Union. Attached, are Ørsted’s comments to the European Commission’s inception impact assessment for the 2030 Climate Target Plan. The comments are structured around eight headlines. 1. Technology Cost Assumptions 2. Infrastructure Needs 3. Carbon Pricing 4. Accounting of CCU under ETS 5. Deployment of Renewable Energy 6. Electrification of final energy consumption 7. Facilitating policies / Maritime Spatial Planning 8. EU/UK relations
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Meeting with Sarah Nelen (Cabinet of Executive Vice-President Frans Timmermans)

2 Apr 2020 · Hydrogen projects

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

22 Jan 2020 · European Green Deal

Meeting with Laure Chapuis (Cabinet of Commissioner Kadri Simson), Stefano Grassi (Cabinet of Commissioner Kadri Simson), Thor-Sten Vertmann (Cabinet of Commissioner Kadri Simson)

21 Jan 2020 · Discussion on European Green Deal and the offshore wind strategy

Response to EU emissions trading system – adjusting the auction process for the period 2021-2030

18 Jul 2019

Ørsted appreciates the opportunity to respond to the consultation on delegated regulation revising Regulation (EU) No 1031/2010 on EU ETS auctioning We only have one comment to this delegated regulation, and it concerns the implementation of phase 4: The possibility for Member States to voluntary cancel allowances in case of closure of fossil fuel using power plants should not be limited by the existence of an additional national measure that targets fossil fuel power plant closure. Member States might want to cancel allowances despite not having an additional national measure for closure of fossil fuel using power plants in place. The text in Annex 1 (template for the notification of voluntary cancellation by a Member State under Article 12(4) of Directive 2003/87/EC), point 5, should therefore be amended as follows (in capital letters): 5. IF RELEVANT, description and reference of the additional national measures that triggered the closure of the installation:
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Response to Evaluation of the effectiveness and policy coherence of the guidelines for trans-European Energy infrastructure

12 Jul 2019

Ørsted welcomes the opportunity to respond to your consultation on the evaluation of the EU roadmap regarding trans-European energy infrastructure (Regulation no. 347/2013, the ‘TEN-E Regulation’). We strongly think the regulation needs an update, to be aligned with political, technological and regulatory changes. We here bring 4 examples of why an update is pertinent: 1. Political change From a decarbonisation and Paris-compatible standpoint, we note with great concern that under Article 4, ‘sustainability’ is just one of the “multiple choice” criteria that a PCI should meet. In our view, the PCI status should in the future only be given to projects that have a high score on sustainability and that is compatible with meeting the Paris Agreement. Meeting the EU long-term decarbonisation commitment will inevitably translate into a (very) reduced role of gas and oil in the energy system, and that gas and oil shall be green or decarbonised (see footnotes in attachment). If such futureproofing of the PCI projects is not introduced, we risk burdening consumers with system costs for a system that will soon become partially obsolete. 2. Technological and regulatory change Regarding the scope of Regulation 347/2013 (henceforth “the Regulation”), we believe there is need to update Annex IV in line with a “collateral” update to the definitions in Article 2. Article 2 refers to definitions in other directives and regulations, in particular the Electricity Directive (Directive 2009/72/EC), which is being updated. In the updated text this Directive, the definition of ‘energy storage’ reads: ‘energy storage’ means, in the electricity system, deferring the final use of electricity to a moment later than when it was generated, or the conversion of electrical energy into a form of energy which can be stored, the storing of such energy, and the subsequent reconversion of such energy into electrical energy or use as another energy carrier. In that sense, it includes not only electricity storage (specifically batteries), but also potentially Power-to-X infrastructure. However, Annex IV remains specific to electricity storage. As Power-to-X technology, and most notably electrolysis, will be key to achieving the EU energy and climate targets for 2030 and beyond, we see it as critical that green hydrogen projects become part of the Projects of Common Interest. Furthermore, as these technologies are taking their first steps towards commercial scale, it would be sensible to include them in the PCI lists with gradual increases to their scale (i.e. relatively smaller projects accepted into the fourth list, and gradually bigger projects in subsequent lists). Such an update should then also be reflected in Annex II, deeming these projects equally eligible for Union financial assistance under Article 14. 3. Technological change Regarding definition of energy infrastructure categories, provided the importance of hybrid assets (including one or more offshore wind generator(s) and interconnection between at least two markets) as an enabler for decarbonization and given the high expectations of expansion of this configuration, we consider it necessary to include the following specific category under Article 4 and Annex II(1): ‘Hybrid infrastructure’: Offshore electricity infrastructure with dual functionality combining offshore wind energy generation and interconnectors. 4. Regulatory change Hybrid projects as discussed above, will require strong cooperation between TSOs and project developers and promoters. The membership of the hybrid infrastructure group (which would be set out in Annex III (1)) would need to reflect this (as is the case for CCS infrastructure under same paragraph).
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Meeting with Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen) and UPM-Kymmene Oyj and

7 Mar 2019 · Advanced biofuels

Response to Revision of the ETS State aid Guidelines

15 Jan 2019

Many thanks for the opportunity to provide feedback. The state-aid to compensate for indirect costs is important to keep industry and jobs in Europe. But it needs to be forward looking by enabling industry to source renewable energy. The Impact Assessment must therefore in addition to the listed activities in the inception report also assess how the Guidelines can make sure that state-aid to cover indirect carbon costs is open also for eligible industry that want to source their electricity from renewable sources: Currently there are large differences in how the Guidelines are interpreted by national authorities with regard to what constitutes an indirect carbon cost, where some wrongly assume that electricity contracts based on renewable sources cannot have carbon costs. However, market prices are steering price setting, not whether the electricity generating asset need to pay for EU ETS allowances. The current situation hence gives a strong incentive for electro-intensive industry to chose fossil electricity above renewable sources in order to keep their state-aid. This is contrary to EU objectives. Moreover, given that the situation in terms of interpretation of carbon cost differ between Member States, the internal market is distorted. The attached slides tries to explain the price-setting of long term contracts. Available for a meeting to explain at any time. Kind regards, Øyvind Vessia on behalf of Ørsted
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Response to Commission Delegated Regulation establishing the Innovation Fund

11 Jan 2019

Ørsted welcomes the opportunity to respond to your consultation on the draft delegated regulation on the operation of the Innovation Fund pursuant to Article 10a(8) of Directive 2003/87/EC. The Ørsted vision is a world that runs entirely on green energy. Ørsted develops, constructs and operates offshore wind farms, bioenergy plants and innovative waste-to-energy solutions, and provides smart energy products to its customers. Headquartered in Denmark, Ørsted employs 5,600 people across its locations in Europe and overseas. We believe hybrid solutions, such as Power-to-X, are a fundamental part of a green energy future, and on this basis, we are pleased to see a solid framework to support innovation in this area. While we are broadly supportive of the set of rules proposed in the draft, we would like to highlight the need for further clarity in certain areas. Organising the application procedure in two subsequent steps (Article 10) is an efficient solution to streamline the process both for applicants and for the Commission (or the executive agency reviewing the applications). However, given the long time lag since the last NER300 call, a more clear calendar for calls, as well as clarity on the waiting time between steps 1 and 2 of each application round, would be comforting. We understand the expectation is to set up the first call for applications by 31 December 2020 at the latest, but the duration of the application process, and the frequency of subsequent calls are unclear. It would also be worth reinforcing the intention of recital 9 into Article 12(3), to ensure that sectors that are harder, more-expensive to decarbonise are not systematically excluded when the budget is not sufficient to support all qualified projects. In that sense, we support the line of thought of recital 9, whereby the cross-sector ranking should be subsequent to the intra-sector ranking. In relation to this, and to some extent also to the second subparagraph of Article 5(1), we note that there is no prescription as to how “sectors” would be defined, particularly when the innovation does not fit within the sectors under Annex I of the Directive, e.g. in the case of substitutions (and noting that the list provided in Table 1 of the draft is an illustrative example only, outside of the body of the main text). While appreciating the potentially changing nature of these sectors, some generic guidelines on what define a sector would help secure consistency, transparency and predictability for the companies applying for funding. Lastly, while we support the “relevant costs” methodology proposed in Article 5, we think it is important to highlight that currently some innovative technologies are not granted equal footing in the market when competing against conventional technologies: Emission-free innovations that are not included in Annex I of Directive 2003/87/EC do not receive free allowances, like the technologies they intend to substitute do. A relevant specific example is the production of hydrogen with electrolysis (excluded from Annex I) versus hydrogen produced from hydrocarbons (included in Annex I, and thus receiving free ETS allowances). In the context of supporting innovation and the transition to a greener economy, beyond the Innovation Fund it is crucial that barriers like this one are eliminated. In the short term, the most viable option to attain a level playing field for green producers is via unilateral inclusion of additional activities and gases in the ETS as per Article 24 of the Directive, which however comes with regulatory lead-time for approval and hence uncertainty for operators. In any case, we would like to encourage a generalised use of this route in the short term to facilitate access to market of green producers, in particular hydrogen produced with electrolysis. In the long term, however, a wider revision of the Directive is required to create a level playing field for green players.
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Response to Free allocation of emission allowances

22 Nov 2018

We welcome the view stated in Recital 30 of the regulation, acknowledging the need to enhance incentives for emission reductions for activities that produce the same product. Furthermore, in Article 10a(8) of Directive 2003/87/EC (the innovation fund) there is reference to supporting products substituting carbon intensive ones produced in sectors listed in Annex I. This we interpret to include also emission-free products, not only the ones that emit carbon in less proportion than existing technologies. While the focus on supporting innovation and new entrants is clear, the current legislative framework leaves a gap between the support of innovation in emissions reductions and the transition of these technologies towards full market competitiveness, since free allocation is by default limited to economic operators using fossil fuels (Annex I of the Directive). As a relevant specific example we want to highlight the production of hydrogen, where the processes covered at the moment are those lying between (Annex I of Regulation): “(a) the point(s) of entry of hydrocarbon feedstock(s) and, if separate, fuel(s); (b) the points of exit of all product streams containing hydrogen and/or carbon monoxide; (c) the point(s) of entry or exit of import or export heat”. By requiring entry of a hydrocarbon feedstock, electrolysers using (renewable) electricity are, by definition, excluded from receiving free allowances, despite producing the same product. Similarly, in Annex I of the Directive, the activity covered in relation to hydrogen production is “reforming or partial oxidation”, again excluding electrolysis. In order to convert European and global industries to use green energy and green feedstocks, it is essential that at least the same incentives are in place for producing with green energy and feedstocks as for using fossil energy and feedstocks. Otherwise, the green alternatives are not given equal opportunities, with slower decarbonisation as a result. Currently, the most viable option to attain a level playing field for green producers is via unilateral inclusion of additional activities and gases in the ETS as per Article 24 of the Directive, which however comes with regulatory lead-time for approval and hence uncertainty for operators. In any case, we would like to encourage use of this route in the short term to facilitate access to market of green producers, in particular hydrogen produced with electrolysis. In the long term, however, fully realising the substitution effect (“same product”) aspired to in Recital 30 and removing regulatory uncertainty would require a wider revision of the scope of the ETS Directive.
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