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Statkraft AS

Statkraft

Statkraft is Europe's leader in renewable energy, developing and generating hydropower, wind power, solar power, gas power and district heating.

Lobbying Activity

Statkraft urges simplified EU taxonomy rules for hydropower

5 Dec 2025
Topic — The initiative reviews the EU taxonomy environmental delegated act to update and simplify screening criteria.
Message — Statkraft proposes simplifying hydropower water protection requirements by aligning them strictly with existing EU law. They argue that hydropower should be automatically considered taxonomy-aligned, similar to other renewable technologies. Furthermore, they request that biodiversity criteria apply only to newer projects to avoid administrative confusion.12
Why — This would reduce administrative costs and provide greater investment certainty for hydropower projects.34
Impact — Environmental groups may lose specific ecological protections that currently exceed standard water management laws.5
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Meeting with Lukasz Kolinski (Director Energy)

4 Dec 2025 · Post-2030 framework for continued rollout of renewables, energy security revision

Meeting with Wopke Hoekstra (Commissioner) and

4 Dec 2025 · Mr Miguel Garcia Jones, Member of Cabinet of Commissioner Hoekstra

Meeting with Bruno Tobback (Member of the European Parliament) and Invest Europe and

2 Dec 2025 · Investing into Europe’s Infrastructure Future

Meeting with Andreas Glück (Member of the European Parliament) and EUROGAS

30 Oct 2025 · Climate and Energy Policy

Statkraft urges market-based flexibility over price caps in EU energy security

13 Oct 2025
Topic — Revision of EU energy security framework for decarbonized, electrified power systems.
Message — Statkraft requests preserving market functionality and avoiding regulated price caps even during scarcity. They emphasize market-based procurement for flexibility services without bias against innovative technologies. The company advocates for technology-neutral mechanisms enabling zero-emission solutions to compete equally.123
Why — This would protect revenue opportunities for their renewable generation and battery storage assets.45
Impact — Vulnerable consumers face sustained high prices without targeted retail-level support during scarcity.67
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Meeting with Ditte Juul-Joergensen (Director-General Energy)

30 Sept 2025 · European Grids Package, Electrification Action Plan

Statkraft urges ambitious 90% emission reduction target for 2040

17 Sept 2025
Topic — The initiative will amend the European Climate Law to include the 2040 target.
Message — Statkraft supports a 90% domestic target to provide investment predictability. They want the carbon market kept central and call for faster project permitting.123
Why — High targets and carbon prices benefit Statkraft by increasing renewable energy demand.4
Impact — Nature-based removal projects lose out if they are excluded to protect carbon prices.5
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Statkraft supports expanding sectors for carbon cost compensation

5 Sept 2025
Topic — This consultation revises guidelines for state aid to industries facing high electricity costs.
Message — Statkraft favors including more sectors critical to European competitiveness and strategic goals. Compensation should be linked to requirements for renewable energy use or efficiency upgrades. They suggest using transparent criteria to assess international competition and leakage risk.123
Why — Aid for industrial consumers boosts demand for Statkraft’s renewable electricity and power agreements.45
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Statkraft Urges Priority Grid Access and Faster Infrastructure Permitting

1 Aug 2025
Topic — EU initiative to accelerate electricity grid upgrades and remove infrastructure bottlenecks.
Message — Statkraft calls for objective criteria to prioritize mature projects and reduce grid connection queues. They also recommend designating grid expansion as an overriding public interest to expedite permitting.12
Why — Faster grid access would secure commissioning dates and enhance the profitability of renewable projects.34
Impact — Speculative developers face higher costs and potential loss of capacity reservations for immature projects.56
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Meeting with Aodhán Ó Ríordáin (Member of the European Parliament)

20 May 2025 · Renewable Energy

Meeting with Marieke Scholz (Head of Unit Competition)

14 May 2025 · Discussion on the evolution of the PPA markets and the recent EU communications regarding the development of PPAs to lower the electricity prices.

Meeting with Andrea Wechsler (Member of the European Parliament) and Hydrogen Europe and Eurogypsum

8 Apr 2025 · EU energy and industry policy

Statkraft Urges Streamlined Water Rules for Hydropower Taxonomy

26 Mar 2025
Topic — The EU is amending taxonomy delegated acts to simplify sustainability reporting for businesses.
Message — Statkraft proposes aligning 'Do No Significant Harm' criteria with existing EU legislation. They specifically request clearer, simplified water regulations for hydropower production.12
Why — This alignment would reduce compliance costs and prevent mislabeling of lawful operations.34
Impact — Environmental groups may lose higher standards if taxonomy criteria only mirror existing laws.5
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Meeting with Jens Geier (Member of the European Parliament)

13 Mar 2025 · Exchange on Clean Industrial Deal

Statkraft Urges EU Recognition of Hydropower's Water Resilience Role

4 Mar 2025
Topic — The European Commission is developing a multi-annual strategy for achieving a water resilient Europe.
Message — Statkraft calls for a strategy that balances water use with the energy transition and biodiversity needs. They urge the EU to foster the multi-benefits of hydropower for climate change mitigation and adaptation.123
Why — This would validate Statkraft's renewable energy business model and facilitate future project investments.45
Impact — Environmental organizations may lose if strict water protections are bypassed for flexible energy utilization.6
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Response to Implementing Act on non-price criteria in renewable energy auctions

21 Feb 2025

Please find attached our consultation response.
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Statkraft defends market-based pricing for EU energy security

26 Nov 2024
Topic — The Commission is reviewing the EU's energy security architecture and legislative framework.
Message — Statkraft emphasizes maintaining the marginal pricing principle to ensure efficient resource use during energy crises. They also highlight the need for integrated infrastructure to enable electricity flows between markets.12
Why — Retaining market-based prices protects the profitability of their renewable energy production.3
Impact — Consumers face significantly higher costs when market prices respond to energy scarcity.4
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Statkraft seeks lean certification rules for low-carbon hydrogen

25 Oct 2024
Topic — This consultation defines the methodology for calculating greenhouse gas emissions from low-carbon fuels.
Message — Statkraft recommends using Power Purchase Agreements without additionality criteria to simplify low-carbon hydrogen production. They suggest allowing green Guarantees of Origin to calculate emissions for fuel production inputs. Finally, the company calls for the removal of the hourly matching requirement.123
Why — Simplified rules would reduce compliance complexity and lower hydrogen production costs.45
Impact — Broad grandfathering clauses would benefit fossil fuel companies while hindering climate neutrality goals.6
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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

Response to Revision of the electricity guideline on forward capacity allocation.

30 Sept 2024

With this targeted consultation, we welcome the European Commissions forthcoming impact assessment on the forward market. Given the future market developments (increased RES, bidding zones changes, changing hedging needs, etc), we believe it's an opportune moment for DG ENER to assess the current market structure and propose appropriate measures for improving hedging in the EU electricity market. Statkraft has decades of experience from the Nordic forward market which was created in response to market demands and the need for organising forward power trading in an efficient manner. The Nordic virtual hub model fits well with many smaller bidding zones with fragmented liquidity, but it may not bring added much value to continental European markets under the current bidding zone structure. Statkraft questions whether there is a strong need for a creating a virtual hub in Europe with cross-zonal products issued by TSOs as long as Germany remains one physical hub. If the market had wanted another an alternative reference price, it may have emerged already. However, the net benefits of introducing a virtual hub will likely increase in the event of the potential split of a German bidding zone. We cannot pre-empt which reference price will be preferred and whether this will be a virtual hub or an existing or future bidding zone with sufficient liquidity to use as a new proxy. Several outcomes are possible. Market participants will seek various ways to hedge and on multiple platforms (exchange, brokers, bilateral). Furthermore, the European Commission should try to avoid overly complex regulations. Despite good intentions, many regulations end up being very lengthy and detailed-oriented. We should not underestimate the regulatory fatigue and increased trading costs for small and big companies after a decade featured by many regulations and reforms (MiFID II, EMIR, CEP, EMD). The revised FCA guidelines should primarily improve hedging for fundamental players, solve existing inefficiencies in the market, as well as increasing social welfare. Lastly, future forward design should take it account that liquidity should not only be associated with LTTRs and cross-border hedging. There are many various reasons for fundamental players to hedge or not. In addition, proprietary trading plays in important role on different marketplaces in bringing liquidity and taking risks. Restricting non-hedging activities may reduce forward market liquidity and increase burdens for fundamental players in finding counterparties for their hedges.
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Meeting with Zaneta Vegnere (Cabinet of Executive Vice-President Valdis Dombrovskis)

4 Sept 2024 · - renewable electricity - NZIA - EU Trade Policy

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

2 Apr 2024

Statkrafts feedback on: Innovative forms of solar energy deployment recommendation to promote their development 2nd April 2024 Statkraft is an active developer of AgriPV in several European markets. We support the innovative use of solar technology and specific auctions where suitable. However, promoting opportunities for AgriPV or floating solar should not be at the expense of traditional deployment of solar. As well as being the most cost-effective solution, traditional ground-mounted solar deployment is often the best use of land that has been degraded by agriculture or industry; studies demonstrate how nature and biodiversity can flourish when land is rested [1]. Therefore, at the same time as wanting to see more AgriPV, Statkraft is concerned that such innovative solutions should not be regarded as the superior or sole solution. To achieve global solar targets, all solutions are needed and large-scale auctions for traditional solar deployment are central to solving the climate crisis. Whether the co-use of land is for farming or for pure ecological reasons, Statkraft advocates for all types of solar on land to retain its classification as farmland. In certain jurisdictions, the land is reclassified as industrial. This is inappropriate given there is always the option to continue farming or to revert to farming. We also see examples of land retaining its farming classification until the landowner dies at which point the land is re-classified resulting in a greater inheritance tax burden. For the energy transition to be a success, we need landowners and farmers to be supportive and to view solar as a positive use of land. Statkraft has also learned from experience in countries where land is not reclassified that this is both important and reassuring to local communities. For AgriPV, a consistent challenge is compatibility with the Common Agricultural policy. The CAP subsidies and their eligibility can vary based on Member State and its national policy frameworks. A lack of coherency and compatibility between CAP direct payments and AgriPV impacts the rollout of solar, while the purpose of those installations is to maintain and protect agricultural production. Ensuring clear guidance on CAP direct payments and its eligibility for farmers is essential. Member States should ensure farmers and agricultural stakeholders who choose to develop an AgriPV project remain eligible to receive direct support from the Common Agricultural Policy. Examples Statkraft has developed a floating solar plant at one of its hydropower sites. The solar plant comprises four floating units of 0.5 MWp each, with a total installed capacity of 2 MWp. The floating units are anchored on the Banja reservoir, near the dam of the Banja hydropower plant [2]. More about Statkraft Statkraft is a leading company in hydropower internationally and Europes largest generator of renewable energy. The Group produces hydropower, wind power, solar power, gas-fired power and supplies district heating. Statkraft is also a major international market operator. We are committed to investing 100 percent into renewable energy. Statkraft is stepping up as a developer of offshore wind, onshore wind and solar across Europe. We are active within 15 countries in Europe. [1] https://www.alphagalileo.org/en-gb/Item-Display/ItemId/242964?returnurl=https://www.alphagalileo.org/en-gb/Item-Display/ItemId/242964 [2] https://www.statkraft.com/about-statkraft/where-we-operate/albania/banja-floating-solar-plant/
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Statkraft calls for balanced qualitative criteria in renewable auctions

29 Feb 2024
Topic — Commission guidance on using non-price criteria to award renewable energy contracts.
Message — Statkraft supports a balanced combination of quantitative and qualitative criteria to award project winners. They recommend that non-price criteria should not exceed 50% of the overall weighting. The group also calls for harmonized auction designs to reduce legal challenges and delays.123
Why — This would reduce their compliance costs and protect project profitability from inflation.45
Impact — New competitors may be excluded if auctions require a lengthy track record.6
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Response to Guidance to facilitate the designation of renewables acceleration areas

23 Feb 2024

Statkraft would like to thank the European Commission for the opportunity to respond to the call for evidence to aid member states to create sustainable and efficient Renewable Acceleration Areas (RAAs) by 21. February 2026. The Accele-RES initiative will be an important contribution to the establishment of these RAAs. As Europes largest renewable energy company, Statkrafts ambition is to develop 2,500 MW of renewable energy annually, which is equivalent to delivering one new wind, solar, or battery facility every nine days, starting in 2025. As such, Statkraft view the design of the RAAs to be essential to deliver Europes sorely needed renewable capacity. Member States have been asked to define RAAs where projects can benefit from even faster permitting. This is a positive step forward if Member states manage the process well. At an administrative level, processes need to be streamlined, digitised, and staffing needs to be increased for permitting to speed up and for RAAs to be established. The proposed digital tool as part of the Accele-RES initiative will contribute to support the member states in these endeavours. See our full response attached.
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Meeting with Maroš Šefčovič (Executive Vice-President) and

15 Nov 2023 · Roundtable for Europe’s Energy Future (REEF)

Statkraft calls for integrated European hydrogen valley market

5 Sept 2023
Topic — EU strategy to double hydrogen valleys to boost domestic renewable hydrogen production.
Message — Statkraft urges the EU to adopt an integrated approach to prevent hydrogen projects from developing in isolation. They call for harmonised regulatory frameworks and physical pipeline connections between valleys to ensure a common market emerges.123
Why — Unified market rules and infrastructure would support Statkraft's ambition to significantly expand its renewable hydrogen capacity.4
Impact — Consumers could face energy supply risks if hydrogen projects remain fragmented and disconnected.5
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Statkraft urges EU support for biogenic carbon capture infrastructure

31 Aug 2023
Topic — This consultation assesses the role of carbon capture technologies in decarbonizing the EU.
Message — Statkraft requests a common framework and financial support to mature the entire CCUS value chain. They advocate for market-based incentives specifically covering both fossil and biogenic carbon emissions. Furthermore, they call for non-discriminatory access to European transport routes and storage hubs.123
Why — This framework would mitigate investment risks and secure infrastructure access for their waste-to-energy plants.45
Impact — Existing polluters might see weakened incentives if biogenic certificates reduce the carbon price.6
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Response to European Critical Raw Materials Act

27 Jun 2023

The Critical Raw Materials Act aims to ensure EU access to a secure and sustainable supply of critical raw materials, enabling Europe to meet its 2030 climate and digital objectives. Statkraft underlines the critical need to ensure sufficient and diversified access to Critical Raw Materials to succeed with the energy transition to renewables. This needs to be sustainably and equitably sourced to the highest extent possible. There are challenging trade-offs for permits to renewable deployment, manufacturing deployment and sourcing of raw material in Europe. The largest bottleneck for both renewable deployment, manufacturing and increased sourcing of raw materials in Europe is the limited amount of land available resulting in difficult permitting processes. Permitting both for renewable power plants, as well as grid, is slowing down the imminent need for this crucial build out. Furthermore, the raw material extraction and processing is proposed to access faster permitting process on par with renewables with this act. Combining these buildouts, with increased manufacturing capacity while restoring nature and biodiversity will be a challenging trade-off for authorities across Europe. Statkraft would underline that cost and resource efficiency must be properly evaluated within this context. The proposal stands to make environmental information from our suppliers more accessible and visible, such as the exact use of key raw materials, extraction countries, and environmental footprint assessments. This type of information can simplify our supplier evaluations and provide us with better information available from public sources. This, in turn, strengthens our own footprint from an LCA (Life Cycle Assessment) perspective, and it will make it easier for us to assess and set environmental requirements for our suppliers. The proposal will increase the focus on recycling key raw materials in the countries where we operate, ultimately leading to better solutions and opportunities for recycling and responsible handling of our equipment at the end of its life. This can also create possibilities for collaboration across value chains to achieve good solutions, with strong support from the authorities. However, the new proposed rules still retain a risk for increasing the administrative burden. Increased reporting requirements have the potential to drive up costs for businesses, organizations, and the energy transition itself. A balance should always be strived to achieve the stated targets. Please see attached Statkraft response to both Net Zero Industry act and the Critical Raw Materials Act.
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Statkraft urges inclusion of hydropower in Net Zero Act

27 Jun 2023
Topic — The consultation addresses the Net Zero Industry Act's framework for manufacturing green technologies.
Message — Statkraft requests that hydropower be officially designated as a strategic technology. They call for an impact assessment on auction rules and keeping cost-based exemptions.12
Why — This would protect their hydropower business and prevent new regulations from increasing development costs.34
Impact — Consumers lose through higher prices and slower transition if restrictive rules inflate renewable energy costs.5
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Statkraft Urges Market-Based Reforms and Rejects Permanent Revenue Caps

23 May 2023
Topic — Revision of the European Union's electricity market design to improve resilience.
Message — Statkraft advocates for market-driven investments instead of permanent revenue caps on energy. They request the continued use of specific financial tools for the Nordic market. They also oppose a new central database for electricity contracts.123
Why — Removing revenue caps would protect the profitability of their hydropower and renewable investments.4
Impact — EU regulators would lose direct investigative powers and centralized data on energy contracts.5
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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

Response to Effectively banning products produced, extracted or harvested with forced labour

30 Nov 2022

Please find Statkraft's consultation response attached.
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Meeting with Kadri Simson (Commissioner) and

27 Oct 2022 · Future of renewable power generation in Europe, engaging with Norway on development of renewable energy capacity and integrating it in EU's energy system.

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

Statkraft Urges Non-Binding Targets for EU Nature Restoration

22 Aug 2022
Topic — This consultation proposes legally binding nature restoration targets to put European biodiversity on the path to recovery.
Message — Statkraft suggests using a less stringent directive without legally binding targets instead of a regulation. They propose incorporating socio-economic considerations and holistic cost-benefit assessments into national plans.12
Why — A less stringent tool would reduce administrative burdens and protect existing energy infrastructure.3
Impact — Environmental organizations lose if the EU adopts weaker measures based on less alarming data.4
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Statkraft Urges Faster EU Permitting and Grid Infrastructure Upgrades

27 Jul 2022
Topic — EU guidance on accelerating permitting for renewable energy and power purchase agreements.
Message — Statkraft calls for harmonized permitting procedures and stricter deadlines to accelerate renewable deployment. They suggest increasing authority staffing and digitalizing administrative processes. They propose including grid infrastructure in rules to prevent energy bottlenecks.12
Why — This would reduce administrative obstacles and accelerate the deployment of renewable investments.3
Impact — Speculators lose the ability to reserve land cheaply through proposed financial commitments.4
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Response to Regulation on REPowerEU chapters

20 Jul 2022

Statkraft appreciates the Commission’s work to strengthen Europe’s energy security and proposals on how to align existing legislation as a response to the Russian invasion of Ukraine and its consequences on energy markets. Statkraft supports that Member States should modify their Recovery and Resilience Plans (RRPs) to include a REPowerEU chapter. We fully agree that renewables are core to lower Europe’s energy import dependency and prevent future price crises. We are convinced that Europe can accelerate the deployment of renewables. We support the RRPs to address internal and cross-border energy transmission bottlenecks. Including grid measures in the RRPs could optimise the integration of new renewable energy projects without delays. Green hydrogen is core in REPowerEU and a key pillar for decarbonisation. However, the strict requirements on additionality, temporality and geographical correlation in the Commission’s proposal for a delegated regulation for the production of renewable transport fuels of non-biological origin from electricity (DA on RFNBO) will make it difficult to realize hydrogen projects. Such proposals directly contradict the targets in REPowerEU and the EU hydrogen strategy. Preventing use of existing renewables to produce green hydrogen makes neither economic nor environmental sense. Requiring green hydrogen to only be based on new, expensive renewable power will hinder the early market ramp up for green hydrogen. Statkraft appreciates that the REPowerEU plan does not propose profound changes in market design. Providing the same price signals regarding consumption and production to all market participants is the best mechanism to ensure efficient use of resources and coordination of supply, demand and transmission. While we fully support the Commission’s proposed measurements to mitigate the price effects on vulnerable consumer groups, we caution against fundamental changes in market design. Statkraft supports prolonging the 24% intake rate to the MSR until 2030. While we understand the need for more financial resources for the RRF we warn against the negative consequences of auctioning allowances held in the MSR to raise revenue for the RRF. 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. It would also weaken Member States’ revenues rather than generating new funds: 1)Reinjecting around 250 million EUA up to 2026 significally impacts the market, as illustrated by the more than 10 % EUA price drop after the proposal was made. Investors would expect this type of ad-hoc measure to be used again, which would jeopardise confidence in the EU ETS as the most cost-efficient instrument for decarbonization. 2)Reinjecting allowances from the MSR that were destined for invalidation as from 2023 will increase fossil fuels consumption and weaken the carbon price signal. Further, the ongoing legislative process on the EU ETS (and MSR) revision would have to consider the impact of this measure. Such reinjection will increase the surplus over the next few years, which will partly be absorbed by the MSR at a later point, leading to a sharp increase of the carbon price at the end of the period. If these EUAs are not withdrawn later, the carbon budget will remain high until 2030 thus limiting the incentive to decarbonise the EU economy. 3)A financial target introduces more uncertainty to the ETS as more EUAs need to be auctioned to raise €20 billion the lower the EUA price is. This will reduce the overall auction revenues for all all allowances, and hence redistributing from MS, and increase the investment gap needed to reach the EU climate targets. Statkraft understands the need to generate resources to the RRF, but proposes to look into other financial and resdistributive measures.
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Response to Revision of EU rules on Gas

12 Apr 2022

STATKRAFTS CONSULTATION RESPONSE ON THE HYDROGEN AND DECARBONISED GAS MARKET PACKAGE Statkraft refers to the European Commission’s proposed revision of the Directive of the European Parliament and Council no. 803/2021 on common rules for the internal markets in renewable and natural gases and hydrogen and the Regulation of the European Parliament and Council no. 804/2021 on the internal markets for renewable and natural gases and for hydrogen. Statkraft supports the overall objective to create a competitive, sustainable market for renewable and low-carbon gases, including hydrogen. Hydrogen and derived fuels will be central in providing hard-to-abate sectors like heavy-duty transport, agriculture and industry with climate-neutral fuel, feedstock and fertilisers through sector integration and indirect electrification. Discussions about sanctions against Russian fuel exports as a reaction to the brutal ongoing war in Ukraine illustrate the importance of substituting fossil fuels in all sectors, including the hard-to-abate sectors. This will require great investments into renewable capacity deployment. Statkraft welcomes the RePowerEU’s strong push for accelerating hydrogen production in Europe, and we believe it is important to accelerate the development of an integrated European gas and hydrogen infrastructure in order to meet these ambitions Statkraft has elaborated on our comments in the attached document. Our main comments concerns: 1. The use of definitions must be consistent Developing clear and distinct definitions that can be applied consistently across EU legislation provides important and much needed legal clarity. This is particularly important for the development of a well-functioning hydrogen market. 2. The revised Gas Market and Hydrogen Directive Article 8 on certification needs to be more fit for purpose Certification is used for several purposes. To document the final share of renewables in national energy consumption, Member States need to document national energy production. At the same time, customers increasingly want to be able to document the carbon footprint of their consumption. Economic operators then must deliver on two distinct documentation objectives. The same documentation criteria are not suitable for both purposes. 3. Certification criteria for renewable gases of non-biological origin should not include additionality requirements We believe that additionality requirements will have an inhibiting effect on the hydrogen market ramp up. It is important that products produced using existing renewable production capacity are classified in the same category as products produced using new renewables. 4. Unbundling ensures fair competition Statkraft is of the opinion that unbundling should be carried out strictly. The objective of unbundling is to remove incentives for network operators to discriminate against competitors as regards to network access and investments. It is important to have requirements for legal and functional separation which ensures a competitive market for storing gas and hydrogen. 5. Non-discriminatory market access is crucial for the development of a well-functioning hydrogen market Equal market access for gas and hydrogen players is important for the development of a renewable gas and hydrogen market. Statkraft believes that a non-discriminatory, tariff-based system for market access must also be a requirement for hydrogen earlier than 1 January 2031. 6. Blending Facilitating a limited percentage of blending in Europe’s natural gas network can be an enabler for the development of the hydrogen economy and contribute to meet targets for decarbonisation. However, it is important that the blended hydrogen is produced from renewable sources and that that we avoid lock-in of new gas capacity.
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Response to EU Solar Energy Communication

12 Apr 2022

See attached document.
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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 Review of Directive 2012/27/EU on energy efficiency

19 Nov 2021

Statkraft AS refers to the European Commission’s consultation on the Energy Efficiency Directive (EED) (2018/2002). We believe that energy efficiency is a crucial part of the solution. For the revision of the directive we emphasise the following points: • Energy efficiency targets and measures must not hinder the increased use of clean electricity which is important to substitute fossil fuel use and decarbonize our economies. Electrification also enhances energy efficiency because electricity is a very efficient energy carrier. • The use of the primary energy factor should not prevent increased use of renewable energy Statkraft supports the introduction of the "energy efficiency first" principle. Multiple sectors have significant potential for energy efficiency and the ongoing transition to renewable energy depends on both energy efficiency measures and increased use of renewable energy to replace fossil energy based on cost-effective criteria. It is important that a cap on final energy use does not prevent the transition to fossil-free energy. It is therefore unfortunate that the directive's energy efficiency targets are set as a cap on final energy use instead of measures for energy or carbon intensity. It should be considered that countries in the EU have different energy systems. Energy efficiency targets or energy efficiency measures should not hinder the electrification of power intensive industries in countries with an already high proportion of renewable electricity. Similarly, energy efficiency targets should not limit the use of renewable energy for the production of renewable fuels and energy carriers through electrolysis, pyrolysis or other power-intensive technologies that can have great significance for the green transition and value-creation in the renewable energy system. We are positive to the opportunity provided by the directive for a large degree of flexibility in national adaptations, allowing each country to adapt the implementation of the directive to national energy and climate policy. Statkraft notes that a new Article 20 is being introduced on contract rights for the heating and cooling sector and that the requirement covers both households and businesses. We do not object to this proposal but point out on a general basis that there is less need to protect professional actors through the use of such regulations and that the freedom of contract should be safeguarded as much as possible for these customers. We support the requirement in Article 23 giving the public the opportunity to provide input to the design of heating and cooling plans at regional and local level. We are also positive to the more stringent requirements for the use of renewable energy and waste heat in the heating and cooling sector. Article 24 requires increased measures for renewable energy, waste heat and thermal heat in the district heating network. These requirements are mainly related to combined heat and power plants based on fossil base load (cogeneration), of which we have very little in Norway. Sweden and Norway are examples of countries where the waste incinerated is the residual after sorting out recyclable fractions such as paper, plastics, glass and metal. Therefore, it is very important that waste heat from waste incineration (Waste-to-heat) is defined as carbon neutral or renewable. Article 25 requires that energy efficiency shall be central to grid development and design of grid tariffs. We support this principle but would like to emphasize again that energy efficiency goals should not be an obstacle to the electrification of society and the efficient development and utilization of the electricity grid. The use of the primary energy factor should not be an obstacle to increased use of renewable energy.
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Response to Revision of Alternative Fuels Infrastructure Directive

18 Nov 2021

As Europe’s largest renewable energy producer, Statkraft is committed to contributing to the EU becoming climate-neutral by 2050. Together with Mer Group, fully owned by Statkraft, our ambition is to become a leading European e-mobility company by providing innovative and renewable solutions and contribute to the European shift towards electric mobility. We consider it important to enable growth of alternative fuels, in particular, to enhance the growth of electric vehicles. Deployment of publicly available charging stations is necessary to support the expansion of electric vehicles. Location is a key aspect to increase the usage of charging stations. To realize the substantial investments in charging and enforced grid infrastructure we need a predictable and effective policy framework and ambitious targets. Equally important is strengthening and simplifying access to required grid infrastructure, such as the proposed power output targets. For the development of charging infrastructure we support market principles, but financial support may be needed to develop sites with low traffic or in densely populated areas of strategic importance. A free market with competition will enable market players to develop the needed technology and innovative solutions, such as smart charging, and will result in user friendly and attractive solutions . Green hydrogen can contribute to emission reductions in the transport sector and we welcome initiatives supporting the deployment of hydrogen refuelling infrastructure to serve large vehicles. We support the establishment of a minimum number of hydrogen refuelling stations along the TEN-T network and in each urban node. We welcome the principle of providing end users with the ability to recharge their EVs on an ad hoc basis, as defined in article 5.2. In today’s digital world, and even more so in the future, the payment solutions will be contactless and digital. Ad hoc users are already able to pay via an app, also with a credit card reader, in addition to other digital payment solutions. We see no or limited need from the user side to pay via a fixed terminal at the charging station. Current physical payment systems are costly and would increase hardware cost substantially and thereby increasing prices for end customers if introduced as an obligation. We recommend keeping the option to use “devices using an internet connection with which for instance a Quick Response code can be specifically generated and used for the payment transaction” also for chargers above 50 kW and open up for use of digital payment solutions. Article 5.4 defines how pricing shall be reasonable and clearly comparable and non-discriminatory. We support non-discriminatory pricing and we would like to specify that as in any other market and commodity there are different price regimes and structures, such as customer loyalty schemes and partnership agreements. The market should be allowed to operate freely, including for price schemes. Regarding the display of the pricing, we support the development of digital communication matching the future demands of the customers and we oppose the requirement for a physical sign on site. In reference to Article 18, we would like to emphasize that when developing and operating a charging station there are several players involved with different roles of which the landowner is the one responsible for parking. It would therefore not be appropriate for the charging operator to be designated as the actor responsible for providing data.
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Response to Carbon Border Adjustment Mechanism

18 Nov 2021

Statkraft is positive to the introduction of the CBAM. As Europe’s largest producer of renewable energy, we are exposed to changes in the policy framework on climate within the EU and the introduction of CBAM affects Statkraft both directly and indirectly. Of particular importance is the price development in the ETS, which directly affects the price of electricity by increasing the marginal cost of fossil power production. In order to ensure legitimacy for a high price on allowances, it is important to have effective measures against carbon leakage. • For Statkraft, it is important to point out that a CO2 border adjustment mechanism is not an end in itself but should be a means to facilitate a stronger climate policy and, in particular, a tightening of the ETS. It should be designed in a way that provides the greatest possible climate effect, while minimizing the cost in terms of trade barriers and bureaucracy. It is therefore important that: o The mechanism is WTO compliant, o That the mechanism proves incentives for other countries to strengthen their climate policy, o Is implemented in the least bureaucratic way possible. • For industries facing global competition, increased costs related to climate measures and high carbon prices can lead companies to relocate production or close down. Such carbon leakage might lead to increased emissions if production is moved from countries with relatively low emissions to countries with weaker climate policies, and weaken support for climate measures if it leads to job loss. Today, the problem is solved through the allocation of free allowances and CO2 compensation for indirect costs. Statkraft believes that there are several good arguments for replacing current instruments with a CO2 border adjustment mechanism: o Such mechanism can help third countries strengthen their climate policies in order to keep the revenues from carbon pricing nationally and avoid obstacle sin trade with the EU. o Free allocations of allowances and CO2 compensation weakens the price signal from the price of allowances, by gradually replacing these instruments with a CO2 border adjustment mechanism, the ‘polluters pay’-principle will be strengthened. o Gives increased income to national authorities through the sale of both CBAM allowances and from the auctioning of allowances that were previously allocated for free. o Ensures that the price of imported goods reflects the climate impact from production • Statkraft owns and operated two hydropower plants in Albania in addition to a project on floating solar power. This business can be directly affected by CBAM, as part of the electricity is sold at spot prices to EU countries. For countries with a high share of renewable energy, such as Albania, the introduction of CBAM on power exports will weaken the incentives for further development for exports to the EU. This challenge can be solved in several ways: o Exclude countries with low CO2 content in power production from CBAM. As long as the aim is to avoid CO2 imports, imposing a tax on countries with low CO2 intensity in the power mix will only contribute to weakening the incentives to invest in new, renewable energy. o Negotiate with countries outside the EU on regulatory measures that can implemented to avoid introducing CBAM. o Use the country's actual carbon intensity in the power mix and not the regional power mix as a basis for CBAM • Statkraft has several projects where we are studying opportunities for industrial production of hydrogen in Norway, notably on Herøya and in Mo i Rana. For the development of industrial value chains for hydrogen, we see that the current compensation schemes are essential. If a CBAM on hydrogen becomes relevant, options should be studied carefully to avoid carbon leakage. If the CBAM is extended to also include indirect emissions, there should be a gradual introduction with a corresponding gradual phasing out of support systems.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

18 Nov 2021

Statkraft refers to the European Commission’s proposal for a revised Renewable Energy Directive and provides feedback on the following topics. Further elaborations on these topics can be found in the attached document. • Well-functioning power and carbon markets are essential to ensure profitability in renewable energy We believe that a strong and effective EU ETS (which will also be revised) is most important in order to be able to also achieve the renewable goals in a cost-effective way. Well-functioning power and carbon markets are essential to ensure profitability in renewable energy and facilitate efficient resource utilization, and other measures should therefore be adapted to this framework. They should therefore not be weakened through new regulation. • Rapid implementation of the revised changes to the ETS is important to provide predictability and ensure an efficiently integrated energy market. • Important role for hydropower: Hydropower plays an important role in the energy system by providing the flexibility and system services – in addition to providing renewable electricity - needed to enable a more extensive use of other renewable energy sources. We believe that it should be reflected to a greater extent in the further work on the Directive. • Support for new renewable target of 40%: While the costs of renewable energy technologies have fallen sharply in recent decades, the massive development required in a short time may not only be realized through market forces and there may be a need for incentive systems. • Stimulation of demand for renewable energy drives development: If there is a need to increase the development of renewable energy beyond what can be achieved through ETS, incentives should be directed towards increasing the demand of renewable energy in the end-use sectors. • Maintain freedom of contract: Statkraft supports the goal of increased use of PPAs but emphasizes that regulations should not restrict the parties' freedom of contract, for example by imposing the use of standardized contracts. • Documentation and certification must be strengthened To meet the increasing demand for documentation of renewable energy and sustainability along the value chain. • The network infrastructure is crucial for offshore wind: The proposal for joint planning of offshore network infrastructure is positive but needs more clarity on the coverage of sea areas, and planning across borders and on- and offshore areas. • National considerations for renewable targets in heat and biofuels: We ask for national adjustments of the targeted annual increase in the share of renewable energy in heat and biofuel for countries with a very high share of renewable energy. Further, waste heat (and electricity production) from waste incineration plants should be classified as climate neutral or renewable in the same way as waste heat from other industries. • Supports goals for the transport sector: We are positive to the increased level of ambition for renewable energy in the transport sector and the extension of the discussion of renewable fuels of non-biological origin to other sectors and areas of use beyond the transport sector. • Coordinated proposals for hydrogen and additionality: For the investment in hydrogen, it is important that the principle of additionality is removed from the directive and associated delegated acts. All renewable generation, both old and new, supported and unsupported, is equally renewable and should be accountable for the production of green hydrogen. Hydrogen is an important focus area for the Commission and the member states. Statkraft would like to see a more comprehensive "treatment" of hydrogen, which is now discussed and regulated in several different directives.
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Response to Revision of the CO2 emission standards for cars and vans

8 Nov 2021

Joint response by Statkraft and Mer to public consultation: CO2 emissions for cars and vans - revision of performance standards As Europe’s largest renewable energy producer, Statkraft is committed to contributing to the EU becoming climate-neutral by 2050. The Mer Group is fully owned by Statkraft. Mer’s ambition is to become a leading European e-mobility company by providing innovative and sustainable solutions and contribute to the European shift towards electric mobility. Statkraft and Mer support the ambitions of the Fit for 55 and the proposals to tighten the CO2 emission reduction targets for new cars and light commercial vehicles. We welcome the increased emission reduction ambitions and the proposal of an effective ban of new fossil-fuel cars from 2035. Both companies encourage measures aiming to enhance regulatory clarity. Setting an explicit phase-out date provides certainty for both consumers and industry, which is important in order to accelerate the deployment of zero- and low emission vehicles in Europe. In our view, electricity production from renewable energy sources must grow significantly if the ambition of zero emissions is to be achieved. Hence, incentivising the use of clean electricity across sectors is important. For the road transport, we encourage stronger incentives for increased production and demand for zero-emission cars and vans. Regulation should target the whole value chain, from vehicle manufacturing and vehicle components (i.e. batteries) to the development of relevant infrastructure (electricity grid and charging points). The roll-out of hydrogen and electric vehicles in Europe will require substantial investments in infrastructure. Due to large system and cost barriers, investments in EV infrastructure will be more demanding in countries with weaker power grids. Clean hydrogen will be highly relevant for vans needing longer range and time-efficient refuelling, being also well suited for heavy load transport where batteries are impractical because of low density and high weight. The choice between battery or hydrogen powered vans mainly depends on driving time, load and flexibility needs.
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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

Statkraft input to the public consultation for the updating of the Effort Sharing Regulation (ESR) Statkraft is Europe’s largest provider of renewable energy. We have for long been a vocal supporter of a strong EU Emissions Trading System (ETS) as the most efficient tool for driving the transition of the European energy system in a technology neutral and marked-based manner. The ESR currently covers sectors not covered by the ETS, by giving Member States individual targets that in sum ensure the overall target for emissions reduction in the EU to be achieved. The various countries have been assigned different reduction targets based on, among other things, economic factors. Norway has been given such a target through an agreement with the EU. Under the ESR member states are free to choose the instruments for realising emission reduction. However, strong guidelines for how quickly the emissions reductions have to be implemented are provided by the Regulation through country-based, annual emission budgets with limited flexibility. The ‘Fit-for-55’-package proposed the continuation the main features of the ESR, with the adaption of reduction targets to the EU’s new targets for 2030. Statkraft supports this approach. In the ‘Fit-for-55’-package, it is also proposed to introduce a separate emissions trading system for road transport and buildings, which together account for around half of the emissions currently subject to the ESR. It is proposed that these sectors should remain a part of the ESR. Both on the EU- and national levels several measures are already in place, also aimed at reducing emissions in the road transport and buildings sectors, such as energy efficiency requirements for the construction sector and requirements for CO2-emissions standards for new passenger cars. With the introduction of a separate emissions trading system for these sectors, a market-based harmonised approach across the EU/EEA area will also be introduced on emitting CO2 in these sectors, with the price decided by the market. Statkraft wishes to emphasize the importance of a coherent approach to the various measures in these sectors in order to ensure that emission reduction measures can be implemented in an effective manner. We would like to add that electrification, both directly and through the use of heat pumps and hydrogen, will be important in order to reduce emission in the sectors covered by the ESR. In practice, this will mean that energy-related emissions from the ESR-sectors are transferred to the power sector and thus regulated by the ordinary ETS. A well-functioning ETS will be important to ensure that this leads to actual emission reduction.
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Response to Strengthing the Market Stability Reserve linked to the review of the EU Emissions Trading System

8 Nov 2021

Statkraft input to the public consultation for the updating of the EU Emissions Trading System: Maintaining an efficient and functional stability mechanism (Market Stability Reserve) Introduction Statkraft is Europe’s largest provider of renewable energy. We have for long been a vocal supporter of a strong EU Emissions Trading System (ETS) as the most efficient tool for driving the transition of the European energy system in a technology neutral and marked-based manner. Comments on proposed changes The stability reserve was introduced to make the price level in the ETS less sensitive to external conditions, such as macroeconomic shocks. The background was, among other things, the significant reduction in demand for allowances due to lower economic activity during and after the financial crisis, which led to the collapse of the price for allowances and the price signal from ETS having little practical significance for European emissions. With the stability mechanism, 24% of the total number of emission permits in circulation (TNAC) will be transferred to the Market Stability Reserve (MSR) if TNAC exceeds 833 million allowances. The current regulations state that the transfer to MSR will be reduced to 12% in the period 2024-2030. Furthermore, the regulations states that if TNAC goes below 400 million, 100 million allowances will be taken out of the MSR and auctioned. If the total volume of MRS exceeds the annual quota volume, the excess share must be cancelled. The revised directive proposes that the share of TNAC to be transferred to the stability reserve should be 24% throughout the period up to 2030. A “buffer zone” is also proposed for when the stability mechanism is activated – the full 24% are only activated by a TNAC at 1095 million, while a lower amount of transfer will already take place at 833 million. Statkraft supports the continuation of the stability reserve. It is important that the transfer to the stability reserve is set at 24% throughout the period up to 2030, to strengthen the stability mechanism. However, the introduction of the new threshold, where full transfer will not be reached until TNAC reaches 1096 million, will mitigate this effect. Since the stability mechanism was established, TNAC has been at a level at around 1000 million. With continued TNAC around this level, the withdrawal rate would be lower than currently, and the MSR will be somewhat weaker. The full effect of the proposed stabilisation mechanism will thus not be activated until a level of TNAC is reached which we barely have seen so far. The draft directive proposes that the stability mechanism should be revised every three years. Statkraft supports this but would like to emphasize that it is important that these revisions aim to ensure the continuation of the main principles of the mechanism. Tightening of the annual supply of emission permits will be important for TNAC. Changes in the behaviour of actors in the emissions trading market, for example through reduced use of allowances for price hedging in the power market, can also affect the TNAC. New EU and national regulations also aiming at emission reductions in ETS sectors will result in lower demand for ETS allowances. Without a sufficiently strong stability mechanism this could result in excess supply of allowances and weaker price signals from the ETS. It may therefore be appropriate to assess the limits for activating the stability mechanism in future revisions.
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Response to Updating the EU Emissions Trading System

8 Nov 2021

Statkraft input to the public consultation for the updating of the EU Emissions Trading System Introduction Statkraft is Europe’s largest provider of renewable energy. We have for long been a vocal supporter of a strong EU Emissions Trading System (ETS) as the most efficient tool for driving the transition of the European energy system in a technology neutral and marked-based manner. Comments on the proposed changes • Adjustment of the Linear Reduction Factor The new draft directive proposes the annual linear reduction factor to be increased to 4.2% to be in line with the new reduction target of 61%. Statkraft supports this approach. Statkraft also supports the proposed introduction of a rebasing mechanism to ensure that the ETS will be just as tight even if the decision to implement the changes is delayed. The volume of the rebasing should be defined depending on the time of implementation to ensure that the total cap remains in line with an early -preferably from 2021- implementation of a higher LRF . Together with the deletion of the excess discharge permits, this will ensure that the actual reduction in emission is the same regardless of when the legislation is implemented and can be an incentive for early action. We want to note that early action underpins the political commitment to strong carbon prices and urge that the proposal is swiftly implemented. We prefer this approach to the earlier presented alternatives to the proposed solution, such as applying a relatively lower LRF from a lower level (so-called "rebasing") or using a higher LRF without rebasing. Measured in total emissions, different combinations of rebasing and reduction factor could give the same results as what the proposed model provides. • Extension of the ETS to new sectors The Commission proposes to extend the ETS to shipping, road transport and buildings, with shipping included in the current ETS, while a separate system for road transport and buildings will be established. In principle, Statkraft would like to see a price on emissions that is the same across as many sectors as possible. Therefore, we support the proposed extensions to include shipping. From this perspective, it seems unfortunate that road transport and buildings will exist as a separate system with different carbon prices than in the original scheme. However, abatement costs in both road transport and building sector are higher than in the sectors currently covered by the ETS. This would require higher ETS carbon prices in order to result in emission reductions in these new sectors. Further, other policy instruments to reduce emissions have already been introduced in the transport and building sectors. This implies that these sectors are less sensitive to additional carbon prices or that carbon prices would have to be very high in order to be effective. Given the political sensitive nature of these sectors and potential negative social impacts from a sudden rise in prices for transport and heating this would be challenging. Therefore, Statkraft believes that the introduction of a separate trading system for these sectors, in combination with the continuation of other instruments, is a good solution. However, we want to emphasize that over time these additional instruments should be reduced and/or aligned with carbon prices and upgraded ambitions, to facilitate the integration of these sectors into the existing ETS in the longer run. Emission reductions in both road transport and building sectors will largely take place through electrification (directly, by heat pumps and hydrogen), and emissions from these sectors will gradually be transferred to the original ETS system. Electrification will increase demand for electricity, and the cap on emissions under the original ETS will be important to ensure that electrification does not lead to increased emissions.
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Response to Commission Delegated Regulation on taxonomy-alignment of undertakings reporting non-financial information

1 Jun 2021

We welcome the delegated act that clarifies the disclosure obligations following the taxonomy, and we appreciate the opportunity to comment on the proposal. The comments we have are: 1. Article 9, 3. It is stated that in the financial report the key performance indicators covering the previous five reporting periods should be provided. Assuming that this does not apply retroactively, this should be stated. If, on the other hand, it is intended that five reporting periods should be provided as of the first reporting, we find this requirement too extensive and propose that it does not apply retroactively. 2. Annex I, 1.1.2.1 A list of standards is provided, but could CapEx beyond these be included? E.g. construction projects that are classified as inventories as they will be divested at the time of completion. 3. Annex I, 1.1.3.1 It should be clarified whether overhead cost allocated to the activity should be included in OpEx. Finally, as the disclosures delegated act will come into application from 1 January 2022, we urge that a final version of this delegated act will be available as soon as possible.
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Meeting with Thor-Sten Vertmann (Cabinet of Commissioner Kadri Simson) and Fortum Oyj and Vattenfall

27 May 2021 · Contribution du secteur électrique dans le cadre du paquet Fit for 55%.

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

8 Mar 2021

See attachment. Scope of TEN-E TEN-E is a regulation regarding infrastructure that gives advantages such as accelerated permit granting, certain regulatory measures, and possibility to EU financial assistance. We believe the main object of the revised TEN-E regulation should be to regulate infrastructure with cross-border effects. By including infrastructure that is in the competitive domain and sometimes with no or little cross-border effects, the number of possible projects for PCI (or PMI) will increase substantially, making it more difficult to give priority when an increasing number of projects are covered by the regulation. Important to keep separation between market based and regulated assets We believe an important basis for a well-functioning internal energy market is to separate between assets which should be part of the competitive part of the energy market (=market-based asset: assets where the commercial risk is taken by the companies), and those that need to be part of regulation (regulated assets: assets where the business risk is socialized, for instance by TSO and DSO ownership). As long as necessary assets can be built as market-based-asset, the regulation should not open up for TSOs or DSOs to build and own these as regulated based assets, with reference to Market directive 2019/944, art 36 and 54 about ownership of storage. TEN-E gives ENTSO a responsibility to propose both cost-benefit analysis as well as infrastructure gaps identification. In the latter they shall ”consider with priority all relevant non-infrastructure related solutions to address the identified gaps”. We believe it is challenging that the entities responsible for the regulated and monopoly part of the energy system is given this responsibility for possible development of assets which should be market-based assets. In our opinion this also contributes to reduce, and may in some cases even erase, the difference between the competitive and regulated part of the energy system. Electricity storage and electrolysers should not be part of TEN-E Our impression is that the justification to include electrolysers above 100 MW and electricity storage of at least 225 MW and 250 GWh/a is that these assets are important for grid development. Statkraft believes that this would be an inadequate justification as new large generation assets and large new power intensive industry also have an important impact on grid development, but they are still not classified as infrastructure. Thus, we neither see the justification to set a minimum value for electricity storage and electrolysers capacity, nor why these assets with this capacity should be part of the TEN-E regulation, while assets with lower capacity are expected to be developed as market-based assets. This only creates unjustified commercial differences for assets of different size in the same energy market, probably favouring TSO/DSO ownership of the assets classified as infrastructure. We acknowledge that storage is part of current TEN-E regulation. Ideally, we would like to see that that electricity storage and electrolysers are not part of the TEN-E regulation, because these should be market-based assets. If the TEN-E regulation includes electricity storage and electrolysers as part of the TEN-E it should be clear that they remain in the competitive domain with reference to the market directive. More equal requirements for PCI and PMI projects Regarding projects of mutual interest. PMI-projects need to be of benefit for at least two Member States in addition to at least one third country. We propose that it is sufficient that PMI-projects benefit one Member State, which is the rule for PCI-projects, as different rules may create inefficiencies in the European energy market.
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Meeting with Stefanie Hiesinger (Cabinet of Executive Vice-President Frans Timmermans) and Fortum Oyj and Vattenfall

8 Mar 2021 · Exchange views on the upcoming initiatives under the Fit for 55 package

Meeting with Mauro Raffaele Petriccione (Director-General Climate Action) and Fortum Oyj and Vattenfall

22 Jan 2021 · 2030 climate and energy framework

Response to 8th Environment Action Programme

30 Dec 2020

Statkraft welcomes the possibility to provide feedback on the 8th Environmental Action Draft Programme. Our organisation supports Europe’s goals of climate neutrality and of phasing out environmentally harmful subsidies by making the best use of market-based instruments. We welcome the Commission’s announcement that it will mainstream sustainability in all relevant initiatives and projects at EU level to increase coherence and synergies through an integrated approach. However, Statkraft is concerned by the proposed decoupling of the environmental aspects of sustainability from the social and economic ones. This comprises a risk of leading to one-sided decision-making and of compromising the achievement of an integrated approach to mainstream sustainability. Although a healthy environment is key for life on Earth, a sole focus on ecological conservation will not allow Europe to achieve UN’s Sustainable Development Goals, as it lacks due considerations for social responsibility and economic solidity. Measuring the progress towards achieving UN’s SDGs requires an integrated and balanced framework for environmental, social and economic objectives. From a sustainability perspective it will be important to consider for example the security of electricity supply per region and the full level of energy service provided not only the environmental impact of different electricity sources individually. Moreover, we would like to comment that the objective of the EU «green oath» TO DO NO HARM might be useful to achieve a mind shift and to mobilize citizen’s heart. Yet, we do not consider this type of vocabulary appropriate for administrating public resources in an objective and balanced manner. Statkraft advises to update the EAP in order to be at least coherent with the Taxonomy’s terminology stating “to do no SIGNIFICANT harm”. All human activities do have an impact on nature. Whether this impact is considered minor or major and whether it can be duly mitigated is in most business areas, assessed and managed by national authorities through a public licensing system which also addresses necessary trade-offs. At the end of this process a company receives a permit to operate, if the public assessment concluded that the activity is sustainable. Although the energy sector is considered to be part of the sectors with the highest environmental impact, we have now over 100 years of experience on how to mitigate hydropower’s environmental footprint, so that society can fully reap its benefits residing in extraordinary contributions to climate change mitigation through its low carbon footprint. In addition, it is the only renewable energy source which can provide energy storage and flexibility to ensure energy supply security. Hydropower has the highest energy conversion efficiency and creates no waste or pollution, which fully supports a circular economy, using the natural cycles of the sun and water. Moreover, in combination with reservoirs it provides regulating water management services which are valuable for climate change adaptation, by increasing freshwater retention, mitigating floods and droughts, enabling other water uses such as water-based transport, irrigation, recreational activities and supporting drinking water or industrial water supply. We’d like to take this opportunity to emphasise that the hydropower sector is aware of the importance of sustainability. In a multi-stakeholder approach it has developed over the past decades a sustainability governance system. EU LIFE has been a partner in testing the Hydropower Sustainability Assessment Protocol. More information can be found at https://www.hydrosustainability.org/. All in all, we appreciate the participatory approach which the Commission applies and hope that a draft of the new monitoring framework, including the proposed headline indicators, will be put out for public consultation in the year to come.
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Response to Climate change mitigation and adaptation taxonomy

16 Dec 2020

Statkraft strongly supports the European Green Deal and a 2030 emissions reduction target of at least 55 percent as an important step to the climate-neutrality target in 2050. We also appreciate the Commission’s plan to involve the financial sector in supporting the achievement of these targets. Establishing a classification system for sustainable activities through the Taxonomy is important in order to prioritize low-carbon investments in a transparent and fair manner. Therefore, it is crucial that the criteria are defined in compliance with the overall intention of the Taxonomy Regulation in order to avoid unintended consequences. We appreciate that hydropower is defined as an enabling economic activity in the Draft Delegated Acts, in line with other renewable technologies. All renewable technologies remain important enablers for the European Green Deal. However, the proposed criteria for hydropower go far beyond current EU legislation and what is relevant in a European context and set a stricter standard for hydropower compared with other renewables. This is not only in conflict with the principle of technology neutrality in the Taxonomy Regulation (§19, 1(a)), but creates unnecessary uncertainty for hydropower and the highly flexible supply of renewable, emission-free electricity to achieve Europe’s climate targets. The Taxonomy is expected to set a new market standard for labeling of sustainable activities, which we expect to have broad economic, legal and practical consequences for economic activities in Europe. All investments in current and new assets, companies’ issuing of green bonds, reporting requirements and company reputation will be measured against the criteria proposed in the Draft Delegated Acts. Concrete proposals to mitigate unintended impact In the attached document Statkraft has drafted concrete changes in the wording of the draft delegated acts with references and argumentation. These changes would ensure that hydropower faces equivalent thresholds to prove sustainable as other renewable energy technologies and refer to the following issues: 1. “Do No Significant Harm “(DNSH) criteria for hydropower should be defined for hydropower along the same principles as for other renewable technologies with direct reference to current EU legislation. Therefore, DNSH criteria for hydropower need only to refer to relevant EU-wide environmental legislation for hydropower, such as the Water Framework Directive (WFD) , without further specifications. 2. Specific criteria on power density for hydropower and requirements for life-cycle analyses should be deleted to ensure technology neutrality as intended in Article 19(1a) in the Taxonomy Regulation. 3. Hydropower should be included in the scope of “renewable energy technologies”. 4. Reservoir hydropower should be included in “storage of electricity”.
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Response to Revision of the Energy and Environmental Aid Guidelines (EEAG)

10 Dec 2020

Statkraft feedback to Roadmap consultation on the revised guidelines for state aid for environmental protection and energy As Europe’s largest renewable electricity producer, Statkraft is committed to contributing to the EU becoming the world’s first climate-neutral region by 2050. The Guidelines on State Aid for Environmental Protection and Energy (EEAG), are of high importance for the energy sector. We fully support the Commission’s overall goal of preventing State aid from distorting competition in the internal market and affecting trade between Member States. In line with the Commission, we also acknowledge the need to ensure that climate targets are reached while limiting the environmental impacts of the use of resources. Electrification is emphasized in the European Green Deal as a means to decarbonize other sectors in the economy, and some incentives may be needed to advance the electrification rate. In principle, we believe that a strong ETS and effective carbon pricing could drive decarbonization in the most cost-efficient way, in addition to providing revenues to governments. The principle of putting a price on emissions to provide sufficient incentives for decarbonization should also be applied to those sectors currently not covered by ETS. Well-designed markets tend to bring cost-efficient outcomes quicker and with less friction than other policies approaches. The dramatic decrease in costs of onshore wind and solar PV has resulted in these technologies already being fully competitive with fossil alternatives. Subsidizing fully commercial and mature renewable generation might undermine the well-functioning internal electricity market and the market-based formation of electricity prices. Therefore, state aid and subsidies for mature technologies and markets should be avoided. However, there are situations, where support may be required. This can be the case: • for spurring market demand for renewable energy in hard-to-abate sectors • to support investments in infrastructure including production and distribution equipment for early movers that are faced with higher costs in an introduction period due to lack of scale • for less mature technologies that need support until commercialization • when deployment needs to speed up beyond what the market can deliver On that basis, State Aid Guidelines should set out the criteria for when aid can be granted while ensuring that market distortion is minimized: • Support schemes should be based on market principles such as contracts for difference and auctions • Support schemes should not create a competitive advantage for a technology that it is less cost-efficient and/or less energy-efficient than other viable options • Support schemes should be temporary and adjustable to market developments, such as decline in costs due to technological development, scale and competition.
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Response to Protecting biodiversity: nature restoration targets

2 Dec 2020

We welcome the Commission’s proposal of conducting a policy option assessment prior to considering the elaboration of binding nature restoration targets. At this early stage of the process, we’d like to highlight the importance of taking a holistic view, considering both positive and negative impacts on nature, people and the economy. Such a sustainability perspective should also take duly into account the sustainable use of nature comprising cost-benefit assessments for all interventions as well as the establishing of priorities. In many cases ecosystems have been modified in Europe to gain benefits for human civilisation. Therefore, we believe a possible strategy to achieve rapidly ecosystem improvements with reasonable efforts could be to start restoration efforts with ecosystems which still are close to their natural status instead of beginning with heavily modified water bodies, undoing the efforts which were made by prior generations. These ecosystems have been modified primarily based on overriding public interest to protect lives, properties and economic activities against floods and droughts or to produce low-carbon and renewable energy without pollution from hydropower or to transport goods in a climate-friendly way on water channels. Since objective evidence shows that 95% of Europe’s flood plains have been converted to other uses by now (EEA, 7/2018, p.73), it does not seem realistic to focus on nature-based solutions only, when coping with climate change adaptation and quantitative freshwater management. Hydropower dams with reservoirs can provide important regulating ecosystem services. The storage capacity of man-made lakes can be used to absorb excessive rainfalls and prevent flood damages downstream, and they enable to store more freshwater in the river basin to prevent droughts. Furthermore, sediments deposing in the reservoirs are contributing to carbon storage. Hydropower dams can be a tool for both water quantity and water quality management. Besides the flood and drought mitigating capacity of reservoirs, hydropower dams can also be used to reduce a river’s water temperature and to increase a river’s oxygen levels by increasing the river water’s air contact in letting it flow over a dam. Such services provided to mankind and nature are part of operating conditions which are written in concessions and licences. When assessing the ecosystems’ natural capacity to capture and store carbon, it will be important to look at the whole picture, the net carbon footprint of an ecosystem, including also their natural carbon emissions (net carbon storage minus natural emissions), since some wetlands such as peatlands can be significant methane emitters. Studies from Finland have shown, that in wetlands with low pH value the land use change from a peatland to a lake can lead to a net carbon reduction. When establishing guidance on how to create 25.000 km of free-flowing rivers, we’d like to draw your attention to the negative effects of removing even small and obsolete horizontal infrastructures, although the intention of restoring ecological connectivity might be a good one. Those low dams and weirs actually contribute to stabilise the ground water levels in the vicinity, what increases agricultural yields, by preventing the ground water to drain naturally towards the ocean. Dam removal projects may also need to find a permanent solution for toxins which can be buried in the sediments. In many places small dams and weirs are also used to maintain an aesthetic landscape and to maintain minimum water levels for fish especially during the dry summer season. All in all, we’d like to stress the necessity to make policies based on objective evidence, promoting only measures which have a scientifically documented benefit to ecosystems. Once ecological benefits are proven, an open and transparent decision-making process has to be in place taking into account the costs and benefits for both nature and people.
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Response to Updating the EU Emissions Trading System

26 Nov 2020

Statkraft is Europe’s largest provider of renewable energy, with a basis in hydropower, a significant presence in wind power and strong growth ambitions within solar and wind in Europe. We have for long been a vocal supporter of a strong EU ETS, as the most efficient tool for driving the transition of the European energy systems in a technology neutral and market-based manner. The ETS has contributed significantly to emission reductions in the EU/EEA area the last years, both through fuel switching from coal to gas and by increasing the profitability of renewables, thereby making it more attractive to invest in zero carbon power generation. By including several industrial sectors, the ETS provides for emissions being reduced where the cost is low, thereby ensuring that the total emission reductions are reached at the lowest possible cost. This is important both for the competitiveness of European industry and in an energy affordability perspective. Following the ambitious climate targets set out in the European Green Deal, the EU ETS needs to be swiftly adapted. We appreciate the possibility to provide a view on topics to be included in the forthcoming impact assessment of the ETS, as a basis for important changes in the regulatory framework that can drive further decarbonization of the European economy. In the attached document we elaborate around the following important aspects: • Swift adjustment of the cap and Linear Reduction Factor (LRF) • Maintaining an effective Market Stability Reserve (MSR) to adjust for possible demand shocks • Extension of the ETS to include more sectors in a carbon pricing scheme • Inclusion of carbon sinks • How to avoid the ETS being undermined by other policies
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Response to Revision of the CO2 emission standards for cars and vans

25 Nov 2020

We strongly support the strengthened ambitions of the European Green Deal and specifically emissions reductions from transport. For these ambitions to be realised we need improved regulation. Emissions standards should in as much as possible be based on real driving emissions of the vehicle and not only the WLTP cycle. This is particularly relevant for PHEV which have repeatedly been shown to have higher emissions in real driving situations. The impact assessment should consider: • Using real driving emissions data from typical usage, particularly for PHEVs • Redefining the “zero and low emission vehicle” concept to “zero-emission vehicle” from 2025 for fleet emissions calculations • Set “zero-emission vehicle” sales quotas with bonuses and penalisations for manufactures (bonus/malus system), achieving 100% sales quota in 2030-2035 The impact assessment should also consider effects on related infrastructure: • the reduced cost of the transition given more regulatory certainty, thus avoiding further investments in soon to be stranded fossil assets • the positive benefits for the power system of increased flexibility provided by BEVs
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

21 Sept 2020

As Europe’s largest renewable electricity producer, Statkraft is committed to contributing to the EU becoming the world’s first climate-neutral region by 2050. We support the Commission’s proposal to increase the EU’s current 2030 climate target from 40 % to 55 % emissions reductions. Preferred option Of the presented options in the Inception Impact Assessment, Statkraft prefers option 4. Hydropower Hydropower is an essential part of the European renewable energy mix and currently the most efficient and competitive way to store and generate electricity. Hydropower can balance the system across time horizons from seconds to seasons. With its flexibility, hydropower can support the integration of vast amounts of intermittent renewables into the power system. Once installed, reservoir hydropower assets have low running costs, negligible carbon footprint and potential lifetimes of more than 100 years. Facilitating the efficient use of hydropower is therefore crucial for Europe’s energy transition, and the role and value of hydropower in meeting the increasing demand for renewable energy must be appropriately reflected in the Directive. Renewable production Well-functioning electricity markets generally will deliver the necessary growth in renewable electricity production without new specific targets for renewables. This is certainly the case for the Nordic market. The dramatic decrease in costs of renewables has resulted in renewables already being fully competitive with fossil alternatives. Subsidizing new renewable capacity can undermine the well-functioning internal electricity market and the market-based formation of electricity prices. Therefore, if support schemes are required, market distortions should be minimized. Further a mechanism in the ETS, which automatically adjusts the supply of allowances to changes in demand induced by national policies and support schemes is urgently needed. In principle, we believe that a strong ETS and effective carbon pricing could drive decarbonization in the most cost-efficient way in addition to providing revenues to governments. Stimulate demand for electrification Electrification is emphasized in the European Green Deal as means to decarbonize other sectors in the economy. However, some incentives may be needed to advance the electrification rate. It is important that the markets provide clear, transparent and effective price signals to all participants. Further, minimum requirements for the share of renewable electricity in final consumption and buildings can be used to stimulate the demand side. Need to create markets and origination schemes for hydrogen With its high and growing shares of renewables in electricity Europe is in a unique position to produce green hydrogen. But there is a need to enhance cost reductions for electrolysers and build scale in electrolyser production in order to remove the first-mover disadvantage. This can be supported through public procurement policies, long term contracts and investment support in the early phase. Such support should not create a competitive advantage for hydrogen where it is less cost-efficient and energy-efficient than other options. Further, following the unbundling principle in the electricity market, only market players should be responsible for construction, ownership and operation of hydrogen installations (including storage and P2X) in order to avoid market distortions and ensure equal level playing fields. Further, a system for documenting the origin of all hydrogen is needed. Such a system should be built on existing systems for documentation of the origin of electricity, and be adjusted to accommodate the specific challenges of hydrogen production – from the source of the energy used in production to the final product, such as ammonium as fuel for ships or in industrial processes and products. It is important to distinguish such a documentation system from possible support systems meant to incentivize new production.
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Response to Offshore renewable energy strategy

13 Aug 2020

As Europe’s largest renewable electricity producer, Statkraft is fully committed to contributing to the EU becoming the world’s first climate-neutral region by 2050. We appreciate the opportunity to provide input to the offshore renewable strategy. Significant cost reductions have made renewable energy technologies competitive with fossil alternatives. Renewables are key to meet the demand for sustainable power, the 1.5 °C Paris Agreement target and the EU 2050 climate neutrality target, and several renewable technologies are needed. We are convinced that a competitive internal energy market is a precondition for this required growth in renewables. Therefore, the forthcoming offshore strategy should be based on a holistic approach. Three specific challenges for the offshore strategy need to be addressed: 1. How can offshore become competitive to onshore? While all renewable energy technologies have experienced large cost reductions over the last decades, the unit cost for offshore wind is still not competitive with other renewable technologies. Cost parity needs to be addressed. The offshore strategy should consider how offshore technologies can be incentivized with least possible market distortions and discrimination across technologies and countries. 2. How to ensure sufficient and cost-efficient infrastructure? Cost efficient production and transmission of offshore power requires the development of a meshed large-capacity offshore grid with connection to and higher capacity in onshore transmission systems, as well as interconnectors between countries. This would allow offshore power to be transported to the area with the highest power price and make the free transmission capacity available for power exchange when the wind production is low. This can enable more efficient use of the transmission systems and increase security of supply through efficient power exchange between countries. However, Transmission System Operators will face higher costs resulting from higher investments and operational costs of a larger grid, and tariffs to consumers may need to be increased. Need for transmission capacity must also be seen in the context of the discussion around offshore island production of hydrogen based on offshore wind. While such hydrogen may be transported onshore by vessels and thus reduce the need for new transmission capacity offshore, the cost competitiveness of such solutions needs to be carefully assessed, and market distortions must be avoided. 3. How to avoid market distortions The availability of renewable resources, the electricity mix, as well market balances vary largely across Member States. Wind production from offshore wind will compete with power produced with other technologies. Lack of sufficient interconnector capacity may lead to significant excess supply and falling profitability in some countries. Country-specific production targets should therefore be avoided. To stimulate an efficient internal energy market, a level playing field between new and old plants and different technologies should be sought. Support for research and development as well as demonstration projects can advance such technologies towards commercialisation and should be limited to the early phases to avoid distortion of the power market. Technology-specific support mechanisms can weaken the level playing field and already established markets, which again can increase the risk for investors and operators of other renewable technologies. The best way to encourage growth of the variety of renewable technologies is maintaining a well-functioning European power market in combination with a strengthened EU ETS which provides effective carbon-price signals. If necessary, this can be combined with highly competitive and preferably technology-neutral auction-mechanisms in the medium term. Successful future progress will need continuous development of licensing systems and reduction of other potential barriers for deployment.
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Response to A EU hydrogen strategy

8 Jun 2020

As Europe’s largest renewable electricity producer, Statkraft is fully committed to contributing to the EU becoming the world’s first climate-neutral region by 2050. Direct electrification is a highly efficient, flexible and sustainable enabler for sector integration and decarbonization of the economy. Hydrogen and its derivatives will play an increasingly important role for processes challenging to electrify and thus contribute to meeting the EU’s climate ambitions and the 1.5 °C Paris Agreement target. Statkraft sees the largest potential for green hydrogen demand in heavy-duty and long-distance road and maritime transport, and as a feedstock and high temperature heat to industrial processes (e.g. ammonia production, refinery processes, reducing agent in steel production). The cost of hydrogen production from electricity varies with the electricity price and the electrolyser’s utilization rate. Optimal hydrogen production will therefore balance operating hours with electricity price variations. Hydrogen can also be converted back into power using fuel cells or gas turbines for extended periods with low wind or solar PV production. Cost reductions in renewable energy and hydrogen technologies (electrolysers and fuel cells) have made green hydrogen applications more cost-competitive to direct use of fossil fuels. Still, value chains for hydrogen have not reached full market maturity. With scale-up of production electrolyser costs are expected to decrease significantly. Being a first mover can be a disadvantage and requires incentives to ensure deployment occurs quickly enough to achieve required scale-up. Deployment of hydrogen could be supported in the following ways: •Setting concrete and stricter emission reduction targets with sanctions if breached (e.g. Regulation (EU) 2019/1242 reducing CO2 Emissions from Heavy duty vehicles; Oslo municipality decision 6 May 2020 to become emission free or fossil free within a wide range of areas by 2030); •Sufficiently high price on CO2 emissions by tightening the EU emissions trading system (ETS) and introducing taxes of the same size for sectors not covered by the ETS. •Carefully evaluate the possibility of a carbon border adjustment mechanism to avoid carbon leakage to countries with insufficient CO2-regimes; •Investment support in the starting phase to reduce costs/risks for first movers and build scale in hydrogen production and applications. •Introduction of joint minimum and public procurement requirements for use of hydrogen to build demand and markets. Incentives to support development of a market for green hydrogen will drive investments and further reduction in electrolyser costs; •Coordinated development of electricity/gas/hydrogen infrastructure and encouraged collaboration between gas and electricity system operators will allow infrastructural cost savings. This should not result in TSOs imposing undue restrictions on markets regarding location of new assets (including storage and P2X). Following the unbundling principle, only market players should be responsible for construction, ownership and operation of hydrogen installations to avoid market distortions and an uneven level playing field. Locational deep connection charges can be considered as well as TSOs tendering for congestion management services for certain locations. Flexible operation of electrolysers has a value to the grid, which should be reflected in the grid tariffs. •There is a need for a harmonised European system to document the origin of all hydrogen. Such a system should be built on existing systems for documentation of the origin of electricity and adjusted to accommodate the specific challenges of hydrogen production. One such well-established method of documenting the origin of electricity in the EU is Guarantees of Origin: a voluntary and transparent system based on common standards. •Improve public acceptance for hydrogen by show-casing pilot projects and demonstrating safety solutions in place.
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Response to Climate change mitigation and adaptation taxonomy

27 Apr 2020

As Europe’s largest renewable electricity producer, Statkraft welcomes the opportunity to provide input to this important process. This first delegated act concerning climate change mitigation and adaption has extensive consequences for the perception of renewable technologies. Hydropower stands as a unique renewable electricity generating technology with its multifunctional contributions and level of flexibility. The following key issues underline the barriers posed by the TEG report hindering hydropower from contributing with its full potential to climate change mitigation and adaption. Creating an unequal level playing field The criteria put forth to assess climate change mitigation are not technology neutral for renewable energy sources. Only hydropower faces specific criteria regarding land use and life cycle assessments. Obliviating the only renewable storage option of electricity Hydropower is the only large-scale renewable generating option to offer storage of energy (in form of water in reservoirs) which can be transformed into electricity instantaneously. Hydropower storage – in line with other storage technologies - should therefore be automatically eligible under the Taxonomy without any further requirements. Recognizing hydropower as an enabling activity Hydropower plants with reservoirs are enabling adaptation, by being actively used to mitigate floods and droughts, limit damage to assets and economic activities and indirectly enable more intermittent renewable power. We suggest recognizing hydropower as an “Enabling activity” in the technical screening criterias. We strongly object to categorising hydropower as “Transitional activity” as this disregards hydropower’s unique capabilities to provide large-scale and renewable flexibility to power systems. Narrow approach to sustainability While the UN definition of sustainability balances economic, social and environmental perspectives, the proposed approach solely focusses on the environmental dimensions, thus neglecting other important multi-purpose contributions of hydropower to sustainability. Compromising the subsidiarity principle Hydropower is site-specific, adapted to local needs and conditions in a water body. The sustainability of each hydropower plant is assessed through national licensing processes considering regional and local particularities in the context of each member state. Additional criteria at EU level may increase the administrative burden in financing hydropower and lead to a loss of flexible clean energy. Size is not a guarantee for sustainability Possible adverse effects of hydropower are always plant and site specific, and size has never been an appropriate criterion to judge whether a hydropower project is sustainable or not. The recommendation to avoid construction of small hydropower under 10 MW should therefore be abated. Major remaining methodological uncertainties The Taxonomy lacks specifications of how to calculate the power density factor and how to handle challenges related to life-cycle assessments. We therefore suggest including more detailed instructions on how to measure power density, hydropower’s carbon footprint and to verify that this is relevant for hydropower in different European countries: • Power density factor The power density must acknowledge the NET effect of carbon emissions by deducting the natural carbon emissions prior to impoundment (as also pointed out by the IPCC). The calculation must be applicable for different hydropower schemes, such as: o multiple reservoirs o cascading hydropower plants o multipurpose reservoirs (irrigation, floods, drinking water, navigation, recreation) o modernization without changes to the reservoir • Life-cycle assessments Further clarification is needed on how to document consecutive reduction of GHG emissions and how to allocate GHG emissions originating from different human activities in multipurpose reservoirs such as carbon inflow from agriculture or sewage.
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Response to Climate Law

6 Feb 2020

Statkraft is a leading company in hydropower internationally and Europe’s largest generator of renewable energy. The Group produces hydropower, wind power, solar power, gas-fired power and supplies district heating. Statkraft is fully owned by the Norwegian state and has global energy market operations. Statkraft has 3600 employees in 16 countries. Statkraft welcomes the Commission’s ambitious climate policy entailed in the European Green Deal to make the European Union the world’s first climate-neutral continent by 2050. As Europe’s largest producer of renewable energy, Statkraft is fully committed to contribute to achieving this target. In our view, a massive development of renewable energy and massive electrification of sectors with significant CO2 emissions will be key. Enshrining the net-zero target in law will set an important standard and commitment for European climate policy. To achieve climate neutrality by 2050 we need to establish a cost-efficient emissions reduction pathway with coherent interim targets. Statkraft supports an interim target for 2030 of 55 percent and to enshrine the interim target in the climate law. This will provide clarity on the necessary direction, prevent more disruptive measures at a later point, and mitigate the risk of a lock-in of carbon-intensive production assets and fossil fuel infrastructure. Well-integrated electricity markets across the EU with market-based regulatory frameworks based on ambitious GHG emission reduction targets, carbon pricing and increased cross-sectoral flexibility is the best combination to facilitate cost-efficiency in decarbonizing the European economy. We believe that a strong EU ETS is indispensable for driving this process based on market forces. Decarbonization of non-ETS sectors is both costly and challenging in many Member States. The EU ETS has proven to be the most cost-efficient instrument at disposal and we therefore support the consideration of expansion of the carbon price signal wider in the economy and including other sectors in the EU-ETS. In that respect, abatement costs and the impact of a carbon price on demand elasticity should be important criteria to evaluate. In general, we believe that a carbon price should be reflected in the price of all carbon intensive products and activities in all sectors. Electrification is the most efficient, flexible and sustainable way to decarbonize the economy, while also bringing significant co-benefits such as better air quality in urban areas, lower import dependency and higher energy-efficiency. A combination of instruments can increase the market share of electric vehicles and replace fossil fuels in the transport sector: a carbon price that makes fossil fuels more expensive than clean electricity, differentiated tax system reflecting emissions, advanced battery technology, and rapid development of charging infrastructure. This is also important for the electrification of small and medium distance ferries as examples in Norway show. Power transmission capacity should be at the core of the political discussion on the electrification of the European economy. Investments in transmission grid infrastructure should be intensified both at cross-border and internal level with focus on regional network planning and policy coordination. We propose the establishment of an electrification strategy to set out a comprehensive regulatory framework and targets for electrification rates and the deployment of infrastructure to facilitate electrification and decarbonization especially of those non-ETS sectors with high GHG emissions.
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Meeting with Mauro Raffaele Petriccione (Director-General Climate Action) and Fortum Oyj and Vattenfall

7 Nov 2019 · European Green Deal

Meeting with Miguel Arias Cañete (Commissioner) and Fortum Oyj and Vattenfall

27 Nov 2018 · EU climate and energy policies

Meeting with Miguel Arias Cañete (Commissioner) and Amazon Europe Core SARL and

23 Mar 2018 · Energy sector

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

23 May 2016 · Market design

Meeting with Miguel Arias Cañete (Commissioner) and TenneT Holding B.V. and

16 Feb 2016 · Market Design

Meeting with Christian Linder (Cabinet of Vice-President Maroš Šefčovič) and TenneT Holding B.V. and

11 Feb 2015 · Energy Union

Meeting with Markus Schulte (Digital Economy) and VERBUND AG and

3 Dec 2014 · Smart Grids