Stockholms stad
Stockholm är Sveriges huvudstad och den befolkningsmässigt största kommunen i landet med cirka 975 551 invånare.
ID: 670368518489-38
Lobbying Activity
Response to European Affordable Housing Plan
3 Jun 2025
Stockholms stad välkomnar EU-kommissionens initiativ att tillhandahålla lösningar för att hjälpa alla aktörer i bostadssektorn att erbjuda mer överkomliga och hållbara bostäder och ser positivt på insatser som syftar till att stötta den lokala nivån i sitt uppdrag att tillhandahålla allmännyttiga bostäder. Stadens bostadsbolag förmedlar lediga hyresrätter genom kommunal bostadsförmedling, vilket är ett av kommunens lagstadgade verktyg för att bidra till en hållbar bostadsförsörjning. Det är därför av högsta vikt att denna handlingsplan tydligt respekterar subsidiaritetsprinciper och därigenom tillåter skillnader för lokala förhållanden, regelverk och bygger på att stötta lokala system utan att försvåra pågående lokalt arbete genom ökad administration. Vänligen se bifogat stadens utökade synpunkter på planen.
Read full responseResponse to Policy agenda for cities
22 May 2025
Städer står inför allt större utmaningar från ökande effekter av klimatförändringar, belastning på infrastruktur, växande sociala klyftor, förändrad demografi, bostadsbrist samt beredskap och investeringar i EU:s gemensamma konkurrenskraft. Även om många städer tar steg för att möta dessa utmaningar, kräver omfattningen och komplexiteten mer operativa verktyg, finansiering, och handlingskapacitet för att kunna förverkliga en gemensam vision för hållbar stadsutveckling i Europa. Den nya EU-agendan för städer behöver spegla denna utveckling genom att uppdatera unionens gemensamma strategi och erkänna den bredare roll som städer spelar. Under de senaste åren har EU ökat sin förståelse för städers betydelsefulla roll för unionens utveckling. Nya initiativ, finansieringsmöjligheter och dialoger har vuxit fram inom olika delar av kommissionens verksamhet, vilket speglar en ökande insikt om städernas centrala roll för att uppnå EU:s mål. Trots denna ambition har det inte lett till att städer inkluderas som en fullvärdig och central aktör i utformandet av lagstiftning eller i befintliga finansieringsmöjligheter. Stockholms stad välkomnar därför EU-kommissionens initiativ om en särskild agenda för städer och ser detta som ett viktigt steg i erkännandet av städer som en central del i unionens gemensamma arbete. Stockholms stad framhåller ett antal uppmaningar till EU-kommissionen vid framtagandet av den särskilda agendan för städer. Se bifogat Stockholms stads uppmaningar till EU-kommissionen inför framtagandet av EU:s nya agenda för städer.
Read full responseResponse to EU Start-up and Scale-up Strategy
17 Mar 2025
Vänligen se bifogat Stockholms stad synpunkter.
Read full responseResponse to Evaluation of the Public Procurement Directives
3 Mar 2025
Bifogat finner ni Stockholms stad synpunkter inför kommande revidering av upphandlingsdirektiven.
Read full responseResponse to Environmental Implementation Review 2025
28 Jun 2024
Se bifogad fil med Stockholm stads inspel inför granskningen av EU:s miljöpolitik 2025.
Read full responseResponse to Type approval of motor vehicles regarding access to in-vehicle generated data
16 Jun 2022
Please see attached pdf-document for the City of Stockholm's input to the consultation on "Access to vehicle data, functions and resources".
Read full responseResponse to Implementing act on a list of High-Value Datasets
16 Jun 2022
Digitalisation can bring about increased efficiency and productivity. Good data management is a prerequisite to bring about this change. The City of Stockholm welcomes the EU:s high ambitions concerning the digital transition and acknowledges that there is an added value of availability of public datasets. There are however some points of concern that the City of Stockholm would like to highlight:
- It is important to not underestimating the costs for the public sector and the costs of data
- The NUTS 2 and 3 geographical level does not allow for a satisfactory socio-economic analysis at the local level
- National agencies as primary source/providers of data can secure the reliability and trustworthiness of data
- Concerns regarding the specifications of standardization and harmonization of high value datasets
- The licensing form of datasets
- Clarity of the implementing regulation on open data – availability of public datasets and the INSPIRE Directive
For further details please see attached file with the City of Stockholm's comments concerning "Open data - availaibility of public datasets".
Read full responseResponse to Policy Program - Digital Decade Compass
12 Dec 2021
The City of Stockholm’s feedback to the EU consultation on the 2030 Policy Programme “Path to the Digital Decade”:
The City of Stockholm’s vision for 2040 states that Stockholm is the most connected city in the world and one of the cities in the world that has made the best use of digitalisation. Stockholm has high ambitions concerning digitalisation and therefore welcomes EU’s ambitions within the field of digitalisation. The City of Stockholm looks forward to contributing to achieving the digital targets and ambitions.
One important issue to reach the goals and ambitions is to clarify EU’s ambitions when it comes to digital independence and to not be too dependent on non-European technologies. Another key issue to reach the goals is that the Commission creates conditions for interoperability through common digital solutions.
In order to be effective, the EUs vision and the digital targets that are set for 2030 need to be both ambitious and realistic taking into the consideration the capacity and preconditions of those key stakeholder who will share the responsibility of carrying out the subsequent legislation and priorities.
In the “staff working document” (annex to the proposal) it’s clear that there are big differences between the Member States when it comes to digital development. The City of Stockholm therefore welcomes that the Member States should submit national Digital Decade strategic roadmaps to the Commission covering the period up to 2030. This roadmaps should also include a plan for implementation in the Member State. The City of Stockholm wants to raise the importance to take the local perspective of cities and regions into account in the national roadmaps. These roadmaps will hopefully be a help for national actors to receive further guidance in their prioritization. It can also be a help ensure the commitment of all Member States.
Please see attached file for comments concerning:
- Digital skills
- Digital identification
- Key public services online and access to medical records
- Secure, performant and sustainable digital infrastructures
- Cloud computing services
- The importance of the "offline perspective"
- The need to clarify how digitalisation contributes to reach the goal of a climate-neutral EU 2050
Read full responseResponse to Bathing water quality – review of EU rules
1 Apr 2021
Increased cooperation among member states and clear guidelines have led to a relatively uniform implementation of the bathing water directive across the EU, which is positive. The inclusion of bathing waters in the register of protected areas under the water framework directive has been an important factor in the implementation of the directive, as it has given the issue greater recognition and made a holistic approach easier. The directive has also led to closer cooperation among responsible authorities, operators and companies at local level.
In Stockholm, increased monitoring of nearby wastewater systems and stormwater collection systems, both public and private, has proven to be a particularly effective way to improve the quality of bathing waters. The monitoring of pipes and water networks has become increasingly systematic in recent years, reducing the administrative burden for local authorities. Going forward, more ambitious monitoring requirements (including for pumping stations) could help identify even more potential sources of contamination.
It is important to note that the directive does not provide mechanisms that would facilitate the work with new kinds of hazardous substances or health issues. This has at times made it more difficult to react to new challenges. When the City of Stockholm investigated a local outbreak of caliciviridae a few years ago, it proved difficult to find local labs that could conduct the necessary tests. A key reason for that is that commercial labs tend to adjust their testing capabilities to the requirements of EU legislation. Making it at times more difficult to tackle new substances or health issues that are not specifically listed in directives such as the bathing water directive or the water framework directive.
It also needs to be noted that the requirement to establish and maintain bathing water profiles has led to higher costs for local authorities. That said, the requirement to identify potential contamination sources and prepare risk management measures has proven to be effective in Stockholm.
Even though the bathing water directive and the water framework directive generally focus on different issues, they connect in some key areas. Most noticeably, in Sweden, when it comes to the issue of overfertilisation and algal blooms. Moreover, some waters that would normally not be recognised as water bodies under the water framework directive due to their small size, do get recognized due to their status as bathing waters. Which makes managing these waters considerably easier.
Read full responseResponse to Climate change mitigation and adaptation taxonomy
18 Dec 2020
Please find attached the feedback of the City of Stockholm on annex 1 of the draft delegated act supplementing the taxonomy regulation.
Read full responseResponse to EU Action Plan Towards a Zero Pollution Ambition for air, water and soil
29 Oct 2020
The City of Stockholm would like to underline that greater responsibility needs to be placed on producers to effectively limit environmental contamination and resource use in the EU. This need for stricter measures to prevent contamination and waste at the source applies to virtually all areas of environmental legislation.
As noted in our response to the consultation on the revision of the EU wastewater treatment directive, high levels of pharmaceutical chemicals and other contaminants of emerging concern in waste water make it exceedingly difficult for a city like Stockholm to recycle sludge in a circular system.
Likewise, packaging for consumer products remains a main source of environmental contamination. In 2018, only 18% of the plastic packaging waste in Stockholm was collected via the national extended producer responsibility scheme. The remainder ended up in municipal waste and had to be incinerated. A main reason for the low degree of material recycling lies in the packaging design itself. With packaging composed of different materials making effective material recycling virtually impossible for end-users.
These are just two of many examples that underscore the importance of tackling environmental contamination and waste directly at the source. The same principle also applies, amongst others, to building materials, chemical compounds (not just in the context of pharmaceutical chemicals and other contaminants of emerging concern), and transport emissions.
Read full responseResponse to Revision of the Renewable Energy Directive (EU) 2018/2001
21 Sept 2020
As previously noted, the City of Stockholm fully supports the Commission’s goal to increase the 2030 EU emission reductions target to at least 55%. Accelerating the transition towards renewable energy will be vital in this context.
Regarding the use of renewable energy in the transport sector, we would like to reiterate that the:
- expansion of urban grid capacity, which will be necessary to provide an adequate recharging and refuelling infrastructure, will require significant funding from national and EU level. Not just in the context of electric vehicles, but also the European shipping and port industry, where the provision of on-shore power supply (OPS), which is a high cost investment for ports and ship owners, will be vital to reduce the climate impact of berthing vessels.
- current one-size-fits-all approach to biofuels significantly undermines EU decarbonisation efforts. Biofuels are among the most climate-friendly fuels on the market from a life-cycle perspective, usually causing significantly less emissions than petroleum-electric hybrids. Unlike other member states, Sweden can produce sustainable biofuels from readily available farmland and forestry. Increased biofuel production from these lands would be beneficial for the environment, increase EU independence from fossil fuels and improve the economic viability of Swedish farms. Instead of making the most of these opportunities, limitations proposed and already set up by the Commission hinder the expansion of domestic biofuel production.
Regarding renewable energy and EU energy taxation, we would like to reiterate that:
- energy products and electricity produced from renewable sources should be as far as possible exempt from taxation. Energy products and electricity from sources that do not clearly contribute to reaching the EU energy and climate goals should be subject to demonstrably higher levels of taxation using an escalator model. Such an approach would generate immediate incentives for a rapid transition to renewable energy and electricity.
- A clear distinction should be made between energy taxation and carbon dioxide taxation. The level of energy taxation is set based on the energy content of the fuel (in principle EUR/MWh). The level of the carbon dioxide taxation is set based on the carbon content of the fuel (in principle EUR/tonCO2).
To promote the use of renewable energy, the EU should also:
- consider links across sectors that are not always seen as part of the traditional energy system. The City of Stockholm produces biogas from waste and sludge, which we use, amongst others, in our public transportation system. In the district heating system, biofuel and waste are used as fuels for the production of heat and electricity.
- support the integration of policies for renewable energy and heating/cooling systems at local level; this could be especially useful in cases where buildings already are heated with renewable energy sources and where energy efficiency measures would not lead to substantial climate effects. However, energy efficiency measure would reduce the use of biofuels needed within other sectors in order to replace fossil fuels.
Last but not least, we want to highlight that a large-scale application of bioenergy carbon capture and storage (BECCS) would allow us to safely capture and store twice as much CO2 as we currently emit on our roads within a few years. While there are no significant technical hinders to a large-scale application of BECCS in Stockholm, it would impose additional costs on the operators of our CHP plants and result in slightly reduced power output from the respective plants. Transferring the cost to the energy consumers would be problematic for many reasons. To solve this issue, we need to find a market that makes carbon capture and storage profitable. Public procurement schemes, under which national governments and private companies procure captured CO2 from CHP operators, could be a suitable option.
Read full responseResponse to Review of Directive 2012/27/EU on energy efficiency
21 Sept 2020
Regarding energy efficiency improvements in buildings, we would like to reiterate that:
- individual metering and billing must remain voluntary in countries where rent includes heating costs. A mandatory requirement would be disproportionate in the context of our housing market, and move the incentive for energetic improvements from owners to tenants. This would be counterproductive, as owners can improve energy performance in a more meaningful way. There are also documented technical problems with the approach, as the energy performance of an apartment also depends on its location within a building. Making fair charging more difficult.
- life-cycle analyses, and a circular approach, should be integral parts of EU energy efficiency policies. The extraction of raw materials, as well as the production, transport and installation of building materials can be significant emission sources. Particularly for buildings that are powered by renewable energy, renovations are not always the most suitable option.
- a systems perspective is vital. Energetic renovations may not always lead to emission savings from a life-cycle perspective. But one also needs to take into account how energetic renovations in buildings that are already powered by renewables could improve renewable energy capacity in other parts of the city. Likewise, recycling waste water heat at source, i.e. a building, can be positive. But large scale recycling at a sewage treatment plant usually brings better results.
- for-profit requirements for municipal housing companies in Sweden and other EU member states, which derive from EU competition law, actively prohibit the kind of investments that are needed to achieve the goals of the renovation wave.
- the right to community ownership of energy generation units and favourable urban planning regulations for photovoltaic installations in buildings are crucial. Regulations regarding local generation and electricity self-consumption (and electricity markets in general) differ significantly across the EU. In Stockholm, the installed photovoltaics are often smaller than the technical limit due to regulatory restrictions. Regulations on a neighbourhood level reduce the payback period and make the technology very suitable for a group of buildings with complementary load curves.
On the role of district heating and BECCS:
- Integrating BECCS into our local district heating system would significantly reduce our carbon footprint. Tests conducted in our CHP plant prove the technology’s effectiveness, and indicate that a large-scale application would soon allow us to safely capture and store twice as much CO2 as we currently emit on our roads.
- By 2040 – the year we aim to become climate positive – residual fossil fuels from the transport sector and the energy recovery of fossil plastics will most likely still be present in our local carbon system. The persistence of such residual fuels reinforces the need to speed up the development of negative emission technologies.
- While there are no significant technical hinders to a large-scale application of BECCS in Stockholm, it would impose additional costs on CHP plant operators and result in a slightly reduced energy output. Transferring the cost to energy consumers would be problematic for many reasons. To solve this issue, we need to find a market that makes BECCS profitable. Schemes under which national governments and private companies procure captured CO2 from CHP operators could be a suitable option.
Last but not least:
- Energy infrastructure and building digitalisation/AI could lead to smarter energy management and better energy monitoring. Energy management systems could be used to better steer district heating centrals, and even out the supply of energy. But expectations towards the impact of digital solutions need to remain reasonable.
- Recommendations from the Grow Smarter lighthouse project should be taken into account, including on the issue of smart street lighting.
Read full responseResponse to Revision of the Urban Wastewater Treatment Directive
8 Sept 2020
As previously noted, the City of Stockholm fully supports the goals of the European green deal, and the ambition to steer the EU towards zero pollution. Tackling remaining sources of pollution in the water sector are vital in this context.
That said, the City of Stockholm would like to underline that:
- storm water runoff is a significant pollution source, not least in an urban context, and it should be addressed accordingly in the new directive. As rightly outlined in the inception impact assessment, the issue has not been well addressed in previous iterations. This may have contributed to the fact that storm water runoff treatment still varies significantly across Europe. Often with negative effects on urban water bodies.
- appropriate storm water runoff treatment is costly. Implementing the recommendations of the Swedish water authorities, which were developed in the context of the EU water framework directive and concern ten of our city’s 21 water bodies, will cost between €150 million and €250 million. Additional measures, as requested by our departments for environment and health, development and transport, as well as our city district departments, are estimated to cost another €50 million. Access to appropriate funding will therefore be important to achieve the goals of the revised directive.
- more effective measures are needed to limit the amount of contaminants directly at the source. Greater responsibility needs to be placed on producers, not least in the context of pharmaceuticals and other contaminants of emerging concern. This is to keep urban waste water as uncontaminated as possible, and ensure that its sludge can be recycled in a circular system.
- a circular approach to the issue of urban waste water treatment is both needed and welcome. Already today, we produce biogas from waste and sludge in Stockholm. This gas is used both as vehicle gas for our inner city busses, as well as for heating and electricity generation. A significant portion of the sludge is also used as agricultural fertilizer. Moreover, heat from purified wastewater is recycled as district heating. Wastewater is, in other words, not waste, but an important resource.
- it is vital that the revised directive provides local authorities with flexibility in assessing and prioritising local waste water treatment needs. National and local contexts differ significantly across Europe and measures that may have a positive effect in one place, may turn out to be counterproductive and costly in another. At the same time, the directive also needs to take into account that many urban water bodies suffer from and/ or contribute to transboundary pollution.
Read full responseResponse to Commission Communication – "Renovation wave" initiative for the building sector
8 Jun 2020
The City of Stockholm supports the position of the Eurocities network, but would like to further add that:
1. As rightly outlined in the road map, energy efficiency improvements have the potential to significantly reduce the EU climate footprint. It is important to note, however, that this is not always the case. The extraction of raw materials, as well as the production, transport and installation of building materials can be significant emission sources. Particularly for buildings that are powered by renewable energy, renovations are not always the most suitable option. A life-cycle perspective should therefore be an integral part of the renovation wave. Such a life-cycle perspective should also take into account how energy efficiency improvements in buildings powered by renewables could improve renewable energy capacity in other parts of the city.
2. Under EU competition law, public financial support for municipal or public housing is considered a form of state aid. As a consequence, municipal housing companies in some EU member states are required to act as for-profit companies. In many cases, this profitability requirement makes it legally impossible for municipal housing companies to make the kind of investments that would be necessary to achieve the goals of the renovation wave.
3. Recommendations from renovation demonstration projects should be taken into account when developing the renovation wave. Recommendations from the GrowSmarter project, for example, underline that:
- energy supply regulations should be on a community or neighbourhood level, not on a building level, as is currently the case in several member states. After all, a community level approach would incentivize the installation of photovoltaics even on buildings that do not use much electricity given that the generated electricity could be distributed to other buildings in the neighbourhood;
- to enable renovations on a larger scale, more funding needs to be made available for the education of energy efficiency workers;
- a CO2 tax should be introduced to incentivise renewable energy supply.
The position of Eurocities can be found at: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12376-Commission-Communication-Renovation-wave-initiative-for-the-building-sector/F523830.
Read full response