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Third Generation Environmentalism Ltd

E3G

E3G is an independent European climate change think tank working to translate climate politics, economics and policies into action.

Lobbying Activity

Meeting with Philippe Lamberts (Principal Adviser Inspire, Debate, Engage and Accelerate Action)

11 Dec 2025 · Future of the EGD/CID in the current inside and outside political context of the EU

Meeting with Valdis Dombrovskis (Commissioner) and

4 Dec 2025 · Industrial Accelerator Act

Think tank E3G urges comprehensive EU circular economy framework with binding targets

6 Nov 2025
Topic — EU Circular Economy Act aims to boost competitiveness through sustainable production and recycling.
Message — The organization requests nine key measures including overarching EU resource use targets with monitoring frameworks, financial incentives for recycled materials, EU-wide minimum circularity requirements for public procurement, and harmonized quality standards for recycled materials. They emphasize making circular economy a strategic funding priority and empowering regional authorities to design circular economy programs.12345
Why — This would support their climate advocacy goals by reducing industrial emissions and resource dependency.67
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Meeting with Nicola De Michelis (Director Regional and Urban Policy) and European Alliance to Save Energy and

5 Nov 2025 · Cohesion policy investments under the present MFF and good practices/frameworks to serve as model for the future MFF

Meeting with Hana Genorio (Cabinet of Commissioner Jozef Síkela)

5 Nov 2025 · Exchange of views on how countries can act to increase climate finance to emerging and developing economies

Meeting with Bruno Tobback (Member of the European Parliament)

3 Nov 2025 · Electricity Grids

Meeting with Mohammed Chahim (Member of the European Parliament, Shadow rapporteur)

28 Oct 2025 · CBAM

Meeting with Bruno Tobback (Member of the European Parliament)

27 Oct 2025 · prep meeting on lead markets

Climate think tank E3G urges comprehensive overhaul of EU energy security framework

13 Oct 2025
Topic — Revision of EU energy security regulations for gas and electricity supply.
Message — E3G requests merging gas and electricity regulations into a single framework that anticipates fossil fuel phase-out, updates security standards for renewable systems, and shields consumers from emerging threats. They advocate for independent integrated planning, demand-side measures, and stronger European governance to manage the transition to a decarbonised energy system.123
Why — This would align EU energy security policy with their climate advocacy agenda.4
Impact — Fossil fuel industries lose as mandatory gas savings targets would accelerate their phase-out.56
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Climate Think Tank E3G Urges EU to Treat Clean Heating as Strategic Industry

9 Oct 2025
Topic — EU strategy to accelerate decarbonisation of heating and cooling in buildings and industry.
Message — E3G requests the EU formally classify heating and cooling as a strategic industrial ecosystem, streamline funding through public and private mechanisms, and fast-track implementation of existing legislation. They argue this recognition would harness competitiveness potential and tackle investment gaps.123
Why — Strategic classification would unlock investment stability and regulatory support for clean heating technologies.45
Impact — Fossil fuel industries lose market share as heating switches to renewables and electrification.67
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Climate think tank urges balanced electrification to deliver citizen benefits

8 Oct 2025
Topic — EU action plan to increase electricity use for decarbonisation and system efficiency.
Message — The organization requests the EU balance supply and demand measures in electrification, prioritize renewables and efficiency, and ensure fair cost distribution. They argue moving too quickly on supply without demand uptake undermines renewables' business case and risks higher consumer bills.123
Why — This would help maintain their influence over EU energy transition policy direction.4
Impact — Fossil fuel industries lose as gas grid decommissioning and worker transitions accelerate.56
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E3G urges EU to adopt 90% climate target for leadership

11 Sept 2025
Topic — The consultation defines the EU's global climate and energy strategy for 2025-2029.
Message — E3G calls for a binding 90% emission reduction target by 2040 to lead international ambition. They propose aligning financial tools and diplomatic structures to deliver concrete energy partnerships and support for developing nations.12
Why — This strategy frames climate action as a strategic security choice, enhancing the think tank's influence.3
Impact — Fossil fuel exporters face economic instability as the EU transitions away from oil and gas.4
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Meeting with Pascal Canfin (Member of the European Parliament)

8 Sept 2025 · Industry Accelerator Act

E3G Urges Systemic Definition and Targets for Climate Resilience Law

4 Sept 2025
Topic — The initiative proposes an integrated framework to help Member States manage accelerating climate risks.
Message — E3G recommends that the EU adopt a systemic definition and measurable targets. They propose integrating climate risk assessments into national planning to improve coordination. The initiative should also address workplace safety and distributional impacts on vulnerable groups.123
Why — A robust framework would safeguard European economic competitiveness and reduce systemic financial risks.45
Impact — Owners of high-polluting assets would lose public funding and face restricted capital flows.6
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E3G backs 90% climate target but demands scientific alignment

19 Aug 2025
Topic — EU initiative to amend Climate Law and set 2040 greenhouse gas reduction targets.
Message — E3G supports the 90% target but urges alignment with scientific advice for domestic reductions. They request justification for using international credits and call for a post-2030 delivery package.123
Why — The 90% target provides the regulatory predictability required for businesses and investors.45
Impact — Developing nations lose support if carbon credits are used instead of direct climate finance.6
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E3G urges independent planning to accelerate European grid expansion

25 Jul 2025
Topic — This consultation seeks views on upgrading, expanding, and digitalising European energy grid infrastructure.
Message — E3G calls for independent system planners to separate grid operation from commercial ownership. They advocate for stronger EU oversight of network planning and improved coordination of local plans. They also recommend expanding funding to address regional disparities and support grid modernization.123
Why — Reform would accelerate the green transition goals that the organization actively promotes.4
Impact — Existing network owners would lose influence over infrastructure planning and investment decisions.56
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Meeting with Vincent Hurkens (Cabinet of Executive Vice-President Stéphane Séjourné) and Cambridge Institute for Sustainability Leadership and

14 Jul 2025 · Simplification, CSRD, CSDDD

E3G calls for mandatory green standards to drive industrial decarbonisation

8 Jul 2025
Topic — EU proposal to accelerate investment in the decarbonisation of energy-intensive industries.
Message — E3G calls for mandatory low-carbon labels and quotas to create market demand. They also recommend fast-tracking grid access through designated industrial electrification zones.12
Why — These measures would ensure industrial policy reduces emissions while maintaining economic competitiveness.34
Impact — Well-connected industrial incumbents lose their unfair advantage under more transparent selection processes.56
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E3G urges EU to phase out free carbon allowances

8 Jul 2025
Topic — Review of the EU emissions trading system and market stability reserve.
Message — E3G calls for a definite phase-out of free pollution permits for all industrial sectors. They recommend expanding the carbon market scope to include municipal waste incinerators and other waste management. The group also proposes focusing EU innovation funds on first-of-a-kind clean technologies.1234
Why — This would align EU policy with E3G’s goals for rapid industrial decarbonisation.5
Impact — Industrial firms will face higher costs as free emission allowances are withdrawn.6
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Response to Recommendation on savings and investment accounts

8 Jul 2025

E3G welcomes the European Commissions initiative to develop a Savings and Investments Union (SIU), as recommended in the Letta Report. Unlocking private savings for the green transition is essential to meet Europes investment needs while supporting innovation and competitiveness. Below we provide feedback on key aspects of Savings and Investment accounts (SIAs). 1. Governance, supervision, and deeper integration We support the Commissions objective of increasing private capital flows by deepening capital markets across Member States. However, national capital markets still have differing regulations that need consistent harmonisation at EU level. The Commission should explore medium- to long-term solutions for developing harmonised EU-level regulations to address these barriers. In this context, strong governance is essential. SIU development should be integrated with other planning and governance tools - such as MFF national plans and National Energy and Climate Plans (NECPs) - to ensure private savings support clearly identified, investable transition priorities. We also support exploring greater supervisory integration at EU level over time, with the potential for more unified supervision to strengthen trust, reduce fragmentation, and enable cross-border investment. Additionally, addressing specific barriers such as differences in insolvency laws and withholding tax procedures is crucial. These reforms can lower costs, reduce administrative complexity, and enable seamless cross-border portability of SIAs. We also support tax incentives to make SIAs easier to use across borders. Moreover, well-designed, targeted tax incentives can help direct savings toward transition-aligned investments, provided they deliver genuine additionality and are clearly linked to sustainability criteria. 2. Access to a wide range of credible products We support giving citizens access to a broad and diverse range of investment products, including equity and debt that fund the green transition and address financing gaps in key sectors. However, eligibility must ensure alignment with EU transition goals. This requires clear and comparable information on the environmental and social impacts of investment products to avoid greenwashing and enable informed choices by citizens. We see strong value in integrating SIU development with high-level EU policy objectives, such as the European Green Deal (EGD) and the Clean Industrial Deal (CID). We believe SIU-related rules should align with: -Private finance regulation that raises transparency of ESG-related information (e.g. CSRD, SFDR, Taxonomy) to better allocate private capital flows; -National-level public finance regulations to ensure coherent, whole-of-government transition strategies. There is currently too little in the Commissions proposal that provides concrete incentives to increase capital allocation in green and transition investments. We recommend that products accessible via SIAs should meet minimum sustainability disclosure requirements, consistent with existing EU frameworks like SFDR, Taxonomy, and transition planning obligations under CSRD, CSDDD, CRR/CRD, and Solvency II. This will ensure SIAs genuinely support transition objectives and mobilise private capital in line with Europes climate and sustainability targets. Conclusion Overall, we see SIU as a crucial mechanism to unlock Europes 37 trillion in private savings for the green transition. With careful design, clear sustainability criteria, harmonised regulations, and strong governance, SIAs can channel private capital toward investments that deliver innovation, competitiveness, and long-term economic resilience. We encourage the Commission to ensure that SIAs are designed to genuinely support Europes competitiveness and climate goals, strengthen investor confidence, and deepen Europes capital markets in a way that delivers clear added value for citizens and the transition.
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Meeting with Alexandre Paquot (Director Climate Action)

19 Jun 2025 · Lead Market

Meeting with Miguel Jose Garcia Jones (Cabinet of Commissioner Wopke Hoekstra)

19 Jun 2025 · Discussion on challenges of industrial decarbonisation

Meeting with Olivia Gippner (Cabinet of Commissioner Wopke Hoekstra)

12 Jun 2025 · Exchange on the PPCA and the No new coal alliance

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

11 Jun 2025 · Introductory meeting / Investment Protection / Clean Trade and Investment Partnerships

Meeting with Maria Teresa Fabregas Fernandez (Director Structural Reform Support)

10 Jun 2025 · Exchange of views on the Multiannual Financial Framework’s (MFF) role to enhance climate action coordination

Meeting with Diana Acconcia (Director Climate Action)

21 May 2025 · Circle of Finance Ministers and programme of London Climate Week

Meeting with Joan Canton (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

19 May 2025 · Preparation Industrial decarbonisation accelerator act

Meeting with Jan Dusik (Deputy Director-General Climate Action)

13 May 2025 · Meeting with E3G - International climate politics

Meeting with Jan Dusik (Deputy Director-General Climate Action)

13 May 2025 · International climate politics

E3G urges mandatory green criteria for EU public procurement

6 Mar 2025
Topic — Evaluation of EU rules governing public contracts and concession awards across sectors.
Message — The organization requests mandatory minimum requirements for green and social public procurement. They advocate for alignment with climate goals and explicit net-zero purchasing targets. The revision must provide legal clarity through strong environmental criteria.123
Why — Standardized rules would provide the market certainty needed to scale net-zero technologies.4
Impact — Low-cost bidders and foreign firms lose competitive advantages gained from lower environmental standards.56
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Meeting with Aurore Lalucq (Member of the European Parliament, Rapporteur) and WWF European Policy Programme and Fairshare Educational Foundation (ShareAction)

6 Mar 2025 · Omnibus, Sustainable Finance, SIU

Meeting with Cécile Hanoune (Head of Unit Climate Action)

28 Feb 2025 · Climate governance, European Semester and next EU budget

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

20 Feb 2025 · Exchange on the upcoming Omnibus

Meeting with Charlotte Merlier (Cabinet of Commissioner Maroš Šefčovič)

18 Feb 2025 · Discussion related to Clean Trade and Investment Partnerships (CTIP), in the context of the Clean Industrial Deal

Meeting with Aleksandra Kordecka (Cabinet of Executive Vice-President Stéphane Séjourné), Arthur Corbin (Cabinet of Executive Vice-President Stéphane Séjourné), Laia Pinos Mataro (Cabinet of Executive Vice-President Stéphane Séjourné) and

13 Feb 2025 · Clean Industrial Deal

Meeting with Elena Arveras (Cabinet of Commissioner Maria Luís Albuquerque) and WWF European Policy Programme

12 Feb 2025 · Sustainability Omnibus

Meeting with Gabriela Tschirkova (Cabinet of Commissioner Valdis Dombrovskis), Nicolo Brignoli (Cabinet of Commissioner Valdis Dombrovskis) and

10 Feb 2025 · Simplification

Meeting with Dan Jørgensen (Commissioner) and

30 Jan 2025 · Affordable Energy action Plan

Meeting with Nikola Minchev (Member of the European Parliament)

11 Dec 2024 · Meeting

Meeting with Antoine Bégasse (Cabinet of Commissioner Mairead Mcguinness) and WWF European Policy Programme and Fairshare Educational Foundation (ShareAction)

12 Nov 2024 · Capital markets, economic transition, corporate and sustainability

Meeting with Nicolo Brignoli (Cabinet of Executive Vice-President Valdis Dombrovskis) and WWF European Policy Programme and Fairshare Educational Foundation (ShareAction)

12 Nov 2024 · Sustainable finance

Meeting with Anne Bergenfelt (Cabinet of High Representative Josep Borrell Fontelles)

11 Apr 2024 · EU energy and climate diplomacy

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

14 Mar 2024 · Energy market

Response to Postponement of deadlines within the Accounting Directive for the adoption of certain ESRS

18 Dec 2023

E3G welcomes the possibility to respond to the open consultation launched by the European Commission on the postponement of sector-specific ESRS. We acknowledge the European Commissions commitment to establish a balanced regulatory framework for corporate sustainability reporting, targeted at achieving transparent, high-quality sustainability information while avoiding unnecessary burdens for companies. We understand that the proposal of a 2-year postponement in adoption of sector-specific ESRS is part of the Commissions strategy to cut red tape, namely reducing corporate reporting obligations by 25% without undermining sustainability objectives. Nonetheless, E3G is deeply concerned by the Commissions proposal to postpone critical sectoral guidance for sustainability reporting and believe this decision does not support the goal of reducing the administrative burden on businesses. On the contrary, standardisation helps achieve simplification for businesses reporting. The existing set of reporting requirements, established by the Corporate Sustainability Reporting Directive (CSRD) and its first set of sectoragnostic ESRS, must be complemented with sector-specific guidelines to properly account for sustainability information in a transparent, comparable and reliable manner. Only by doing so will the Commission put in place a balanced, robust and standardised reporting framework in Europe. In light of these considerations, we advise against postponing the adoption of all sector-specific ESRS by 2 years to June 2026. We suggest instead a phased-in approach for the publication and adoption of sector-specific ESRS. Read more in our full consultation response.
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Meeting with Michal Wiezik (Member of the European Parliament)

29 Nov 2023 · Industrial transformation in CEE

Meeting with Anne Bergenfelt (Cabinet of High Representative Josep Borrell Fontelles)

27 Oct 2023 · Climate change

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

26 Oct 2023 · Energy Transition

Meeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness) and Finance Watch and Fairshare Educational Foundation (ShareAction)

17 Oct 2023 · Sustainable finance

Meeting with Valeria Miceli (Cabinet of President Ursula von der Leyen) and WWF European Policy Programme and

28 Sept 2023 · Concerns on corporate sustainability reporting in view of the upcoming package on 25% reduction of reporting burden. They conveyed the message that sustainable finance should continue ensuring transparency for the green transition.

Response to Carbon capture utilisation and storage deployment

31 Aug 2023

Third Generation Environmentalism (E3G) welcomes the opportunity to respond to the Call for Evidence for the Industrial Carbon Management Strategy. The following statement accompanies and highlights additional points and priorities to the already submitted response to the consultation. The attachment contains a briefing outlining E3Gs views on an EU industrial carbon management framework, based on a robust set of guiding principles and safeguards, that can facilitate the deployment of high-value carbon capture. It further includes a recent publication by E3G and Bellona - the 'CCS ladder' - outlining a framework to determine 'high-value' CCS applications for Europe. One way or another, it seems clear that CCS (and CDR, CCU) and the politics surrounding their deployment will play a key role in the next phase of the European Green Deals implementation. We propose a set of overarching principles to help mitigate the risks and concerns associated with these technologies that can form the foundations of an EU industrial carbon management strategy. 1. Focus explicitly on delivering climate neutrality. The development of carbon capture technologies can only be pursued as a means to reach our climate goals, rather than representing an end in itself through being supply-driven. CCS cannot be used as a distraction from the need to eliminate the unabated use of fossil fuels, including upstream, and to reduce emissions to the maximum extent possible. 2. CCS should not be considered the default emissions reduction option, especially, if there are credible alternatives for completely eliminating emissions. Overall, the highest value of CCS for climate action can only be achieved if all other measures are deployed at the necessary scale and pace. Drastic reductions in fossil fuel usage, combined with a strong emphasis on energy efficiency and lowering primary energy demand, are necessary to reach climate targets and limit the risk of potential overreliance on CCS which could itself compromise climate objectives. 3. Target support where it will provide the most added value. While the theoretical availability of CO2 storage sites is substantial, in practice there are many factors that could constrain the pace and scale of actual storage development. To navigate these constraints and avoid the public sector at both EU and national levels bearing an undue burden, support for CCS should be targeted to applications that provide the most added value in terms of emissions reductions that cannot be achieved through other means. In short, we argue CCS is most valuable for industrial processes which align with all of the following conditions, where: 1) There are limited alternatives for deep decarbonisation/defossilisation; 2) CCS has a significant emissions reduction potential; 3) CCS has (relatively) limited feasibility challenges to scale and deliver emission reductions based on costs, location and/or size of individual CO2 sources, and 4) CCS has limited negative side effects such as fossil fuel lock-in (see attachment for further details). We urge the European Commission to set out its own set of guiding principles, guardrails and value assessments. Further, it is good to see CDR treated separately from that of CCS (and CCU). CDR is the process of permanently removing CO2 from the atmosphere and storing it to produce a net CO2 reduction. It has its own distinct set of challenges and trade-offs, which should not be conflated with those of CCS (and CCU). CDR will only enable economy-wide negative emissions once the vast majority of emissions have already been abated the hardest to abate emissions are those already emitted. Public support for CCU needs to be considered case by case, as the climate benefits of most CCU applications are questionable, and could simply lead to a displacement of emissions. Full life cycle assessments are a necessity.
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Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans)

12 Jul 2023 · Renewables potential in CEE

Meeting with Damyana Stoynova (Cabinet of Executive Vice-President Frans Timmermans)

6 Jul 2023 · Climate mis- and desinformation

Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans) and Climate Action Network Europe and

4 Jul 2023 · Electricity Market Design Reform

E3G urges science-based 2040 climate targets and gas phase-out

22 Jun 2023
Topic — The EU is establishing a 2040 climate target to reach net-zero by 2050.
Message — E3G recommends using the latest scientific evidence to set a 2040 climate target. They suggest shorter five-year policy cycles and a total phase-out of gas by 2040.123
Why — Prioritizing scientific input increases the legitimacy and influence of this climate-focused think tank.4
Impact — Gas suppliers and carbon-intensive power plants would face early closures and extreme costs.5
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Meeting with Francisco Barros Castro (Cabinet of Commissioner Elisa Ferreira), Wioletta Dunin-Majewska (Cabinet of Commissioner Elisa Ferreira)

7 Jun 2023 · Presentation of E3G's report: Making clean technology value chains work for EU economic convergence

Meeting with Anne Bergenfelt (Cabinet of High Representative Josep Borrell Fontelles)

25 May 2023 · Climate change, peace and security

Meeting with Silvia Modig (Member of the European Parliament, Rapporteur for opinion) and European Environmental Bureau and

19 Apr 2023 · Net Zero Industry Act (staff level)

Meeting with Tiemo Wölken (Member of the European Parliament)

28 Mar 2023 · 2040-Klimaziel, ESABCC-Bericht (Staff level)

Meeting with Maria Angela Danzì (Member of the European Parliament)

21 Mar 2023 · CSDDD

Meeting with Nils Torvalds (Member of the European Parliament)

20 Feb 2023 · Climate law

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

20 Feb 2023 · Net zero industry act and hydrogen bank

Meeting with Ciarán Cuffe (Member of the European Parliament, Rapporteur) and Stichting European Climate Foundation and

7 Feb 2023 · EPBD

Meeting with Ditte Juul-Joergensen (Director-General Energy) and Bureau Européen des Unions de Consommateurs and

20 Jan 2023 · U.S.-EU Task Force: Best practices in Energy Savings and Flexibility Other participants: Cleantech-Cluster Energy, ELVIA, EU DSO Entity, California Energy Commission, ASE, AEE, ComEd, Octopus Energy, OPower, Uplight

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis)

12 Dec 2022 · Trade and climate

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

28 Nov 2022 · COP28

Meeting with Anne Bergenfelt (Cabinet of High Representative Josep Borrell Fontelles)

28 Nov 2022 · Climate Diplomacy

Meeting with Frans Timmermans (Executive Vice-President) and Climate Action Network Europe and

15 Nov 2022 · Progress of COP27 negotiations

Meeting with Sandra Bartelt (Cabinet of Commissioner Jutta Urpilainen)

19 Oct 2022 · Global Gateway

Meeting with Kevin Keary (Cabinet of Executive Vice-President Valdis Dombrovskis)

18 Oct 2022 · Global Gateway

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

8 Aug 2022

E3G welcomes the opportunity to contribute to new reporting requirements on National Energy and Climate Plans (NECPs). Given that the NECPs serve as one of the primary tools to guide Member States’ climate and energy transitions in a coherent and just manner, it is crucial that the reporting requirements be comprehensive enough to facilitate effective decision and policy making. NECPs should essentially be a tool to identify best and worst practices, with enough detail to duplicate or drop past policy actions. 1) In order for the NECPs to deliver their potential impact, they should encompass a whole-of-society approach to energy and climate policy. The plans should be consistent with other structural plans and governance mechanisms, such as the Social Climate Plans, the National Reform Programmes and Stability/Convergence Programmes of the European Semester, and Long Term Strategies. A coherent approach to EU governance reporting obligations, within which the goals and targets of the different cycles are fully respected, should enable the capitals to integrate different reporting cycles while limiting administrative burden. In the long term, this could mean referring to parallel reporting and merging different reporting obligations accordingly. 2) It is important to note that the above goals will be challenging unless reporting against all indicators is made ‘mandatory’ instead of ‘voluntary’. Necessitating information that has a social dimension establishes the important links between the different policy domains of energy, housing, health, and social policy. The Commission should work with Member States to provide further guidance, as in the case of the Council Recommendation on a fair transition to climate neutrality. 3) In light of the current geopolitical context and REPowerEU, new reporting obligations rightly include additional information on energy efficiency, energy security and energy savings. The inclusion of air quality, multilevel dialogue, energy poverty, and just transition is also a positive development. The reporting template nonetheless includes certain gaps that need to be addressed to ensure robust data collection that can tackle energy poverty in all of its complexity, thereby guiding bespoke policymaking. To this end, we recommend extending reporting metrics to reflect the multidimensional nature of energy poverty and just transition. Table 2 of Annex XIX (energy poverty) has a narrow focus on indoor heating despite growing evidence that an increasing number of European households are unable to keep their homes cool in the summer, consequently suffering from adverse health impacts. As Europe experiences record-breaking heatwaves, expected to become more intense and frequent due to climate change, Member States should also include indicators that capture summertime energy poverty. Annex XX on just transition does not sufficiently capture vulnerability to energy poverty. In addition to gender, aspects of race and (dis)ability should also be prioritised to counter disparities in access to energy. The inclusion of these aspects will help uncover the intersections between social determinants and energy insecurity, thereby facilitating the creation of more targeted measures. 4) Reporting on multilevel dialogue (Annex XXIII) must include a much stronger effort to strengthen public participation and establish meaningful dialogue with all affected stakeholders, especially the most vulnerable citizens. Details concerning participatory processes should not only include who participates but also how their participation has been enabled, and how participation will be facilitated from agenda setting to implementation and monitoring. E3G is an independent climate change think tank accelerating the transition to a climate-safe world for all. For more information, please contact namita.kambli@e3g.org or taube.vanmelkebeke@e3g.org
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E3G Urges Stronger Corporate Climate Accountability and Broader Scope

23 May 2022
Topic — EU consultation on improving corporate governance to foster sustainable long-term value creation.
Message — E3G recommends expanding the Directive to companies with 250 employees and including SMEs in high-risk sectors. They want mandatory links between executive pay and sustainability targets while defining climate due diligence. Human rights protections must cover the entire supply chain.123
Why — These measures align corporate strategies with global climate goals and ensure long-term stability.45
Impact — Smaller companies in high-risk sectors would face new, burdensome regulatory compliance requirements.6
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Meeting with Damyana Stoynova (Cabinet of Executive Vice-President Frans Timmermans)

6 Apr 2022 · Preparations for COP27 and engagement with international partners

Meeting with Markus Pieper (Member of the European Parliament, Rapporteur) and UPM-Kymmene Oyj

14 Mar 2022 · RED III

Meeting with Kadri Simson (Commissioner) and

3 Dec 2021 · Discussion on upcoming Hydrogen and Decarbonised Gas Markets Package (adoption foreseen for 14.12.2021)

Meeting with Stefano Grassi (Cabinet of Commissioner Kadri Simson) and Transport and Environment (European Federation for Transport and Environment) and

2 Dec 2021 · EPBD - Energy efficiency - Minimum Energy Performance Standards

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

19 Nov 2021

E3G welcomes the update of the Energy Efficiency Directive (EED) to align it with the Climate Law and the need to limit global warming to 1.5˚C. While E3G is generally supportive of the direction of the proposal, the directive needs to be improved to meet European climate targets and ambition. The draft recast contains useful provisions that need to be safeguarded, and others that need strengthening. A few items risk undermining climate progress and should therefore be deleted. We welcome the introduction of a proper provision for the Energy Efficiency First Principle, opening the door to tangible application. But as it stands, both in the article and in the flanking texts (recitals and annexed guidelines), there are still uncertainties and discrepancies, on the scope of the article and its enforcement. The recommendations to Member States contain more actionable wording that would benefit the directive if they became binding provisions. Legislators should seek to more strongly embed reporting on the application of the Principle (to governing planning, policy and investment decisions) in the Renewable Energy directive (RED) and ETS-backed funds. We welcome that the draft recast raises both the EU and the national energy efficiency targets, but they are still below the cost-effective potential, and governance is still too loose to ensure full compliance by all Member States. The overall ambition should be increased to 45% (compared to PRIMES 2007) and national contributions need to be binding to ensure they all contribute in a fair way, and the annual saving obligation should be increased to 2% from 2024. The provisions on the exemplary role of public buildings hold the potential to give a much-needed push to scale up deep renovation. Their scope should be extended, not only to all publicly owned buildings but to publicly occupied buildings too. We welcome the fact that renovation depth is being pegged to Nearly Zero Energy Building standard, which may be strengthened in the revision to the Energy Performance of Buildings directive, and that alternative compliance options are removed. The dedicated section on energy poverty is a step in the right direction. To complement the EED and help tackle the structural challenge of volatile energy prices, there is an opportunity to upgrade the Commission’s Energy Poverty Observatory to track a) Member States’ annual energy savings to be achieved in energy poor households under the recast EED, and b) renewable H&C support measures Member states will have to make available to low income and vulnerable households under the revised RED. It could deliver independent measurement, evaluation and technical assistance: for energy poverty levels in the EU, EED and RED progress, and Climate Action Social Plans and their implementation. The phasing out of incentives for gas boilers as of 2025, in article 8, is decisive for aligning the EED with climate commitments and ensuring the incentive is directed towards clean, sustainable heating and cooling (H&C) solutions. Permitting fossil gas, no matter how efficient, to contribute to energy savings is a risk of delaying the unavoidable phase out of fossil fuels, and of artificially extending the lifespan of outdated systems, when a complete shift away from combustion is needed. We know that combustion technologies entail climate, health and efficiency costs; the EED should pave the way to truly sustainable H&C solutions. The encouragement to local authorities to draw up H&C transition plans is welcome, but this requirement should, through nationally appropriate mechanisms, be extended to the municipalities themselves to reflect the critically local dimension of H&C infrastructures. The 50,000-inhabitant threshold for H&C assessments risks omitting rural areas from the need to draw up plans. E3G is an independent climate change think tank accelerating the transition to a climate-safe world for all. For more information: adeline.rochet@e3g.org
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Response to Social and labour aspects of the climate transition

19 Nov 2021

E3G welcomes the decision by the European Commission to provide guidance to Member States on addressing the social and labour aspects of the climate transition. To ensure an inclusive and socially fair transition, especially in the lead up to the establishment of a Social Climate Fund and the drafting of Social Climate Plans, we recommend the following: - Co-create a positive narrative of how climate action benefits people and communities With the first part of the Fit-for-55 package, the Commission has outlined how climate action can enhance wellbeing. This narrative now needs to be strengthened across all levels of government, in particular the local (urban and rural) levels, to foster societal acceptance of the necessary reforms. For this to happen, it will be important to move beyond the current language of ‘co-benefits’, such as affordable energy, gender equality, etc. as social add-ons and place these at the core of climate policy to cement its relevance to people’s everyday lives and strengthen public support. It will be equally important for governments to work with community champions, such as European Climate Pact Ambassadors, to collectively shape and communicate new narratives that speak to shared values, such as intergenerational solidarity, and make explicit the opportunities and benefits the European Green Deal can enable. - Put structural funds at the heart of just transition and align these across policy levels Structural funds frameworks are designed at regional and sub-regional level and should be informed by macro-opportunity and local socio-economic need. The European Social Fund (ESF), for instance, is one of the only training funds that also supports associated childcare and transport costs, which are crucial for women’s inclusion. While the added focus on youth employment and training as part of the ESF + is welcome, the scope of the Fund should go beyond upskilling and retraining to a life-long approach, to include the equipping of the very young with the creative education to access the emerging green and digital jobs of the future. This requires a holistic approach across EU funds, Directorates-General, and education and training strategies at the Member States and regional levels. A similar approach should also be adopted to align the Social Climate Fund with structural funds as well as the Just Transition Fund, to create greater synergies and multiply socio-economic benefits. - Involve citizens and local governments early in determining how revenues from the Social Climate Fund are spent. Part of the revenues allocated to the Social Climate Fund should be redirected to support mitigation and adaptation projects chosen by citizens at the local level, which is where the effects of climate change are acutely felt. The adoption of deliberative and participatory initiatives, such as green participatory budgeting, will not only raise awareness amongst citizens on the benefits of climate action, but also empower people, including marginalised groups, to become more involved in local governance, building democratic legitimacy. Involving those with the lowest propensity to take part is also a way to ensure no one is left behind, as those furthest from decision making tend to be disproportionately affected by climate change. Giving voice to these groups requires resources – both in terms of finance and human resources – to enable local governments to engage citizens and better co-design solutions. This should also leverage and connect with other relevant aspects of Fit-for-55 proposals, such as the ‘encouragement’ of local governments to draw up heating and cooling plans, and provisions to ‘consider’ the role of renewable and citizen energy communities in the Energy Efficiency Directive revision. Such provisions should be bolder and stronger. E3G is an independent climate change think tank accelerating the transition to a climate-safe world for all. For more information: namita.kambli@e3g.org
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Meeting with Kadri Simson (Commissioner) and

8 Nov 2021 · Gas market and security of supply framework.

Meeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness)

19 Oct 2021 · Sustainable Finance

Meeting with Pär Holmgren (Member of the European Parliament) and Climate Action Network Europe

7 Oct 2021 · COP26 (staff level)

Meeting with Olivia Gippner (Cabinet of Executive Vice-President Frans Timmermans)

14 Sept 2021 · Presentation of E3G’s briefing “Fit for Society: Benchmarks for a social Fit for 55 package”

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

13 Sept 2021 · Hydrogen and gas sector decarbonisation package

Response to Action plan on the digitalisation of the energy sector

9 Sept 2021

The roadmap document suggests the core focus of the action plan will be on ensuring digitalisation enables a more flexible energy system that increases asset utilisation and reduces costs of decarbonisation. Creating a flexible energy system is an extremely important objective. However, it would be a mistake to focus work purely on identifying how digitalisation can help consumers to provide services for the system. Instead, a more consumer-focused approach would be to identify how the digitalisation of energy can make consumers lives better as the system decarbonises. This is a subtle but important difference. Whilst the latter is likely to yield increased system flexibility, it is not the core objective. Digitalisation has the potential to play a major role in supporting consumer engagement with new zero carbon products and services, and to do so in a way that is fair and inclusive. It can be extremely complicated for consumers to navigate the range of options they face from a range of providers (efficiency, zero carbon heating and cooling, micro-generation, EV charging, home energy storage, etc), let alone understand the combined benefits and project manage delivery. Digital platforms (e.g. smartphone apps) can provide a seamless omni-channel experience, giving access to a wide range of products and services, providing rapid response, and defining a pathway to delivery. They can also rapidly diagnose feedback from consumer engagement, leading to fast learning and improvement in the consumer experience. Currently, the development of such platforms is being left to the market and is the basis for the competitive success of energy service providers. However, this can create ‘winner takes all’ problems which can threaten the effectiveness of digitalisation in driving better consumer outcomes: - Either the number of consumers able access the benefits of the best performing platform(s) is limited, often to those who can pay the highest price, or - One platform becomes dominant leading to concerns over market power affecting upstream and downstream competition. The key policy question, therefore, is how to promote innovation in platform development whilst maintaining access for all consumers and effective competition in service provision? Innovation tends to develop faster in the ITC sector than the energy sector, so making sure that stakeholder engagement extends beyond standard energy policy development processes and captures potential disruptors outside the sector will be key. Local government authorities are well-placed to play a key role in such efforts, given their direct understanding of citizens’ needs as the closest level of government to people. Please see the full consultation response attached for more detail on the considerations that should be taken into account in authorities' approach to platform development. A final issue that must be considered is the need to avoid energy industry actors using relationships with platform providers to exploit a dominant position and prevent competitors developing relationships with consumers. Whilst this is most likely to be a problem where monopoly utility providers exist , similar issues may emerge in those areas of Europe where competition is less well developed. Recommendations Digitalisation has a major role to play in improving consumer engagement with zero carbon products and services through providing a simple, fast, and seamless omni-channel experience. The action plan on the digitalisation of the energy system should explore whether regulations are required to ensure: • Innovation in digital platform development does not limit access for all consumers and effective competition in service provision. • Inclusive, transparent and fair access to digital platforms. • Digital platforms are designed to support the role of local authorities and cities in driving their own delivery agendas by highlighting and promoting local opportunities.
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Meeting with Frans Timmermans (Executive Vice-President) and European Environmental Bureau and

7 Sept 2021 · state of play on just transition planning in coal regions in Europe

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

22 Jun 2021 · Discussion on socially fair green transition

Meeting with Antoine Colombani (Cabinet of Executive Vice-President Frans Timmermans), Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans), Estela Pineiro-Kruik (Cabinet of Executive Vice-President Frans Timmermans), Stefanie Hiesinger (Cabinet of Executive Vice-President Frans Timmermans)

22 Jun 2021 · Virtual meeting on social dimension of Fit For 55 / European Green Deal

Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton)

14 Jun 2021 · Carbon border adjustment mechanism

Meeting with Antoine Colombani (Cabinet of Executive Vice-President Frans Timmermans)

7 Jun 2021 · CBAM

Meeting with Kurt Vandenberghe (Cabinet of President Ursula von der Leyen)

7 Jun 2021 · CBAM

Meeting with Wioletta Dunin-Majewska (Cabinet of Commissioner Elisa Ferreira)

1 Jun 2021 · Participation to the event “How to seize the potential for a green recovery in Central and Eastern Europe” and panel discussion.

Meeting with Thierry Breton (Commissioner) and European Environmental Bureau and

28 Apr 2021 · Exchange on the preparation of the update of the industrial strategy.

Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton) and European Environmental Bureau and

19 Apr 2021 · Industrial Strategy

Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton) and Notre Europe - Institut Jacques Delors / Notre Europe - Jacques Delors Institute and

22 Mar 2021 · Industrial strategy; green transition

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis), Cristina Rueda Catry (Cabinet of Executive Vice-President Valdis Dombrovskis)

15 Mar 2021 · Trade policy review; trade and climate

Response to Revision of EU rules on Gas

10 Mar 2021

The EU needs to deliver markets that are ‘fit for 55’ by 2030 and ensure that the needs of energy consumers are met in a world in which a variety of new energy solutions become available. These imply a reduction of 29-37% in fossil gas consumption by 2030. This dynamic will fundamentally transform the shape of the gas market. It will make it more fragmented as entire geographical entities are likely to stop using gas through bottom up policies. This points to the fact that the focus of current gas market policy on promoting gas-on-gas competition is not sufficient. Instead, we propose the following benchmarks of success: • Mitigate risk of “non-delivery”: Do zero greenhouse gas emission products and services have access to the highest value markets such that scarce and high value resources are not constrained to low value markets where alternatives products and services exist? • Enhance competition and cost-effectiveness: Is fair competition across the energy sector embedded in infrastructure planning processes to allow consumers access to the best value products? • Deliver a fair transition: Has an appropriate balance been struck between maintaining incentives for consumers to move away from fossil gas usage whilst avoiding high penalties for those unable or unwilling to do so? • Ensure climate value: Do the measures lead to a material reduction in unabated fossil fuel consumption in line with climate targets and are conditions put in place to maximise the deployment of fully climate neutral solutions? Are we avoiding a lock-in to fossil gas? To do that we recommend to: - change the framing of the package and orient it around markets for essential net-zero emissions services (e.g. a package for markets that deliver zero-emissions heat) instead of around an energy vector like gas; or, at the very least, to add a fourth policy option is added to explore increasing competition between gaseous solutions and other energy solutions - consider the implementation of the Energy Efficiency First principle across all options. - introduce a combination of regulatory and fiscal measures to enable consumers to make climate neutral choices and to ensure that measures such as the potential extension of the ETS do not penalise consumers who cannot choose stopping gas use. - include a mechanism to avoid lock in risks. - develop principles for fair allocation of gas system costs and require governments to develop plans to phase out fossil fuel subsidies. - strengthen the role of citizens in developing local fossil fuel phase out plans and strengthen consumer protection - ensure the market is designed in a way that scarce and inefficient resources, such as hydrogen, can be allocated to where they add most value - Implement a reformed governance to aid the design of efficient (market and other) delivery mechanisms, enhance our ability to respond to innovation as well as strengthen the potential for geographical cohesion. - ensure the polluter pays principle is adhered to and risks of non delivery of hydrogen are not borne by the citizen - carry out a careful review of some of the underlying assumptions in the current policy option framing and validate against independent science. (more detail in the attached file)
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Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans)

25 Feb 2021 · On-going E3G projects on just transition

Meeting with Anne Bergenfelt (Cabinet of High Representative Josep Borrell Fontelles)

10 Feb 2021 · Climate diplomacy

Meeting with Kitti Nyitrai (Cabinet of Commissioner Kadri Simson) and Climate Action Network Europe and

14 Jan 2021 · TEN-E

Meeting with Anthony Agotha (Cabinet of Executive Vice-President Frans Timmermans)

13 Nov 2020 · European Green Deal Diplomacy and civil society

Meeting with Antoine Colombani (Cabinet of Executive Vice-President Frans Timmermans)

30 Oct 2020 · Sustainable finance

Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans), Riccardo Maggi (Cabinet of Executive Vice-President Frans Timmermans)

15 Oct 2020 · Energy diplomacy and Green Deal priorities

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis) and Transport and Environment (European Federation for Transport and Environment) and

15 Sept 2020 · Sustainable finance

Meeting with Gaelle Garnier (Cabinet of Commissioner Thierry Breton) and European Environmental Bureau and

8 Sept 2020 · Clean Hydrogen Alliance launch

Response to Communication on the future of research and innovation and the European Research Area

31 Jul 2020

Research and Innovation (R&I) has been recognised by the EU as central to delivering the 2050 climate neutrality objective through the European Green Deal as well as building the foundation for Europe’s economic prosperity and resilience in the COVID-19 recovery. The upcoming European Commission Communication on the future of Research and Innovation and the European Research Area (ERA) is the opportunity to articulate how EU R&I policy will contribute to the climate neutrality objective. EU R&I policy and the revitalised ERA should place the challenge of achieving climate neutrality by 2050 at its heart, catalysing a successful transition by ensuring its benefits are spread across all member states and channelling open cooperation with international partners. --> ERA mission and governance at EU level Delivering climate neutrality by 2050 will require a deep reorganisation of EU R&I around achieving system-level innovation. In order to achieve this, the European Research Area should embrace a challenge-based approach to EU R&I and incorporate solutions from socio-economic disciplines to ensure innovation spans beyond technology. An adequate governance structure for climate R&I within the ERA is needed: such an institution would define a roadmap of R&I needs for emissions reductions, efficiently allocate resources across sectors and centralise learning. Financially, supporting the whole innovation chain under an R&I funding ‘one stop shop’ would ensure funding alignment, increase accessibility, avoid duplication and maximise value. --> ERA supporting R&I at member state level In order to support the climate neutrality transition and allow the EU to deploy its full potential, the ERA must ensure that R&I benefits and developments are socially and geographically inclusive. The ERA should reorient towards widening participation in climate R&I and building expertise in member states and regions that have been lagging. European funding and capacity-building support, coupled with systematic integration of all member states in new decarbonisation value chains, can in this way complement national commitments to reap the benefits of clean R&I across Europe. In addition, more systematic support for social innovation solutions has the potential to both increase citizens’ ownership of the transition towards climate neutrality, empowering them as actors and drivers of the process, and contribute to the development of place-based innovation approaches with greater local relevance. --> ERA engaging international R&I players The ERA has the potential to leverage EU R&I attractiveness to channel cooperation with foreign R&I stakeholders towards solving decarbonisation challenges that require pooling of technologies and know-how. Global decarbonisation represents an opportunity for the European economy to boost its competitiveness by driving climate neutrality through innovative European technologies, processes and business models. European innovation leadership and deployment expertise in certain sectors is well-recognised, and if mobilised through international relations has the potential to solve socio-technological challenges in achieving climate neutrality outside its borders, as well as develop markets for EU technologies. Such cooperation would have greater chances of success if negotiated as part of bilateral trade or investment agreements, and if focused on areas of lower competitive threat or large joint benefit. The EU’s ‘climate-neutral and smart cities’ mission is one example of an initiative that could be replicated internationally and create stronger synergies with existing city cooperation schemes such as C40, ICLEI or Covenant of Mayors.
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Response to EU Strategy on Adaptation to Climate Change

30 Jun 2020

E3G welcomes the decision by the European Commission to update the EU’s Strategy on Adaptation to Climate Change, in light of the European Green Deal and the need to “recover better” from the COVID-19 crisis. To develop a strategy that better protects Europeans, E3G makes the following recommendations: 1. Build a systemic approach As a fundamentally systemic risk, climate change requires a systemic strategy that breaks down silos through reforming responsibilities, institutions, and funding. Concretely: • The strategy should encourage Member States to develop action plans that stress test how their key economic sectors, infrastructure and critical systems will withstand different global warming scenarios and identify the necessary short-to-medium term actions to reduce vulnerabilities, building on existing adaptation strategies. • This regular exercise could be supported by establishing a European independent climate risk observatory responsible for monitoring systemic risks across EU sectors and supply chains and recommending appropriate policy responses through objective and evidence-based analysis. • The insight of those most affected will be key from development to implementation. An inclusive dialogue should be established to engage with critical sectors (like health, finance, and agriculture) and the most vulnerable communities, building on the European Climate Pact. 2. Invest in resilience and cohesion The European Environment Agency has projected that climate impacts will vary strongly across the EU, creating and reinforcing geographical divides. Aligning EU finances with a revamped Adaptation Strategy is the only efficient way to build a Europe that protects its citizens and ensures cohesion between regions. The new strategy will need to consider how to incentivize investments that build resilience: • With climate disclosure on the rise, climate-vulnerable regions are increasingly exposed to the risk of capital flight. A climate risk observatory could be key to assessing the socio-economic impacts of insurance coverage gaps and credit flight from vulnerable sectors or communities. • Developing a European climate-related disaster risk pool (i.e. pooling risks and funds from insurance companies, private and public actors) can provide a rapid and cost-effective response to catastrophic events such as floods or fires while ensuring solidarity across European regions. • De-risking investments in adaptation and resilience is key to unlocking stronger private finance. The strategy could support this by expanding technical assistance to public finance institutions on developing resilience bonds. 3. Bring adaptation and resilience to European diplomacy Adaptation and loss and damage have taken on new significance for the most vulnerable developing countries in the face of increasingly material climate impacts. A geopolitical EU must: • Build a better understanding of the risk it is exposed to beyond its borders. An observatory could assess and monitor risks stemming from climate change impacts in the EU Neighborhood and along critical supply chains. • Develop a more systematic approach in the cooperation with international partners and allies, co-developing supply chain and climate-related security risks resilience strategies. • Resilience is a priority issue for developing countries, particularly for the Least Developed Countries and Small Island Developing States. They are expecting enhanced attention to and support for adaptation and resilience, including evidence that developed countries are making good faith efforts to maintain a credible pathway to the 1.5°C goal. COVID-19 also means there will be an even greater need for support and solidarity to developing countries and the resilience of their economies, which are under strain due to drops in tourism and debt distress. E3G is an independent climate change think tank accelerating the transition to a climate-safe world. For more information: Taylor.Dimsdale@e3g.
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Response to Strategy for smart sector integration

8 Jun 2020

The energy system is approaching two major tipping points. Separate parallel systems are increasingly interconnected with electricity becoming the dominant connecting vector; and system operators now need to dynamically adjust both supply and demand to maintain system stability rather than relying purely on supply. Against this backdrop, E3G have identified the following four challenges that need to be addressed to enable for a more integrated energy system that can deliver climate neutrality: 1. Establishing a framework to inform choices across energy system solutions and actively manage risks, e.g. through an independent expert body/a Clean Economy Observatory 2. Making the most of new sources of competition between infrastructures & energy system solutions, e.g. by ensuring that the way we reward an remunerate supply side and demand side infrastructures ensures equal market access for equal services and by removing subsidies inconsistent with climate objectives. 3. Defining future need in administered markets, especially where this involves consumer purchasing decisions. There’s a need for a review over in which markets consumer behaviours is the best source for competition and in which markets regulatory intervention is needed to achieve system change/decarbonisation objectives. The latter may be the case where consumer choice is limited by other factors, e.g. large scale infrastructure transformation, the former where multiple solutions to deliver an outcome exist and only barriers to consumer access and competition need to be improved. 4. Ensuring equitable cost and benefit sharing, in particular for vulnerable customers. As consumers transition between systems it is important that vulnerable consumers are identified early and their shift to systems with lower operational costs is supported. Similarly, cost and benefit sharing between Member States needs to be revised should Members States opt for different pathways (eg high vs low H2,…) The attached paper sketches these challenges and potential solutions out further, as well as this blog: https://www.e3g.org/library/sector-integration-shifting-energy-system-paradigms.
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Response to A EU hydrogen strategy

5 Jun 2020

The journey to climate neutrality will not be easy and the ability to produce zero emissions gases is an important part of the decarbonisation toolbox. Current policy and regulatory processes are not well suited to making meaningful decisions on this issue. The hydrogen strategy should be seen as an opportunity for a new regulatory and planning approach. Significant uncertainty over future cost, availability of and need for hydrogen makes it difficult to take planning and market regulation decisions. Many studies published cloud this uncertainty by presenting single point estimates for costs and volumes or omitting crucial factors (e.g. methane emissions or CCS infrastructure costs). The prospect of risky binary decisions means there is often a focus on “wait and see” and “pilot projects” which is not sufficient for the scale and speed of the transition needed. Strengthening Europe’s ability to carry out evidence-based whole energy system analysis, accelerate learning and manage risks is required to enable climate neutrality and the deployment of hydrogen. We recommend:  Current best evidence suggests that the success of zero emissions hydrogen is dependent on delivering efficiency, renewables and electrification.  The legitimacy of a hydrogen strategy and the associated costs and investments hinges on its ability to contribute to emissions reductions through a simultaneous phaseout of unabated fossil gas. A successful hydrogen strategy thus is accompanied by clear measures and milestones towards a phaseout of unabated fossil gas.  The EU Hydrogen Strategy must recognise the foundational role that an evidence-based pathway choice mechanism plays in allowing other players – regulators, investors, consumers – to implement a smooth and efficient transition. If needed, to expedite the process until a proper whole systems independent governance structure is in place, an independent expert group on hydrogen should advise on core interventions in line with the EU’s climate objectives. Decisions of this strategic importance need to be based on best evidence and high transparency and be free from vested interests.  For hydrogen to play a role, energy markets need to be framed around outcomes. These markets must ensure key outcomes are delivered efficiently, promoting fair competition between different technologies. Obstacles to fair competition between unabated fossil gas and all its alternatives, including hydrogen, need to be removed. This includes fossil fuel subsidies (e.g. exemptions from VAT). There are many system-level risks to be managed if hydrogen is developed at scale:  A certificate system to trace the origin and greenhouse gas content of new gases should include scope 3 emissions from methane. But this will not ensure sustainability by itself. If new gases are developed, the total volumes must be capped at the volume of the sustainably available potential.  Distribution-level network utilisation may reduce as users electrify and reduce energy demands. The social impact on remaining users will need to be managed, in particular if new investments into hydrogen use are made and the cost of hydrogen continues to be higher than those of fossil gas.  Imports of blue hydrogen need to be contingent on measures to drastically and speedily reduce methane emissions. For green hydrogen, evidence suggests that cost differentials on renewables costs are eliminated by shipping costs, imports from water scarce regions need careful management of water use, and for many of EU neighbours the development of renewable electricity for domestic use is a more effective contribution towards combatting climate change for at least another couple of decades. In the context of an economic recovery towards more regional resilience and stability, EU engagement in its neighbourhood should support a growth strategy that reduces dependence on the export of a single commodity the price of which is determined on global markets.
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Response to Revision of the guidelines for trans-European Energy infrastructure

5 Jun 2020

Context: The EU has committed to achieving climate neutrality by 2050 but is currently falling short in meeting its energy and climate targets already for 2030. Despite that, energy infrastructure is rightly recognized as a key enabler for the transition. The EIB reports that infrastructure investments decreased in the period 2009-2017, grid investments in Europe have stalled not bringing the necessary expansion and digitization. The TEN E revision takes place in the framework of the COVID-19 recovery and the EU Green Deal development. Recommendations for the evaluation process: The general objective of the TEN E revision should be to successfully contribute to both the economic recovery and the delivery of the EU Green Deal objective. To do so, the next TEN E must: 1. Align with new policies and objectives, in particular the new EU climate objectives. This means to reconsider current infrastructure categories and priority corridors/thematic areas and update them coherently with the future infrastructure needs 2. Enable best and most cost-effective technology deployment and system integration in view of these objectives. For this, we need to rethink the current infrastructure governance to deliver fast learning and fair competition 3. Support only investments that contribute to achieving net-0 – update TEN-E eligibility and the selection criteria for PCIs If done well, the revision is likely to have economic impacts on only on supply-side stakeholders, but also on demand-side ones. The Commission rightly mentions the efficiency first principle as a way to reinforce sustainability criteria for PCIs. To be implemented, energy efficiency and demand-response stakeholders must be involved in the process next to TSOs, DSOs and National Regulatory Authorities. Social impacts will indeed fall on consumers, including households. The TEN E regulation has the potential to contribute to reducing energy poverty, strengthening energy security and resilience, and creating jobs, only if done right. Consumers’ organizations should be involved in the TEN E discussions to ensure taxpayers money will only be spent at their benefit. Following the adoption of the 4th PCIs list, the Commission has committed to only include projects contributing to achieving the Green Deal objective in future lists. The sustainability criteria, currently under development, should use as minimum benchmarks the Sustainable finance taxonomy and EIB energy lending policy. They also need to be ready before the adoption of the 5th PCIs list. Transparency must be ensured when defining this methodology and PCI projects should be updated as soon as the new TEN E regulation will be agreed. For more input, see the attached paper. Recommended additional reading: ACER opinion: https://acer.europa.eu/Official_documents/Acts_of_the_Agency/Opinions/Opinions/ACER%20Opinion%2014-2019%20on%20the%20ENTSOG%20draft%20TYNDP%202018.pdf ACER-CEER paper: https://www.ceer.eu/documents/104400/-/-/f1846269-a27b-b3db-5edc-697b9156d3c4 Artelys report on Gas Supply Security: https://bit.ly/2XtXjMk BPIE report: https://www.energyunionchoices.eu/wp-content/uploads/2017/08/Safeguarding-energy-security-in-South-East-Europe-with-investment-in-demand-side-infrastructure.pdf E3G on CCS: https://www.e3g.org/library/european-ccs-learning-from-failure-or-failing-to-learn-summary E3G on EU investments in gas: https://www.e3g.org/docs/03_03_20_E3G_Gas_Investment_Transition_Risk.pdf E3G on Breaking the logjam: https://www.e3g.org/library/briefing-summary-eu-energy-system-decarbonisation-policy-breaking-logjam ECF on fossil free https://europeanclimate.org/wp-content/uploads/2019/03/Towards-Fossil-Free-Energy-in-2050.pdf EIB energy lending policy https://www.eib.org/attachments/strategies/eib_energy_lending_policy_en.pdf EIB investment report https://www.eib.org/en/publications/investment-report-2019 Global Monitor report on New Gas Boom https://bit.ly/3gSHDtI
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Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans)

5 Jun 2020 · European Green Deal and biodiversity

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

23 Apr 2020 · European Green Deal and Recovery

Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans), Riccardo Maggi (Cabinet of Executive Vice-President Frans Timmermans)

26 Mar 2020 · TEN-E review

Meeting with Anne Bergenfelt (Cabinet of High Representative Josep Borrell Fontelles)

2 Mar 2020 · Political Scenarios for COP26/2020

Meeting with Antoine Colombani (Cabinet of Executive Vice-President Frans Timmermans)

28 Feb 2020 · Green Deal and industrial policy

Response to Climate Law

6 Feb 2020

The upcoming EU climate law will help closing some of the gaps of the current European governance framework. The law should enshrine the objective of reaching climate neutrality by 2050 at the latest EU-wide, and a trajectory to reach it. It should complement the Energy and Climate Governance regulation. The law should precise the legal status and governance context of the national long-term strategies. The law should set revised 2030 targets. At the very least, the law should set the process by which these targets are adopted, in line with the international rhythm. According to this logic, the Commission will publish the impact assessment for enhanced climate ambition ahead of international stocktakes. This year, the Commission should release its analysis of the headline targets before the March European Council. The current adaptation framework at EU-level should be strengthened to elevate the political discussion on climate impacts and trigger additional actions at local and national levels. The European Commission (or another institution) should be mandated to monitor and prepare for evolving climate impacts in Europe. This should go beyond the monitoring of the current impacts, with a focus on foresight under different scenarios, including above 2C of global warming. The current institutional duo European Commission – European Environment Agency does not have the mandate nor the capacity to monitor, suggest and facilitate the actions required during the next stage of the decarbonisation. Besides, there is value in decentralised and sector-specific governance system as more out-of-the-box models might be required considering the specificities of the sectors concerned. The several governance frameworks currently co-existing in the EU should be aligned to deliver climate neutrality. But also, it must be recognised that each economic sector probably needs a specific governance model. While the industry sector probably requires a more top-down approach with mandatory targets, cities and regions’ actions should be incentivised. For instance, the Commission should develop common methodologies for carbon budgeting or resilience action at local level. The law should require that every economic sector is ruled by a framework fit for purpose and that delivers the results. The Commission should lead a yearly evaluation and if necessary, trigger an upward revision of sectoral efforts, both in terms of ambition of the targets and stringency of the governance. The law should confirm the duty for all policies to actively contribute to climate neutrality and increase Europe’s resilience. Conversely, the law should prohibit any European action that goes against the trajectory to reach climate neutrality. The Commission should set up an internal process to guarantee this goal is reached. But it should also rely on external institutions to provide advice to national, regional and local actors to identify any major contradictions. It should become a mandatory test for any funding released or initiatives taken. The Commission should use the existing processes (EU Semester, EU Climate and Energy Union Governance, social dialogues) to guarantee that there is a unity of action at European level but also across different levels of governance.
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Meeting with Kurt Vandenberghe (Cabinet of President Ursula von der Leyen)

6 Feb 2020 · bring more Europe into the national climate and energy debate in Germany

Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans), Riccardo Maggi (Cabinet of Executive Vice-President Frans Timmermans) and WWF European Policy Programme

17 Dec 2019 · Just Transition

Meeting with Elina Melngaile (Cabinet of Vice-President Valdis Dombrovskis)

21 Nov 2019 · EU Green Finance strategy; climate resilience; updated EU disclosure and reporting regime

Meeting with Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen)

20 Nov 2019 · Exchange of views on EU ambitions on climate neutrality by 2050

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

16 Oct 2019 · UNFCCC and European Green Deal

Response to European Partnership for Clean Hydrogen

31 Jul 2019

Dear all, we would like to share with you some of the recent evidence available regarding alternative gases (incl hydrogen) below and in particular highlight the following two dimensions relevant for the shape and priorities of the initiative: - Aligning with the Paris Agreement: In light of the Paris Agreement and the aim of achieving climate neutrality by mid-century it is important that this initiative only supports research that has validity in a net-zero emissions world. Hydrogen from natural gas or coal have significant supply chain emissions (methane) even if carbon capture technologies are used (see evidence links below). These should thus be excluded from R&D support unless it is towards improving performance and permanence of carbon capture solutions or ways to reduce supply chain emissions to zero. - Mission based innovation: Hydrogen can potentially play a role in industrial and heavy transport decarbonisation or seasonal storage, but is likely not to be the only solution. We thus suggest to frame the initiative around core challenges such as the above allowing all possible solutions to compete, rather than limiting innovation to a specific technology. For more background on designing mission-based innovation processes, please see here: https://www.e3g.org/library/report-summary-mission-based-innovation-for-climate-and-energy Further evidence on hydrogen: - https://www.e3g.org/library/renewable-and-decarbonised-gas-options-for-a-zero-emissions-society - https://theicct.org/sites/default/files/publications/ICCT_eu_gas_def_20190529.pdf - https://europeanclimate.org/wp-content/uploads/2019/03/Towards-Fossil-Free-Energy-in-2050.pdf - https://www.agora-energiewende.de/fileadmin2/Projekte/2017/SynKost_2050/Agora_SynKost_Study_EN_WEB.pdf Please get in touch should you have any further questions. Lisa Fischer
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Response to Evaluation of the effectiveness and policy coherence of the guidelines for trans-European Energy infrastructure

12 Jul 2019

Context: The TEN-E regulation, adopted in 2013, selects projects eligible for the Connecting Europe Facility funding, which will allocate €5.35bn to cross-border energy infrastructure investments between 2014 and 2020. Significant political and policy developments have happened since these guidelines were proposed and negotiated: renewed 2030 energy targets; adoption of the Paris Agreement; 2050 climate neutrality strategy; G7 commitment to phase-out fossil fuels by 2025; EU security of supply solved by ongoing PCIs. Europe is now heading towards an energy system that is significantly more decentralised, digitised and aiming for a much deeper decarbonisation that was envisaged in 2011. Prioritising and funding energy infrastructure for 2050 on the basis of an outdated TEN-E regulation means wasting an opportunity for modernisation and greater effectiveness in how we use our resources. The TEN-E regulation remains the only basis for the selection of priority energy infrastructure projects (PCIs), and for the award of EU funding to such projects often amplified through funding from the European Investment Bank. Drafted seven years ago, it pre-dates the Paris Agreement and the Clean Energy Package. This is why the PCIs selected on the basis of the TEN-E regulation are not meeting the needs of a modernised energy infrastructure: • Only four smart grid projects have been selected and the number of gas projects exceeds that foreseen by the original impact assessment. • Europe’s grid digitisation is lagging behind – Europe will not meet its 80% smart meter target by 2020. Investment needs in electricity grids are expected to amount to about €10bn/year to 2030. Recommendations for the evaluation process: - The reference period for the evaluation, currently limited to up to 2019, shall be expanded. Testing whether the regulation is able to support the Paris Agreement implementation requires a forward look: if we keep the current guidelines, would we build the infrastructure needed for our 2030 and 2050 targets? Would we build any infrastructure that might become superfluous?    - The evaluation should also look at whether current responsibilities and procedures to identify infrastructure needs, largely held by ENTSOs, reflect the move towards a more decentralized energy system and with a significant higher element of “soft” infrastructure investments, such as energy efficiency and digitization measures. This means the range of stakeholders shall be expanded in order to: 1. Included voices and views from the DSO community 2. In view of the Energy Efficiency First principle rooted in the Governance Regulation, energy efficiency, demand-side response, and smart grids stakeholders should also be part and parcel of the evaluation process. The Interservice Group (ISG) shall include representatives from competent Commission’s Units and external industry groups in the stakeholder engagement. Recommended additional reading: -E3G report on renewable gases https://www.e3g.org/library/renewable-and-decarbonised-gas-options-for-a-zero-emissions-society -E3G report on More security lower cost https://www.e3g.org/library/more-security-lower-cost-a-smarter-approach-to-gas-infrastructure-in-europe -ICCT report https://www.theicct.org/publications/role-renewable-methane-eu -BPIE report https://www.energyunionchoices.eu/wp-content/uploads/2017/08/Safeguarding-energy-security-in-South-East-Europe-with-investment-in-demand-side-infrastructure.pdf -ECF study on fossil-free https://europeanclimate.org/wp-content/uploads/2019/03/Towards-Fossil-Free-Energy-in-2050.pdf -OCI report on EIB and PCIs http://priceofoil.org/2019/06/12/new-report-the-european-investment-bank-cant-meet-the-paris-agreement-if-it-keeps-funding-gas-infrastructure/ -ACER opinion https://acer.europa.eu/Official_documents/Acts_of_the_Agency/Opinions/Opinions/ACER%20Opinion%2014-2019%20on%20the%20ENTSOG%20draft%20TYNDP%202018.pdf
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Meeting with Andrea Beltramello (Cabinet of Vice-President Valdis Dombrovskis), Elina Melngaile (Cabinet of Vice-President Valdis Dombrovskis)

23 May 2019 · Sustainable Finance

Meeting with Marion Perelle (Cabinet of Vice-President Miguel Arias Cañete)

10 Jan 2019 · Clean Energy Innovation

Meeting with Robert Schröder (Cabinet of Commissioner Carlos Moedas)

9 Jan 2019 · R&I missions

Meeting with Robert Schröder (Cabinet of Commissioner Carlos Moedas)

4 Sept 2018 · R&I and decarbonisation

Meeting with Kaius Kristian Hedberg (Cabinet of Commissioner Elżbieta Bieńkowska), Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska) and

4 Sept 2018 · the industry dimension of the Commission’s work on the mid-century strategy

Meeting with Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen)

3 Sept 2018 · EU Long-Term Climate Strategy

Response to Common provisions on the ERDF, the ESF+, the CF, the EAFRD, the EMFF and AMIF, ISF and IBM

26 Jul 2018

ASSESSMENT Exclusion of most aspects related to fossil fuel investments The Commission finally took a clear stance on fossil fuels with wording effectively excluding fossil fuels from Cohesion Policy funding . However, the provision still leaves a backdoor open for liquified natural gas (LNG) and it does not explicitly exclude the transmission of fossil fuels, which could potentially be to include gas pipelines. This exclusion list – once updated to exclude transmission – should be taken as a model for allocation criteria in other sectoral legislations. Clear promotion of energy efficiency projects Energy efficiency’s role in achieving a greener and low-carbon Europe has been recognised as a policy objective by calling on Member States to promote “energy efficiency measures” . This is further strengthened by the introduction of an energy efficiency focus (and renewable energy use) as a conditionality element to unlock investment in housing . Establishment of climate earmarking in both funds but it may not be enough to meet the overall 25% spending pledge In its proposal, the Commission only commits 30% of the ERDF total envelope and 37% of the Cohesion Fund budget to the climate objective. These figures are below the 40% share of funds needed for climate projects to reach the 25% climate mainstreaming target . Climate became a criterion both to allocate and disburse funds • Climate conditionality - The gross national income (GNI) remains the main measure (counts for 80%) to allocate Cohesion funds. The novelty is that climate change – albeit to a small degree only - will also contribute to the evaluation, together with the level of integration of migrants and education. The Commission also sets out a list of result indicators to monitor and drive investment choices under these funds . • Climate proofing - A set of “enabling conditions” will be used as performance indicators which will condition the disbursement of funds . This should ensure that Member States’ investments fall in line with EU energy and climate policy frameworks to receive funds. Support to a just transition to a low carbon economy albeit more theoretical than implementable In line with the primary scope of this fund, seeing the concept of “clean and fair energy transition” included as part of the “green Europe” policy objective shows recognition for the need to address the effects of the decarbonisation agenda in affected regions. Disappointingly, this acknowledgement is however not articulated further into actionable propositions, which raises questions as to how implementable this commitment really is. The need for Member States to prioritise just transition as part of their own programming process is a further hurdle to ensure affected regions effectively receive dedicated financial support.
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Response to Multiannual Financial Framework: Specific Programme implementing the 9th Framework Programme for Research and Innovation

26 Jul 2018

ASSESSMENT Stagnant contribution of Horizon Europe to the budget’s climate mainstreaming objective The 35% of climate mainstreaming allocation of the Horizon Europe Fund has not increased since the previous budget round. While this is in line to achieve the EU’s 25% climate mainstreaming objective it does not compensate for lower contribution targets announced for other sectoral policies and it also does not send a particularly strong signal of investing in green and low-carbon innovation and research. Small increase in funding for research in climate, energy and mobility There is an increase – albeit small – of resources for “climate, energy and mobility” from €12 to €15 billion . There are nonetheless other relevant programmes that could have a climate angle such as ‘digital and industry’ and ‘food and natural resources’. A new “bottom-up” approach for EU innovation This is particularly the case since the missions or goals have yet to be defined. The idea is to give voice to a group of 10-15 people through mission boards, grouping Member States representatives, stakeholder groups and experts . This is an interesting suggestion as it opens programming to civil society members and could potentially direct more attention to low carbon innovation and research. This is however conditional upon ensuring large public buy-in as well as an open, inclusive and transparent selection process. There is also a significant move towards ‘bottom-up innovation’ which comes with a push for open calls with few pre-defined objectives. This will be done through the new European Innovation Council and strengthening the European Institute of Innovation and Technology.
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Response to Multiannual Financial Framework-Draft legislative proposal on the InvestEU Programme and EFSI evaluation SWD

26 Jul 2018

ASSESSMENT Fossil fuel funding has not been ruled out and a method for “climate-proofing” investments in the Sustainable Infrastructure window has not yet been defined. InvestEU’s predecessor – EFSI – supported numerous high-carbon investments with just under a quarter of its budget allocated to such projects to date. This has been contradictory to meeting the EU’s climate and sustainability commitments under the Paris Agreement and should have been remedied in the proposals for InvestEU. The InvestEU proposal lists energy sector investments that are eligible for support, all of which appear positive in relation to climate. Fossil fuel investments, while not included in this list, are not explicitly ruled out – which leaves them as de facto still permissible. “Climate proofing” will be applied only to projects supported through the Sustainable Infrastructure window. At this stage, the Commission provides very little detail on the climate proofing methodology, stating that it will develop guidance as a next step. The guidance developed by the Commission will use, in an appropriate way, the criteria established by the “Taxonomy Regulation” for determining whether an economic activity is environmentally sustainable. Depending on what is deemed appropriate, this could ensure that investments in fossil fuels are excluded and greenhouse gas emissions are avoided or reduced by only making investments through eight means permissible, including generating, storing or using renewable energy or improving energy efficiency . Ringfencing of 30% of funds for climate action is insufficient and a backward step. On the other hand, having at least 50% of partner investments in the Sustainable Infrastructure window dedicated to climate and environment is potentially positive EFSI’s goal for at least 40% of its funds to be focused on climate action highlights InvestEU’s proposed contribution of 30% of its overall budget towards climate objectives as a backward step. In addition, it is an insufficient contribution to achieving the EU’s 25% climate mainstreaming target for the whole of the MFF . On a more positive note, it is proposed that implementing partners (such as national public banks) should ensure that at least 50% of the investment under the Sustainable Infrastructure window contributes to EU climate and environment objectives. However, definitions and the process for ensuring this happens are not clear, nor is the likely impact of this requirement on the share of overall InvestEU funding and investments supporting climate action. Energy efficiency at a crossroads Unlike the Cohesion Fund policy proposal, the Commission paradoxically does not explicitly prioritise energy efficiency in InvestEU despite recognition of the significant barriers to energy efficiency investment. This is a potential concern given the fact that the two EU instruments which have focused on delivering energy efficiency investments are being superseded by InvestEU without being replaced. This could leave energy efficiency vulnerable to being in a worse position than under the EFSI regime, and risks continued underinvestment. However, the proposed budget for InvestEU’s Advisory Hub – at €75m per year – is three times larger than EFSI’s equivalent. Moreover, it is proposed that the Advisory Hub focuses, amongst other things, on “facilitating development of aggregators for small-scale projects”, “leveraging local knowledge” to ensure widespread use of InvestEU support and capacity building for project pipeline development, for financial intermediaries focusing on clients and projects that struggle to access finance, and the development of sector specific knowledge. These are qualities, along with the increased budget, for the proposed Advisory Hub that apply themselves well to driving energy efficiency investment – so the potential for an improved energy efficiency outcome is there as well.
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Response to Multiannual Financial Framework: Connecting Europe Facility 2021-2027

26 Jul 2018

ASSESSMENT CEF’s overall envelope for energy has been increased to €8.7 billion. The new text contains some significant improvements: • The inclusion of 10% of funding dedicated to cross-border renewable energy projects has the potential to address barriers to important projects such as offshore wind hubs in the North and Baltic seas and renewable energy cooperation in Southeast Europe. • Investments will now be assessed for climate resilience under different climate scenarios, and investments in cybersecurity for grids can now be counted as contributing to security of supply. Greater focus on ‘synergies’ between technologies and sectors will also support projects that link energy and transport, such as electric vehicle charging. 
 Lack of clear exclusion of fossil fuels infrastructure and climate proofing definition. Unlike the Cohesion Fund policy proposal, the Commission has not fully excluded fossil fuels infrastructure from the CEF budget . The proposed legal text includes loopholes enabling significant investments in fossil fuel infrastructure: • The CEF regulation does not fully exclude fossil fuels from receiving funding. This could be achieved by excluding oil and gas projects from eligibility, for example by only allowing projects under Annex I and IV under the Trans-European Networks for Energy (TEN-E) regulation to be eligible. 
 • CEF-Transport is not fossil free as it references "alternative fuels" – which are defined as including natural gas, liquified natural gas (LNG) and compressed natural gas (CNG) in the alternative fuels directive. 
 • 65% of the spend are now required to go to “climate-related spending”. A clearer definition of the scope of this concept must be provided. This is necessary to clearly prevent an opening for the financing infrastructures using fossil gas. 
 • The climate proofing requirement for the remaining 35% of the program is yet to be defined. The regulation references a process that would come up with a coherent definition across all MFF proposals, but the process and its governance are unclear, including the extent to which civil society and the European Parliament will be involved. It also references the carbon price in this context – but using a carbon price at project level is not sufficient to climate proof an investment portfolio. Instead, the evaluation of infrastructure needs should be based on the compatibility with a fully decarbonised economy. The overall climate impact of the CEF portfolio is also not included in the proposed monitoring indicators: 
 • “Number of gas projects” is not an adequate indicator for progress on security of supply. The gas grid is expected to be fully resilient within the first few years of the next CEF (by 2022/25) . Higher energy efficiency efforts and increased deployment of renewable energy and interconnection mean this target might be achieved even earlier. • The sustainability indicators are not sufficient to assess whether CEF supports the EU’s decarbonisation aims. To ensure sustainability, the indicators should be expanded also to ensure no that no projects that are contrary to the EU’s climate policies are funded. The budget has been doubled, but the political priorities have not changed. Eligibility for energy projects to access the CEF is determined by the 2013 TEN-E regulation. However, its scope excludes many innovative projects and the infrastructure priorities set out in the regulation have not been updated to bring them in line with Europe’s climate goals under the Paris Agreement. As a result, new priorities should either be defined in the new CEF Regulation, or by securing a commitment to revise the TEN-E regulation.
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Response to Legislative proposals for ERDF/CF, ETC (Interreg) and ECBC

26 Jul 2018

ASSESSMENT Exclusion of most aspects related to fossil fuel investments The Commission finally took a clear stance on fossil fuels with wording effectively excluding fossil fuels from Cohesion Policy funding . However, the provision still leaves a backdoor open for liquified natural gas (LNG) and it does not explicitly exclude the transmission of fossil fuels, which could potentially be to include gas pipelines. This exclusion list – once updated to exclude transmission – should be taken as a model for allocation criteria in other sectoral legislations. Clear promotion of energy efficiency projects Energy efficiency’s role in achieving a greener and low-carbon Europe has been recognised as a policy objective by calling on Member States to promote “energy efficiency measures” . This is further strengthened by the introduction of an energy efficiency focus (and renewable energy use) as a conditionality element to unlock investment in housing . Establishment of climate earmarking in both funds but it may not be enough to meet the overall 25% spending pledge In its proposal, the Commission only commits 30% of the ERDF total envelope and 37% of the Cohesion Fund budget to the climate objective. These figures are below the 40% share of funds needed for climate projects to reach the 25% climate mainstreaming target . Climate became a criterion both to allocate and disburse funds • Climate conditionality - The gross national income (GNI) remains the main measure (counts for 80%) to allocate Cohesion funds. The novelty is that climate change – albeit to a small degree only - will also contribute to the evaluation, together with the level of integration of migrants and education. The Commission also sets out a list of result indicators to monitor and drive investment choices under these funds . • Climate proofing - A set of “enabling conditions” will be used as performance indicators which will condition the disbursement of funds . This should ensure that Member States’ investments fall in line with EU energy and climate policy frameworks to receive funds. Support to a just transition to a low carbon economy albeit more theoretical than implementable In line with the primary scope of this fund, seeing the concept of “clean and fair energy transition” included as part of the “green Europe” policy objective shows recognition for the need to address the effects of the decarbonisation agenda in affected regions. Disappointingly, this acknowledgement is however not articulated further into actionable propositions, which raises questions as to how implementable this commitment really is. The need for Member States to prioritise just transition as part of their own programming process is a further hurdle to ensure affected regions effectively receive dedicated financial support.
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Meeting with Telmo Baltazar (Cabinet of President Jean-Claude Juncker)

12 Feb 2018 · Energy Union - Climate Action

Meeting with Ioannis Latoudis (Cabinet of Commissioner Corina Crețu), Tomas Nejdl (Cabinet of Commissioner Corina Crețu)

29 Jan 2018 · MFF and climate risk

Meeting with Marion Perelle (Cabinet of Vice-President Miguel Arias Cañete)

20 Oct 2017 · Multiannual Financial Framework

Meeting with Ioannis Latoudis (Cabinet of Commissioner Corina Crețu), Tomas Nejdl (Cabinet of Commissioner Corina Crețu)

19 Sept 2017 · Climage change and the EU Budget in the framework of Cohesion Policy

Meeting with Ivo Schmidt (Cabinet of Vice-President Maroš Šefčovič)

7 Sept 2017 · MFF post-2020

Meeting with Marion Perelle (Cabinet of Vice-President Miguel Arias Cañete)

14 Jul 2017 · Energy Union Governance

Meeting with Jyrki Katainen (Vice-President) and WWF European Policy Programme and

3 Apr 2017 · Sustainability finance in the mid-term review of the Capital Markets Union

Meeting with Valdis Dombrovskis (Vice-President) and

17 Nov 2016 · sustainable/green finance

Meeting with Valdis Dombrovskis (Vice-President) and

27 Oct 2016 · Sustainable Finance; CMU

Meeting with Maroš Šefčovič (Vice-President) and

6 Sept 2016 · The role of the local level in the governance of the Energy Union

Meeting with Peter Van Kemseke (Cabinet of Vice-President Maroš Šefčovič)

10 Jun 2016 · RE100 and business consumer demand for renewables

Meeting with Maroš Šefčovič (Vice-President) and

23 May 2016 · Energy Union governance

Meeting with Manuel Szapiro (Cabinet of Vice-President Maroš Šefčovič)

27 Apr 2016 · innovation and market design

Meeting with Mathieu Fichter (Cabinet of Commissioner Corina Crețu) and Climate Action Network Europe and

12 Apr 2016 · Upcoming legislative proposals related to energy efficiency and renewable energy.

Meeting with Miguel Arias Cañete (Commissioner) and Transport and Environment (European Federation for Transport and Environment) and

11 Mar 2016 · Implications of the Paris Agreement in the EU climate and energy policies

Meeting with Miguel Arias Cañete (Commissioner) and BUSINESSEUROPE and

18 Feb 2016 · Market design

Meeting with Miguel Arias Cañete (Commissioner) and Transport and Environment (European Federation for Transport and Environment) and

21 Jan 2016 · COP21 and oncoming legislative package

Meeting with Lee Foulger (Cabinet of Vice-President Valdis Dombrovskis)

10 Dec 2015 · Capital Markets Union/G20 COP21

Meeting with Miguel Arias Cañete (Commissioner) and WWF European Policy Programme and

25 Nov 2015 · COP21 PARIS

Meeting with Edward Bannerman (Cabinet of Vice-President Jyrki Katainen)

21 Sept 2015 · Investment Plan and China

Meeting with Valérie Herzberg (Cabinet of Vice-President Jyrki Katainen)

17 Sept 2015 · Capital markets union

Meeting with Miguel Arias Cañete (Commissioner) and

4 Sept 2015 · International Climate negotiations and Commission Working Programme

Meeting with Paulina Dejmek Hack (Cabinet of President Jean-Claude Juncker) and EUROSIF A.I.S.B.L (EUROPEAN SUSTAINABLE INVESTMENT FORUM)

9 Jul 2015 · Capital Markets Union

Meeting with Miguel Arias Cañete (Commissioner) and

23 Jun 2015 · ETS review, Energy Union implementation and International Climate negotiations

Meeting with Telmo Baltazar (Cabinet of President Jean-Claude Juncker) and Avaaz Foundation

17 Jun 2015 · Climate Action and Energy

Meeting with Miguel Arias Cañete (Commissioner) and

30 Apr 2015 · International climate talks and EU climate diplomacy. State of play of legislative files

Meeting with Edward Bannerman (Cabinet of Vice-President Jyrki Katainen)

16 Mar 2015 · Investment plan energy efficiency

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

18 Feb 2015 · Climate action

Meeting with Igor Driesmans (Cabinet of High Representative / Vice-President Federica Mogherini)

5 Feb 2015 · EU-China Trade and Investmens

Meeting with Edward Bannerman (Cabinet of Vice-President Jyrki Katainen)

4 Feb 2015 · EU-China cooperation on sustainable development

Meeting with Peter Van Kemseke (Cabinet of Vice-President Maroš Šefčovič) and University of Cambridge Institute for Sustainability Leadership

16 Jan 2015 · Energy Union

Meeting with Peter Van Kemseke (Cabinet of Vice-President Maroš Šefčovič)

4 Dec 2014 · Energy Efficiency

Meeting with Miguel Arias Cañete (Commissioner) and

13 Nov 2014 · Lima climate talks; climate and energy priorities