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UNION FRANCAISE DE L'ELECTRICITE - UFE

UFE

UFE represents France's electricity sector on policy, sustainability and climate commitments.

Lobbying Activity

UFE urges EU to grant nuclear permanent green status

4 Dec 2025
Topic — An initiative to update technical screening criteria for nuclear and hydropower activities.
Message — UFE proposes removing the 2050 nuclear waste deadline and treating nuclear as a permanent renewable equivalent. They also advocate for hydropower rules to align strictly with existing EU water laws.123
Why — Granting permanent status would lower financing costs and reduce the administrative burden.45
Impact — Environmental protection groups lose the benefit of rigorous sustainability criteria for hydropower.6
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Meeting with Dorota Denning (Cabinet of Commissioner Valdis Dombrovskis), Mirzha De Manuel (Cabinet of Commissioner Valdis Dombrovskis) and

18 Nov 2025 · Competitiveness and simplification

French power sector calls for expanded EU grid funding

29 Oct 2025
Topic — The European Commission is seeking feedback on the next long-term EU budget.
Message — UFE wants national grid reinforcements and smart distribution projects to qualify for direct EU funding. They also demand faster funding decisions and reduced paperwork for electricity system operators.123
Why — This would reduce regulatory hurdles and help secure massive investments needed for grid infrastructure.456
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French electricity industry backs streamlining of energy security rules

13 Oct 2025
Topic — The Commission is revising rules to secure a more decarbonised energy system.
Message — UFE wants officials to prioritize implementing current rules instead of creating new ones. They advocate for smart streamlining to better coordinate cybersecurity and physical infrastructure protection.12
Why — Streamlining reduces compliance costs and secures funding for their existing power plants.34
Impact — Foreign fossil fuel suppliers lose market share as Europe prioritizes domestic energy.5
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Meeting with Nicolás González Casares (Member of the European Parliament)

9 Oct 2025 · Grids Package, Electrification

Meeting with Bruno Tobback (Member of the European Parliament)

9 Oct 2025 · Upcoming Grids Package

French electricity association calls for granular CBAM emission calculations

25 Sept 2025
Topic — The initiative sets rules for calculating embedded emissions based on actual data during the CBAM period.
Message — UFE proposes a granular methodology to mirror the actual electricity production cycle more accurately. They suggest updating the default emission factor to calculate levies on an hourly basis using available data.12
Why — This approach avoids overestimating carbon emissions for importers while maintaining a level playing field.3
Impact — Exporters from non-EU countries using fossil fuels lose the advantage of less precise averaging.4
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UFE urges ETS coupling and daily pricing for electricity imports

25 Sept 2025
Topic — Rules for converting carbon prices paid in third countries into CBAM certificates for imports.
Message — UFE calls for linking the EU and UK carbon markets and a temporary suspension of CBAM during negotiations. They recommend replacing yearly average carbon prices with daily averages to ensure accurate costs. Furthermore, only official carbon pricing should be deducted from CBAM, excluding voluntary carbon credits.123
Why — This would reduce market uncertainty for long-term electricity contracts and prevent double-taxation.45
Impact — Exporters relying on voluntary carbon credits would face higher costs as these offsets would be ignored.6
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Meeting with Paula Rey Garcia (Head of Unit Energy) and Climate Action Network Europe and

18 Sept 2025 · Electrification, tripartites contracts, storage and flexibility, and grids

French power industry urges electrification to meet 2040 targets

16 Sept 2025
Topic — The initiative aims to update the European Climate Law with a 2040 target.
Message — The organization backs the 90% emissions reduction target but demands electrification be prioritized across all sectors. They advocate for a level playing field for all low-carbon sources, including nuclear power.12
Why — Focusing on electrification would significantly expand the market for French power generation services.3
Impact — Fossil fuel providers and carbon removal firms would see their roles severely restricted.4
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Meeting with Anne-Maud Orlinski (Cabinet of Commissioner Dan Jørgensen)

15 Sept 2025 · Electrification Action Plan Grids Package White Paper on deeper electricity market integration

Meeting with Arthur Corbin (Cabinet of Executive Vice-President Stéphane Séjourné) and TotalEnergies SE and

10 Jul 2025 · Clean industrial deal Financement Simplification

Meeting with Christophe Grudler (Member of the European Parliament)

10 Jul 2025 · Politique énergétique européenne

French electricity sector urges priority for industrial electrification

8 Jul 2025
Topic — EU consultation on accelerating industrial decarbonisation and boosting European competitiveness.
Message — UFE requests that direct electrification be prioritized as the most efficient decarbonisation pathway. They propose increasing financial support for operational and capital expenditures while shortening permit approval times to one year.123
Why — Preferential funding and faster permitting would accelerate the deployment of electrical infrastructure.45
Impact — Non-European technology suppliers would face disadvantages due to new local content requirements.678
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French electricity union urges €60 carbon floor price implementation

8 Jul 2025
Topic — Reviewing the EU emissions trading system and its market stability reserve for climate targets.
Message — UFE seeks a €60 per tonne carbon floor price to ensure investment visibility. They also request that the reserve reacts to prices rather than supply volumes.12
Why — This would provide a stable price signal to unlock investments in decarbonisation technologies.3
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French electricity association urges national focus in grid planning

3 Jul 2025
Topic — EU initiative to upgrade and expand electricity and hydrogen infrastructure across Member States.
Message — UFE advocates for a bottom-up planning approach to preserve national involvement. They call for better funding for distribution projects and faster permitting for substations.12
Why — This allows French operators to secure more funding and avoid regulatory uncertainty.34
Impact — Non-European equipment manufacturers lose out if the EU adopts local preference in procurement.5
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French electricity group urges flexible identity checks for supplier switching

17 Jun 2025
Topic — EU regulation harmonizing data access procedures for switching electricity suppliers across member states.
Message — UFE requests clarification on balancing the 24-hour switching process with consumer withdrawal periods. They also demand non-digital identity verification options to support elderly and less tech-savvy customers.12
Why — These adjustments help suppliers avoid expensive technical overhauls and preserve current functional French systems.34
Impact — Mandatory digital-only identification would disadvantage elderly consumers who are unable to use digital channels.5
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Response to Implementing Act on non-price criteria in renewable energy auctions

21 Feb 2025

UFE supports most of the elements in the draft IA: - A stakeholder consultation by MS to design the criteria in line with market reality is welcomed by UFE. It goes hand in hand with the necessary backing of EU industries ramp up, as UFE has been advocating for. - A clearer specification of the criteria is also a positive development. The proposed methodology for the sustainability criteria based on a pre-defined menu will help MS align. This regulatory harmonisation is a powerful competitiveness enabler for EU-based industries, as it subjects them to a list of criteria common to all MS and simplifies their procedures. UFE points out that certain elements could be subject to improvements: a. Resilience criterion - The resilience criterion mentions a diversification, which is necessary to avoid dependencies, but UFE believes that the provisions risk being circumvented. The definition proposed in art. 7 refers to "final products and [main specific components] originating in a single third country". If the industries in countries other than the dominant one are controlled by industrial groups from this dominant country, the gains in terms of resilience would be very small. It would thus be needed to clarify the impact of these situations on the resilience criterion. - Furthermore, UFE considers that the criterion should go a step further to enhance the Unions manufacturing capacity. When the criteria cant eliminate distortions of competition, the introduction of a Made in EU criterion could be valuable for certain technologies. It could use the same methodology as the resilience criterion and turn more significant as the local industrial base becomes strong enough to supply with the necessary volumes. - UFE points out the complexity of the draft IA. For instance, it is unclear to what extent the principles and criteria set out in art. 3 allow a State to be exempted from the provisions contained in this draft Act, especially art. 7. The latter mentions a 75% of the Net-Zero technologies which needs to be clarified (which phase, which part of the product). - To avoid jeopardizing projects that would implement these provisions, it is necessary to assess the legal and political feasibility of this article, and examine the relevance of the thresholds, before its application. An exit clause should be inserted in art. 7 in case of a certain percentage increase in costs and/or unavailability of the supply chain (as initially provided for by the NZIA). b. Other criteria - Regarding the ability to carry out the project, UFE stresses that when a candidate is asked to provide information on their suppliers and/or on the construction and operation schedules, these provisions shouldnt be binding when the bid is submitted, given the possible lack of visibility over the supply chain. - About cybersecurity, UFE questions the implementation of art. 5(b) and the related operational aspects, requesting a clarification by the Commission. Then, art. 16 stipulates that compliance with cybersecurity criteria is based on the presentation by petitioners of a cybersecurity plan, which UFE welcomes as it can enhance the cyber resilience of installations. However, it should be more clearly defined and include a list of equipment, a risk analysis and a mitigation plan for the installation. For UFE, the analysis of this plan is not compatible with the deadlines of a call for tenders when it covers a very large number of projects, as it is the case for PV. It would entail too great an administrative burden for the contracting entity. However, the company could commit to delivering such a plan when the production unit is ready for operation. - For circular economy, UFE warns that the consolidation of the sectors is a prerequisite and that it may be premature to introduce this criterion. - UFE recommends that recital 6 becomes a proper article as it would enable MS to incorporate its principles into their calls for tender with greater impact.
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Meeting with Christian Ehler (Member of the European Parliament) and EPIA SolarPower Europe and

13 Dec 2024 · Energy policy

Meeting with Christophe Grudler (Member of the European Parliament)

10 Dec 2024 · Politique énergétique européenne

Response to Greenhouse gas emissions savings methodology for low-carbon fuels

25 Oct 2024

UFE thanks the Commission for the possibility to share its analysis on the proposed draft delegated act. This delegated act will be crucial for the deployment of low-carbon fuels and especially low-carbon hydrogen produced with low-carbon grid electricity and/or directly with nuclear electricity in the EU. UFE also recalls the emergency of defined legal frameworks permitting the emergence of a European industry of renewable and low-carbon fuels (especially hydrogen). 1. UFE's major concern on this draft relates to additional safeguards (recital 2): UFE shares the consideration of rules set out without prejudice to Articles 107 and 108 of the Treaty on the Functioning of the European Union and approves the need to ensure that State aids do not unduly distort competition. Nevertheless, according to recital (2) of the draft delegated act, new criteria in addition to the proposed rules for the methodology of low-carbon fuels could be implemented during State aids clearance. UFE warns about these additional criteria that could provide legal uncertainties to low-carbon fuels projects and threaten their development. Example of time limitations to the use of electricity in certain production processes needs to be clarified because of its significant impact on reliability and economic viability of low-carbon fuels production. 2. UFE recommends taking a decision before 1 July 2028 to provide long-term signals on both subjects (art.3-Monitoring and review): To substitute fossil fuels and to achieve the EUs target of reducing net GHG emissions fixed in the Fit-for-55 package, it is key to build a long-term legal framework permitting the emergence of a European industry of renewable and low-carbon fuels (especially hydrogen). 2.1 Low-carbon fuels produced from nuclear power plants: UFE supports a technology-neutral position using an approach of GHG emissions reduction based on a life-cycle assessment. Together with renewable energies, nuclear power plants could provide a steady-, low-carbon electric supply to electrolysers to ensure a competitive and reliable production of low-carbon fuels. A framework for PPAs could be introduced, relying on a similar market-based approach attributing the dedicated emission factor of nuclear electricity. Appropriate criteria adapted to the specificities of nuclear power plants should be defined. Criterion of additionality needs to be adapted accordingly because of different construction times between renewable and nuclear assets. 2.2 Hourly average carbon content of the electricity mix: To provide consistency with the delegated act for the production of RFNBOs and to reflect more accurately the physical flows of electricity, the hourly average carbon content of the electricity mix where the electrolyser is located at the country or bidding zone level could be used as an alternative way, if the information is publicly available from a reliable source. 3. The carbon intensity of electricity from all energy sources should be calculated using a harmonised methodology in part C of the annex (Table5): UFE calls on the Commission to harmonise the methodology used to calculate the carbon intensity of electricity, regardless of its origin, encompassing the manufacture of the electricity production assets. UFE regrets the use of old data for the life-cycle assessment and suggests to employ the most recent data available. For instance, emission factor proposed for nuclear, 1.2gCO2e/MJ, uses old data: 2002 for enrichment and U3O8 sea transport and 2005 for uranium ore extraction. 4. The emission intensity of generated electricity in Member States set out in part C of the annex (Table 6) should be more accurate: The proposed value of 23.8gCO2e/MJ (equivalent to 86gCO2e/kWh) does not reflect the actual carbon intensity of the electricity mix in the French bidding zone. UFE recommends using European data to complete Table 6 or data from official national statistics (French agency ADEME, 53g CO2e/kWh in 2023.
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Meeting with Sophie Wilmès (Member of the European Parliament)

17 Oct 2024 · Informal discussion

French electricity industry urges nuclear inclusion and European content rules

27 Jun 2023
Topic — The EU consultation seeks feedback on accelerating clean technology manufacturing and industrial resilience.
Message — UFE requests that nuclear technologies be integrated more broadly as strategic assets. They recommend shortening permitting deadlines and adding local content criteria to public procurements. They also call for an ambitious dedicated funding instrument to reduce operating costs.123
Why — Faster permitting and increased subsidies would lower costs and boost French industrial competitiveness.4
Impact — Non-European technology suppliers would lose market share due to new local content preferences.5
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Meeting with Christophe Grudler (Member of the European Parliament, Shadow rapporteur) and ENEDIS

8 Jun 2023 · NZIA

Meeting with Morten Petersen (Member of the European Parliament)

15 Mar 2023 · Energy Market Directive

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

25 Oct 2022 · Green Deal state of play

French electricity industry urges flexibility in F-gas phase-out

29 Jun 2022
Topic — Revision of EU rules targeting fluorinated greenhouse gases in electrical switchgear.
Message — UFE requests extending the transition period to 2028 for certain voltage levels. Bans should only apply to new installations to ensure existing equipment can be repaired. They suggest conditioning bans on the existence of multiple equipment manufacturers.123
Why — This approach would protect energy infrastructure safety and avoid supplier monopolies.45
Impact — Domestic consumers may face higher heating bills due to increased equipment costs.6
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UFE urges lower carbon intensity values for French electricity

17 Jun 2022
Topic — The consultation concerns the methodology for calculating greenhouse gas savings for renewable and recycled fuels.
Message — UFE requests using more accurate national data to reflect France's low-carbon mix. They also propose an hourly methodology and grandfathering for industrial carbon capture.12
Why — Lowering carbon intensity values would improve the competitiveness of French hydrogen producers under EU rules.3
Impact — Direct air capture firms would lose their regulatory advantage over cheaper industrial carbon capture sources.4
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Response to Data Act (including the review of the Directive 96/9/EC on the legal protection of databases)

12 May 2022

New services arising from vehicle connectivity will improve peaceful driving, comfort and life of drivers and passengers, while contributing to road safety, infrastructure optimization, ecological transition and vehicle electrification. As with any digital technology, data represents the key component in these developments. As players of the mobility ecosystem, we welcome the Data Act’s main goals: o the creation of a single market for data; o the right for users to access the data generated by connected devices; o the right to transfer access to such data to the third-party of their choice. However, as far as automotive data are concerned, we believe that while the access through third-party service providers is necessary and welcomed, it remains an insufficient step. To protect consumer rights and the innovative capacity of European undertakings, many use-cases will require direct access to in-vehicle data and resources. We are therefore convinced that a sector-specific legislation on access to in-vehicle data is required to complete the Data Act approach. If the European Union wants to foster innovation and see new players emerge in favor of more sustainable, shared and innovative mobility, it is essential that access to vehicle data is open to all relevant players, at the risk of creating distortions of competition and wasting time in the development of solutions that benefit European citizens.
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Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

31 Mar 2022

Please find enclosed the Frency Electricity Industry response to the consultation on the Energy Performance of Buildings Directive. The position focuses on the following point: - Acknowledging the role of all technologies decarbonising buildings - Ensuring that GHG emissions become a building performance indicator - Infrastructures for sustainable mobility - Clarifying the framework for minimum energy performance standards and for financial incentives - Strengthening the provisions on indoor air quality and thermal comfort
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Meeting with Christophe Grudler (Member of the European Parliament, Shadow rapporteur)

11 Jan 2022 · Revision of RED II

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

19 Nov 2021

UFE, the association representing the French Electricity Industry, welcomes the European Commission’s proposal to revise the Directive on energy efficiency (EED). But given the climate emergency, we believe that some improvements are still needed. Please find enclosed UFE's reaction and recommendations on the proposal of revision of the EED.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

18 Nov 2021

UFE thanks the Commission for the opportunity to provide feedback on the proposed RED III. Please find attached our contribution.
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Response to Revision of the Energy Tax Directive

18 Nov 2021

UFE thanks the Commission for the opportunity to provide feedback on the proposed revision of the Energy Taxation Directive. Please find attached our contribution.
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Response to Revision of Alternative Fuels Infrastructure Directive

18 Nov 2021

UFE, the association representing the French Electricity industry, thanks the European Commission for the opportunity to react to its proposal for a new Regulation on the Alternative Fuels Infrastructure (AFIR). UFE supports the proposal made by the European Commission as it sends positive signals regarding the electrification of transport, a necessity to decarbonise this sector. UFE believes that some improvements should however be made to ensure the proposal is fit for the objective of 1 million public chargers deployed by 2024. Please find enclosed UFE's reaction on the AFIR with our projections on the application of the fleet-based targets to France.
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Response to Updating the EU Emissions Trading System

8 Nov 2021

UFE thanks the Commission for the opportunity to react on the proposed revision of the ETS Directive. Please find enclosed and below our contribution. UFE, the association representing the French Electricity Industry, is mainly aligned with the Commission's proposal on the revision of the existing EU ETS. We believe that the Commission has put together the right set of measures to ensure the EU ETS remains a core instrument of decarbonisation in the EU - in particular increasing the linear reduction factor (LRF) to 4.2% in combination with a one-off reduction of the cap as of 1 January 2024.  Finding a swift agreement on the EU ETS is now essential to ensure a smooth and rapid implementation of the EU ETS reform and reach the 2030 objectives. UFE will therefore focus its feedback on the introduction of a new ETS for building and road transport. UFE takes note of the Commission's decision to introduce an emissions trading system applying to road transport and building but remains sceptical regarding both the effectiveness and the social consequences of the proposed mechanism. This is why:  UFE supports the Commission's decision to maintain building and road transport in the scope of the Effort Sharing Regulation. Sectoral regulations such as the Regulation on CO2 standards for vehicles have proven to be a successful decarbonisation tool . Therefore, in order to have a coherent and harmonised approach with predictable effects in a timely manner, a similar approach should be taken for the building sector. Indeed, studies have shown that only a carbon price of around 200€/tCO2 in 2030 and a coherent trajectory until then would drive substantial behavioural changes and induce a significant additional reduction of GHG emissions in road transport and building. Given the climate urgency, such a high price must be reached very quickly to contribute the 2030 decarbonisation target, which will be very difficult and would hardly be acceptable to consumers, especially low-income households.  A robust and efficient set of measures is needed to address the social and distributional impacts of such a high CO2 price on vulnerable households. In this regard, UFE takes note of the Commission’s proposal to establish a Social Climate Fund, however the €8 billion allocated to France for the 2025-2032 period will be insufficient to properly address these impacts, especially considering that only a share of this amount will be dedicated to compensation measures. UFE recalls that it is key to both help vulnerable households invest in low-carbon technologies and establish compensation measures, which will be an important driver of social acceptance. Measures facilitating consumption management by consumers should also be considered under the Social Climate Fund. To limit any possible negative effects of the ETS for buildings and road transport, UFE recommends the following:  Appropriate measures should be taken to limit price volatility under the ETS.  Particular attention should be paid to limiting the management constraints that will lie with energy suppliers when it comes to the operational functioning of the ETS.
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Meeting with Pascal Canfin (Member of the European Parliament)

15 Oct 2021 · Green Deal

Meeting with Kadri Simson (Commissioner) and

15 Oct 2021 · Communication on Energy Prices and upcoming energy proposals.

Meeting with Kadri Simson (Commissioner) and

8 Oct 2021 · Overview of the FR electricity sector and discussion on the increase of electricity price.

Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

22 Mar 2021

UFE fully supports the EC’s willingness to revise the Energy Performance of Buildings Directive (2010/31/EU, EPBD) as part of the Fit for 55 Package endorsing the new EU climate ambitions. Following the Renovation Wave Strategy, the EPBD is a key file when it comes to the EU building stock’s decarbonisation and renovation. To that end, the option 3 of the roadmap is fully appropriate to align the directive with the objectives of the 2030 Climate Target Plan. UFE supports this scenario, which can be combined with option 2, and would like to highlight some concrete recommendations. 1. The EPBD should develop an approach in terms of climate performance The Energy Performance Certificates (EPCs) should help reduce energy-related GHG emissions from buildings by 60% compared to 2015 level. Therefore, the EPBD’s article related to EPCs should be revised by: - Introducing the possibility to refer to final energy consumption alongside primary energy to be consistent with the Energy Efficiency Directive - Setting a carbon component in art. 11 of the EPBD which should be integrated to the mandatory minimum energy performance standards proposed by the EC and be at the core of the Building Renovation Passports - Ensuring that an approach in terms of climate performance is taken into account alongside efforts in energy savings - Switching from old fuels heating systems to low-carbon energies, incl. electricity, in addition to energy efficiency measures. 2. Climate resilience and digitalisation cannot be viewed as side issues for building renovations i) Ensure that the new and renovated buildings are climate resilient by: - Introducing in art. 11(2) the notion of winter & summer comfort in the EPCs and adding recommendations on thermal comfort to avoid long periods of extreme-low or high temperature in buildings - Converting the objective of “near-zero energy building” into a “near-zero energy and emission building” and integrating it into all new building requirements. ii) Revise the EPBD in line with the new EU digital ambitions by fostering the development of smart meters. They provide opportunities for the buildings’ energy performance by assessing the needed renovations and their effectiveness and increasing the information available to building occupants on their energy consumption. 3. The EPBD must address the remaining barriers to private charging 90% of electric vehicle (EV) charging happens at home or in the workplace and that 80% of the EU existing building stock will be still in use in 2050. Therefore, the EPBD revision needs to reopen art. 8 by: - Ensuring the right-to-plug to all EV users and extending it all buildings and not only new buildings or buildings subject to major renovation. Since different connection schemes exist, involving the DSOs to advise the building decision-maker(s) can facilitate the implementation of these requirements. The 'right-to-plug' can notably be achieved by enhancing the possibility for the tenant and co-owner to install charging points in their housings and adressing the unecessary exemptions applied to SMEs. - Developing the right incentives for investments and install collective charging infrastructures particularly in residential buildings - Setting strong requirements to ensure all buildings are pre-equipped - Supporting the implementation of smart charging to foster the efficient decarbonisation of both the transport and energy sectors. The EV has become a useful source of system flexibility for both i) the electric system and the integration of renewables and ii) the energy performance at building scale especially as EVs park for a long period of time. It will also help to reduce the connection cost as well as the bills of EV users. The EPBD revision should be consistent with the Alternative Fuels Infrastructure Directive to avoid any gaps or overlaps between the two texts. Please find UFE's additional recommendations attached to this reply.
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Response to Revision of the NIS Directive

18 Mar 2021

A high level of cybersecurity across the EU can only be achieved through a systemic approach UFE supports the extension of the scope to more (sub)sectors. The introduction of a new distinction between essential and important entities with identical risk management and reporting obligations is a significant improvement. The inclusion of new sub-sectors of the power system in the scope of the Directive (electricity producers, NEMOs and market participants providing aggregation, demand response or energy storage services) will help ensure a higher level of cybersecurity of the system as a whole. The size-cap rule does not address properly the risks faced by the power sector The size-cap rule does not seem appropriate to address cybersecurity risks faced by the power sector from end to end. But the same high requirements cannot apply to all entities regardless of their size and resources. According to EC’s proposal, micro and small enterprises are not included in the scope. Applied to the power sector, this means that a significant number of actors will not be subject to any cybersecurity requirements. However, a coordinated cyberattack on several small entities of the electricity system (small producers, EV charging infrastructures' operators) could cause significant imbalances and hamper the management of the power system. That said, UFE stresses that the right balance needs to be found regarding requirements for micro and small enterprises from the power sector. As the number of small actors in the electricity sector is expected to increase significantly in the coming years, it is of utmost importance to ensure that minimum cybersecurity risk management and reporting obligations apply to them. These requirements must be proportional to their capabilities and the cost of implementation relative to their size. Financial incentives are needed to accompany essential entities of the power sector in the implementation of the NIS 2 Directive Financial mechanisms and incentives should be explored at both EU and national levels to help the increasing number of essential entities in the implementation. It appears of utmost importance to accompany a sector at the heart of the transition to a climate-neutral economy in its digital transition. Essential entities and their targeted network and information systems must be clearly defined There is confusion on what can be considered as an essential entity in the energy sector: the list set out in Annex I refers either to specific actors or general activities. It is necessary to make a clear reference to legal entities (natural or legal person) in Annex I, as provided by Art.4(24). Cybersecurity obligations of essential and important entities must be clarified to avoid any misinterpretation that would lead to a broadening of the scope of the Directive to all components of the IT systems of targeted companies, even when not necessary. This could lead to unnecessary costs and administrative burden. Article 18(1) should be modified to specify that cybersecurity risk management measures only apply to important and essential services. A mutual exchange of information between national authorities and essential entities is needed The Directive should guarantee a mutual exchange of information between national CSIRTs or national authorities, and essential entities, to increase the level of awareness of the relevant actors in case of cybersecurity risk. This could be done by ensuring that internal CSIRTS of essential entities are notified without delay of any major incident occurring in their sector. Non-EU service providers should be subject to minimum cybersecurity risk management requirements Essential entities located in 3rd countries shouldn’t be exempted from guaranteeing a certain level of cybersecurity. The possibility to establish cybersecurity standards that would apply to non-EU essential entities should be further explored.
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Response to Revision of Regulation on Union guidelines for the development of the trans-European transport network (TEN-T)

18 Dec 2020

Given the surge of electric vehicle (EV) sales in 2020 and the 90% emission reduction objective set by 2050 for the transport sector in the EU Green Deal, UFE fully welcomes the announced revision of the EU guidelines for the development of Trans-European Transport Network (TEN-T). UFE agrees with the problems identified in the Inception Impact Assessment (IIA) and would like to highlight some key features to be considered when aligning the TEN-T guidelines with the last EU transport policies developments. 1. Ensure the consistent coverage of charging infrastructure on public roads for all TEN-T modes In light of the surge of EVs in 2020 and the objective of 1 million public charging points to be installed in Europe by 2025, it is vital that Member States acquire the right and necessary charging infrastructure and deploy them on both the TEN-T Core and Comprehensive Network. To this end, UFE supports integrating minimum binding requirements per vehicle type for charging infrastructure from the upcoming revised Alternative Fuels Infrastructure Directive (AFID) and other related transport policies into the TEN-T Core Network taking into account the geographic, density and traffic specificities of territories. Additional ad-hoc subsidies should be introduced to cope with the expected costs of deploying charging infrastructure and ensure consistency between TEN-T and AFID. Moreover, UFE believes the principle of corridor could be reassessed in light of national needs in order to ensure the full and appropriate coverage of all Member States with charging infrastructure. The deployment of charging infrastructure should therefore go beyond the main axes defined at EU level. 2. Strengthen the synergies between TEN-T and energy policies UFE has long emphasised the existing synergies between transport, energy and climate policies and the need to create further linkages between them. We thus endorse the EC’s intention to make sure the revisions of TEN-T and TEN-E guidelines go hand in hand in order to coordinate the coherent planning and construction of the European electricity infrastructure and to decarbonise the end-using sectors. Indeed, linking TEN-T and TEN-E will provide several benefits such as allowing and providing further support to new projects and could also contribute to assessing the prospects of projects regarding smart charging or renewables for EV charging. 3. Extend the provisions on urban nodes UFE considers that the revision of the TEN-T guidelines should address the need to increase the number of urban nodes and accelerate the coordination between the Member States for cross-border charging. To do this, stakeholders should be more involved in the promotion of EV charging infrastructure in urban nodes by continuing to enhance the Sustainability Urban Mobility Plans (SUMPs). 4. Enhance the digitalisation of TEN-T infrastructure UFE supports the strengthening of provisions to improve the digital dimension of TEN-T. To ensure the development of new intelligent services for EVs and charging infrastructure, the EC must ensure non-discriminatory access to relevant data on EVs (e.g. state of charge of the battery), for all types and brands of vehicles, and for all concerned actors. It will contribute improving EV-user experience and developing charging services.
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Response to Climate change mitigation and adaptation taxonomy

11 Dec 2020

UFE thanks the Commission for the opportunity to provide feedbacks on the proposal regarding the “EU classification system for green investments”. Please find detailed feedbacks enclosed.
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Response to Revision of the Energy and Environmental Aid Guidelines (EEAG)

10 Dec 2020

1. Transparency EEAG must ensure that state aids are directed to sectors and projects of common interest. The revised EEAG must ensure that an effective investment framework from upstream to downstream is put in place that will ensure that investors have the visibility necessary to manage their risk and control their costs. To provide further transparency and certainty, the revised EEAG should reassert the essential principles that will guide the assessment of the proposed aid measures. In this regard, the reference to the EU taxonomy is not a solution. First, delegated acts of the EU Taxonomy have not yet been adopted. Second, State aid should be assessed on a case-by-case basis considering the objective of common interest, therefore, a mechanical link with taxonomy must be avoided. The scope of a given aid measure should be adapted and differentiated according to the aid’s objective: • In the case when the aid aims at achieving technology development goals, the scope of the aid should be technology-specific, in order to avoid systematically favouring the least costly technology irrespective of the actual value of the energy it produces; • In other cases, when the aid aims at achieving other objectives of common interest such as security of supply, a technology-neutral stance of the aid should prevail. In this regard, the EEAG should recognise that Member States can support all technologies that can contribute to achieving the targeted objective of common interest. This would give Member States the required flexibility to diversify their energy mix and maintain a competitive drive to lower costs per technology while ensuring their security of supply. UFE therefore calls for the EEAG to consider State aid supporting specific technologies as the default option to determine the bespoke support levels needed by different technologies, in light of their specificities and scalability. 2. Tendering Pursuant to Article 194(2) of the TFEU, Member States are responsible for their own energy mix. In UFE’s view, the 2014-2020 EEAG enabled efficient and competitive renewable support schemes, especially thanks to tendering. However, past experiences have shown that technology-neutral calls for tenders are not efficient, as they do not allow for the achievement of the energy policy objectives. Furthermore, UFE stresses that cross-border support schemes covering more than one country should remain optional. Indeed, national specificities (e.g. administrative costs, regulatory framework) have a significant impact on the cost of a given project. As project promoters are not competing on equal footing, cross-border calls for tenders are therefore not allowing a fair competition. 3. Broadening the scope of the EEAG UFE sees a risk in terms of fair competition between different actors, technologies, or even energy carriers. UFE stresses the need to harmonise the future EEAG with the Electricity Directive and Regulation, the Renewable Energy Directive and the Energy Efficiency Directive. 4. Green bonus UFE does not support the introduction of a green bonus or a brown malus in the EEAG. The assessment of the objective of common interest, i.e. the Green Deal, should be the core principle and should guide the Commission in its authorisation process. By introducing a bonus/malus system, there is a high risk of implementing bureaucratic or arbitrary assessment schemes leading to substantial market distortions. 5. Energy-intensive users (EIUs) In line with the EU decarbonation objectives, EIUs should be encouraged through State aids to invest in energy efficiency and the decarbonation of production processes, for example via electrification. The new guidelines must preserve existing support for energy-intensive users such as CCGTs which are subject to the ETS, and also avoid any risk of double taxation under the ETS.
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Response to Updating Member State emissions reduction targets (Effort Sharing Regulation) in line with the 2030 climate target plan

26 Nov 2020

UFE welcomes and supports the EC’s initiative to review the Effort Sharing Regulation (ESR) to align it with the new 2030 and 2050 climate targets of the EU. Although it is of the utmost importance to ensure that all sectors are subject to a meaningful CO2 price signal or CO2 standard regulation, the same carbon pricing instrument will not be suited for all sectors. It is therefore crucial to carefully assess both the revision of the ESR and the extension of the ETS, and interactions between these two mechanisms. 1. Sectoral legislations and national objectives are efficient tools to foster decarbonisation in the building and road transport sectors UFE strongly believes that for the road transport and building sectors, strengthening sectoral legislations will be a more effective decarbonisation tool than their integration into the ETS. Extending the ETS to road transport would increase costs for consumers, in particular low-income households, while having little effect on their mobility behaviours and thus no significant impact on the reduction of CO2 emissions for road transport. Indeed, the price of CO2 in the ETS system would need to increase drastically (around 100-200€/tCO2) to drive significant behavioural changes in this sector. This price level would be difficult to attain via the ETS without a sharp price increase, and would be perceived as unfair by consumers. In this context, it is both fairer and more efficient to support households via investment aid. By contrast, sectoral legislations have provided a clear signal to both manufacturers and consumers while reducing emissions. It also allows acting upstream by addressing the supply. Regarding road transport for instance, in France, the implementation of the CO2 emission standards has led to a reduction of new cars’ CO2 emissions by around 16% during the first semester of 2020. In consistency with a just transition, CO2 standards also protect households from a taxation effect induced by a (low) CO2 price unable to drive decarbonisation that would be an additional burden to their energy bills and that might be perceived as unfair. The same applies for the building sector, where sectoral legislations such as the EED and the EPBD set clear objectives in terms of energy efficiency. The recently released Renovation Wave Strategy and the planned legislative revisions could also be promising tools if they include a more climate-centric approach. In any case, especially concerning dwellings, there is a duality between the one who decides on the CO2 performance (the owner) and the one who would support the ETS impact on energy prices (the tenant). This situation is all the more problematic as poor households are over-represented in the tenant category. Therefore, only legislation and mechanism that will have an impact on the owner will be relevant. 2. Option 3 must be favoured in the revision of the ESR UFE strongly believes that one ETS for all sectors is not the right tool to support the decarbonisation objective of the EU. The extension of the ETS must be carefully assessed and its effectiveness must be compared with other carbon pricing solutions, always taking into consideration particularities of each sectors (marginal abatement cost, risk of carbon leakage, policy overlaps etc.). Therefore, UFE is strongly opposed to options 1 and 2 as proposed in the EC’s roadmap on the revision of the ESR, as they would not offer an efficient way forward for the decarbonisation of the building and transport sectors. Option 3 described in the inception impact assessment is understood as a scenario of “no ETS extension” where “the ESR would have the same scope as today” and is the most efficient option. The ESR revision must align national targets with the new 2030 and 2050 emissions targets. Indeed, the extension of the ETS opens the door for a suppression of Member States’ targets. UFE does not support this idea, as national targets contribute to Member States’ empowerment
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Response to Updating the EU Emissions Trading System

26 Nov 2020

UFE supports the EC’s initiative to strengthen the ETS to contribute to achieving the new ambitious climate targets for 2030 and 2050. 1. The ETS must be reinforced as the core instrument of decarbonisation in the EU A predictable carbon price is essential to ensure the ETS plays a key role in decarbonising the EU economy while guaranteeing a smooth and fair transition. In this regard, UFE is in favour of the creation of a carbon floor price of at least €30/tCO2 on the ETS. UFE strongly supports the review of the LRF to align the ETS with the new climate targets and welcomes the EC’s will to examine a one-off reduction of the cap to reflect more accurately the actual emissions level. 2. A single ETS for all sectors is not the right instrument to foster decarbonisation Although it is of the utmost importance to ensure that all sectors are subject to a meaningful CO2 price signal or CO2 standard regulation, UFE strongly believes that one ETS for all sectors is not the right tool to support the decarbonisation objective of the EU. Some sectors, such as road transport and heating, are by nature decentralised and not at risk of carbon leakage. The ETS is therefore not the most effective tool to drive decarbonisation in these sectors, as effective sectoral legislation is already in place at European and national levels. For instance, CO2 legislation for the road transport sector gives a clear long-term price signal to both consumers and car manufacturers. Extending the ETS to road transport would increase the cost of transport for vulnerable households, without inducing significant GHG emissions reduction. The same applies for the building sector, where existing sectoral legislation could lead to GHG emission reduction. In any case, the ETS won’t have the expected outcome due to an insufficient CO2-price level. When it comes to the maritime and aviation sectors, UFE is in favour of an extension of the ETS: the structure of these sectors, comprising few stakeholders, is conductive to an inclusion in the ETS. UFE calls on the EC to bear in mind that the same carbon pricing instrument will not be suited for all sectors. The extension of the ETS must be carefully assessed and its effectiveness must be compared with other carbon pricing solutions, always taking into consideration particularities of each sectors (marginal abatement cost, risk of carbon leakage etc.). 3. Consistency among all EU climate policy instruments is essential The ETS revision is closely linked to the revision of the ESR and the implementation of the CBAM, and the review of the LRF and the MSR will depend on the scope of the revised ETS. When it comes to carbon leakage, the future of free allowances in the ETS will need to be assessed in the light of both the scope and parameters of the upcoming CBAM. In reviewing the ETS, the EC will also need to take into consideration the new 2030 RES and energy efficiency targets. 4. The MSR should be adapted according to the evolution of the ETS and other targets The MSR should be updated to reflect the evolution of the market balance in an increasingly decarbonised economy. The effects of the extension of the ETS, of a CBAM and of the RES and EE enhanced targets will also affect the ETS market balance, and have to be integrated in the study of the MSR evolution. The thresholds should be studied (whether according to TNAC volume or to price level), together with the possible adjustments of the MSR behaviour (intake/injection rate). 5. Investments in research and innovation must be strengthened The power sector needs to invest in research and innovation to bring out decarbonised technologies addressing the challenges of circular economy. The EU needs to be at the forefront of these new technologies, which will shape the future economy. In this respect, UFE is in favour of strengthening the Innovation Fund via an improved support for low-carbon and carbon removal investment and innovation through various mechanisms.
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Response to Revision of the CO2 emission standards for cars and vans

26 Nov 2020

UFE welcomes warmly the EC’s intention to revise the Regulation 2019/631/EU setting CO2 emission standards for cars and vans. Given the planned increase of the 2030 target of GHG emission reduction from 40% to 55% and the new reduction objective of 90% of emissions by 2050 for the transport sector, UFE considers it is essential to ensure CO2 emission standards for cars and vans consistent with the new EU climate ambitions. The EU legislations related to transport should be aligned to the decarbonisation targets set for the other sectors (e.g. electricity). UFE supports the IA’s proposals to toughen the target levels and their timing as well as to implement specific mechanism to incentivise zero- and low-emission vehicles according to the type of vehicles targeted. During the last revision of the Regulation, UFE was already calling for the 40% emission target for both cars and vans for 2030 and still supports its increase in line with the objectives of the Green Deal. This increase in targets for reducing CO2 emissions should go hand in hand with a higher ambition in terms of deployment of charging infrastructure, which should be addressed in the upcoming revision of AFID (public infrastructure) and EPBD (private infrastructure). 1. The revised CO2 emission standards should support the rise of electric vehicle (EV) share CO2 standards deliver clear benefits. It is easier to communicate on a clear and numbered objective, to remember it and engage society but also to monitor progress. Their implementation has successfully drivelled to the concrete surge of EV sales observed since the beginning of 2020. The significant increase in EV sales observed during the first quarter of 2020 was maintained during and after the COVID-19 crisis. Indeed, after the COVID-19 crisis, numerous Member states, incl. France, have chosen to restart the automotive sector by incentivising EVs. The EC should continue to support the decarbonisation of the vehicle fleet thanks to its electrification. In addition, in France the distribution network is ready to connect these higher shares of electric vehicles without jeopardising the electricity supply. Distribution network operators can also support the electrification of fleets by accompanying optimal grid location for EV chargers to meet end-users’ needs and optimise costs for users and the community. EU regulations should thus incentivise the electrification of the vehicle fleet by setting stricter CO2 standards for cars and vans to encourage car manufacturers to expand the supply of zero-carbon vehicles and ensure it is fitted to achieve carbon neutrality. 2. The CO2 emission standards are an efficient tool to reduce transport emissions In France, the implementation of the CO2 emission standards has led to a reduction of new cars’ CO2 emissions by around 16% during the first semester of 2020. UFE believes the strengthening of CO2 standards constitutes a more effective tool to decarbonise the transport sector than the extension of the EU ETS system to road transport as a replacement to sectoral legislation. Indeed, expected CO2 prices in the EU ETS won’t be sufficient to trigger a swift decarbonisation of the transport sector. By contrast, CO2 emission standards have provided a clear signal to both manufacturers and consumers while reducing emissions, since their implementation. In consistency with a just transition, CO2 standards also prevent consumers from a taxation that would be an additional burden to their energy bills and that might be perceived as unfair. Document endorsed to the reply: Enedis, Report on the integration of electromobility to the public electricity distribution network (November 2019): https://www.enedis.fr/sites/default/files/Report_on_the_integration_of_electric_mobility.pdf
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Response to Revision of the Intelligent Transport Systems Directive

18 Nov 2020

UFE welcomes the consultation of the European Commission ahead of the revision of the Directive ITS. In light of the surge of electric vehicles (EVs) on the market in 2020, expected to be continued in 2021, the French electricity industry would like to highlight the need to integrate several aspects regarding electric vehicles (EVs) in the revised Directive. UFE would like to present further inputs on the specific objective 3 to ensure data sharing and access: 1. To guarantee the development of new intelligent services for EVs and charging infrastructure, the EC must ensure non-discriminatory access to relevant data on EVs (e.g. state of charge of the battery), for all types and brands of vehicles, and for all concerned actors. Smart charging (a form of demand response with EVs) and V2G (feeding back energy of the EVs to the grid) enable to increase the use of (locally) renewable energy, to optimise grid investments, to better anticipate the impact of EVs on networks and can bring financial rewards to the end user (higher consumption of off peak electricity) and the site owner (cheaper connection to the grid). However, respecting the constraints of the user (departure time and requested energy) is key for this, in order to bring a good experience. For that, knowing how much energy is still left in the battery (technically known as state of charge) is key. The ISO 15118 (a communication protocol between the vehicle and charging point) will enable the access to the state of charging but also to other external parameters such as information on the energy mix, cost of electricity, departure time, etc. For these reasons, it is important that car manufacturers implement the ISO 15118 and give third party access to battery information in a non-discriminatory way. 2. Standardised framework to access data should be applied in order to organise data sharing on charging. Simplified provisions for information and data transfer should be ensured in consistency with the rules of the GDPR to obtain consumers’ consent. Information should be made available on the location and access of charging infrastructure. 3. To improve and strengthen the interoperability of charging infrastructure for electric vehicles, the EC should push for the harmonisation of the communication system at EU level and develop further the standard ISO 15118.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

21 Sept 2020

UFE welcomes the EC initiative to bring greater consistency between energy and climate policies. Considering the 2018 revision of RED, UFE believes that, alongside a review of the overall 2030 target, the EC should also ensure the complete and correct transposition of REDII by MS. To achieve climate neutrality, the EU must put in place an effective system in which reducing CO2 emissions is the priority. Frameworks for energy efficiency and renewable energies must achieve this goal and as such the development of RES must be supported. UFE supports a target of reducing GHG emissions by at least 55% by 2030. To achieve this objective, the EU legislative framework must encourage the reduction of CO2-emitting energy consumption particularly in the most carbon-intensive sectors (transport & construction). The carbon price signal should be the driving force to encourage investments enabling a transition to a low-carbon economy, including in RES or energy efficiency. This policy will enable a switch towards low-carbon energies and open a natural and economically efficient way for the deployment of RES. In a common and consistent framework, an increase of renewable energies could bring positive effects to achieve EU’s decarbonisation but UFE cannot quantify the share of renewable energy in the final energy consumption needed to reach the EU GHG emissions reduction objective. This level can vary depending on the circumstances and projections will have to be made based on the EC impact assessment on the new reduction target of GHG emissions by 2030. UFE thus supports a combination of Options 3 and 4. To align the Directive with the objective of carbon neutrality, UFE recommends to: - Focus on enhancing RED II implementation by notably simplifying and shortening permitting procedures and promoting especially technology specific tenders to reach the existing 2030 RES target. Indeed, efficient permitting procedures and technology specific tenders are the most efficient way to deploy RES to both increase the necessary visibility for investors and develop a balanced production mix allowing a smooth integration into the grid. Repowering procedures of installations that come to end of life should be particularly simplified and facilitate the RES objectives’ reach - Consider in the revision of RED the key role of networks and infrastructure, ready to electrify end-use sectors and integrate renewable energy sources - Focus on strengthening the levers aimed at accelerating the development of renewable heating and cooling - Maintain the RES support mechanisms and promote greater use of long-term renewable energy purchase contracts (PPA) - Allow revenue stabilisation mechanisms especially Contract for Difference as crucial financing tool to de-risk financing of renewable projects (e.g. offshore wind projects). They provide the necessary confidence for investors which results in a lower cost of capital and ultimately guarantees affordability for the final consumer The use of renewable electricity is a cornerstone of EU’s decarbonisation and the amendment of REDII should further recognise the key role of electrification in some end-uses sectors. The review of REDII should recognise the role of green and decarbonised hydrogen for heavy transport (maritime, rail, aviation and long-haul coaches), when direct electrification is not feasible. New RED should increase RES consumption in buildings by: - Replacing the current heating & cooling system with a more low-carbon and efficient one (e.g. replace old fossil-based boilers by a heat pump or new and more efficient boilers) - Planning the phasing-out of higher-emission energies for new buildings as a first step, and for the renovations of (non-)residential buildings as a second step - Encouraging the development of heating networks which bring flexibility and allow a high penetration of renewables as well as incentivise existing district heating and cooling connections with domestic heat pumps
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Response to Review of Directive 2012/27/EU on energy efficiency

21 Sept 2020

The Directive 2012/27/EU on energy efficiency (EED) is a key tool to reduce energy consumption, and accompanied by an ambitious electrification, and the deployment of renewable energy sources, it will help meet the EU’s climate and energy objectives. The EED was recently revised in 2018 and is currently in its implementation phase, UFE regrets that the issue of climate efficiency was not taken into account at the time. Considering the EC pledge to raise the 2030 target to reduce GHG emissions by at least 55%, it is of utmost importance to make the EED consistent with this objective. Instead of reviewing upwards the 2030 overall energy efficiency (EE) target, UFE believes it is essential to increase the implementation of EE measures in the EED. Indeed, early assessments show that most of the National Energy and Climate Plans (NECPs) do not plenty assess whether the national policies are sufficient to reach the 2030 EE target and that Member States (MS) run the risk of not meeting their target. UFE thus supports a combination of Options 2 and 3 and believes the EED revision should focus on aligning the Directive with the climate objectives and adopting a more climate-efficiency centric approach. The EED needs to encourage the switch to low-carbon energies. The objective of reducing GHG emissions should be at the core of energy policy as energy savings alone do not systematically correspond to a significant reduction in GHG emissions. This ambition is not concretely addressed in the Roadmap. More synergies need to be introduced between the EED and other Green Deal initiatives so that concrete measures in sectors with the greatest potential for energy savings such as buildings and transport are taken. The EED must be revised in conjunction with the Renovation Wave (RW) to decarbonise the EU building stock and the Energy Performance of Buildings Directive (EPBD). For instance, the development of smart meters in buildings supported by the EC should be addressed in both the EED and the RW as they help increase the participation of customers to the electricity markets by notably providing access to data on final energy consumption and demand response services. The EED and RW should also assess the need and the efficiency of a deep renovation based on consumption data. Finally, the EED should acknowledge the importance of charging infrastructures’ deployment in line with the provisions of EPBD, to bring efficiency to the system. Therefore, UFE believes the review of the EED should: - Enshrine the objective of carbon neutrality in art. 1 and 3 with a greater consistency between EE savings and climate objectives to reduce GHG emissions - Improve the Energy Efficiency Certificates tool by including a CO2 component - Encourage MS to set national targets for the reduction of energy consumption by 2030 according to their specificities and taking a year of reference - Prioritise efficient and low-carbon technologies - Create EE objectives for transport to reduce GHG emissions in modes of transport, such as maritime, which are not covered by EU CO2 legislations (thus not those concerned by Regulations EU 2019/631 and 2019/1242) - Prioritise the renovation of public buildings in conjunction with the RW by extending art. 5 to all public buildings (not only those owned and occupied by central government). The EC should also set a new goal in terms of energy consumption rather than only in terms of renovated area in the EED to set up a safeguard for GHG emissions - Support the development of smart meter solutions (art. 9), reinforce the access of consumers to their data and their use, and foster the uses of already existing smart meters functionalities for energy consumption management - Add a reference to final energy consumption in the billing information and simplify the information available to raise awareness and visibility among customers and help them having a better understanding of their energy bills and savings (art 10 & 11)
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Response to Sustainable and Smart Mobility Strategy

28 Jul 2020

UFE welcomes the EC initiative to present a Strategy for a Sustainable and Smart Mobility and underlines several key points to enhance the decarbonisation of the transport sector. 1) Electrification is a cornerstone to reduce the environmental impact of transport (Problem 1) The electrification of transport can improve air quality and reduce the GHG emissions along the vehicle life cycle analysis (LCA). To illustrate, the electric vehicles are two to three times less polluting than internal combustion engine using fossil fuels (battery recycling phase taken into account). In addition, the electricity power system is ready to integrate the massive development of EVs into the grids. RTE (French TSO) showed in 2019 the possible integration of 15M electric vehicles (EV) into the grid by 2035. Enedis (French DSO) concluded that the investments planned by 2030 would represent only 10% of the total investment. 2) The roll-out of public and private charging infrastructure needs to be supported (Problems 1.i., 1.ii. and 2) Knowing that 90% of EV charging is happening at home, the EC needs to address the issues of the right-to-plug, especially in the co-properties and the issue of having access to a charging station in public areas at home proximity. To deploy public charging infrastructure, the EC should push for a quantitative and qualitative approach taking into account the charging powers and the location as well as the development of the EV market. The local level needs also to be fully involved in the planning to enable an infrastructure deployment closer to users’ needs (e.g. territorial coverage and traffic). Smart charging should be encouraged in private infrastructure and in public only for residential and tertial districts to ensure grid flexibility as well as energy savings. 3) The access of data on E-mobility should be encouraged (Problems 2, 3 and 4) Non-discriminatory access to data related to E-mobility and notably to batteries, should be guaranteed for all concerned actors (e.g. energy service providers, system operators, fleet operators). Available data should include load control to charge vehicles at the best time and at the lowest cost, as well as electricity reinjection to ensure networks flexibility. The EC should establish a standardised framework to organise data sharing. Such a framework could also offer opportunities to tackle the issue of cybersecurity which may present a risk for the grid security. Key enabling policies To ensure Europe’s sustainable mobility, the EC should: • Promote only sustainable transport in the revision of the Directive on the Alternative Fuels Infrastructure (AFID). • Create the conditions for a sustainable and competitive value chain of batteries in Europe in the revision of the Battery Directive via a circular approach tackling the risk perception of the private sector and enhancing the battery recycling sector. • Ensure and favour a green hydrogen for heavy transport segment (long-haul trucks, maritime and aviation transport) in the Hydrogen Strategy when direct electrification is not technically and economically feasible. • Guarantee a non-discriminative access to the EV for all concerned actors in the EU Digital Strategy. To answer the growing infrastructure needs, the EC should: • Ensure public infrastructure deployment and assess the prospects for private infrastructures while setting national targets for the deployment of charging infrastructure in the AFID. • Push the roll-out of infrastructure in the existent public and private buildings within the Renovation Wave. • Enhance the coordination between the Member States via the TEN-T Core and Comprehensive Networks. Additional document: Enedis, Report on the integration of electric mobility (2019) URL: https://www.enedis.fr/sites/default/files/Report_on_the_integration_of_electric_mobility.pdf
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Response to Modernising the EU’s batteries legislation

9 Jul 2020

UFE welcomes the EC initiative to revise the Directive 2006/66/CE on batteries which will offer strong opportunities for a competitive, circular and sustainable value chain for batteries produced in Europe. UFE would like to emphasise the following points in the EC Roadmap. 1) Pave the way for an EU competitive, circular and sustainable value chain Considering Europe’s ambition to be the first carbon-neutral continent by 2050 and assessing its dependency on energy and raw materials towards third countries, UFE supports a comprehensive approach in line with the EU Industrial Strategy and Circular Economy Action Plan. The EC should invest in developing the recycling sector for batteries to tackle GHG emissions associated with battery manufacturing processes (p.2). To be fully consistent with the Green Deal, an assessment of the battery carbon footprint should be conducted based on the location of the production of both batteries and its key components as well as on the CO2 emitted per kWh. To do so, the CO2 national average of the electricity system is the proxy available. The EC should also clarify the definitions of “lifetime” and “hazardous substances” and consider the environmental impact of the battery production via LCA methodology (p.3). The EC should investigate further the mechanisms which can be used to integrate low carbon electricity into the overall electricity mix in the production of batteries. 2) Clarify the rules of the game in the long run to reduce the risk perception A circular approach on the battery lifecycle is key to tackle the environmental and health risks of the battery industry (p.2). Many obstacles remain to ensure a mature and viable recycling sector of batteries in Europe. The legal uncertainty needs to be addressed to build confidence in the private and banking sectors. To face it, UFE recommends setting a fair balance between the recycling cost and the targeted recycling rate, which should be technically and economically feasible, to secure the effects of scale and increase the effectiveness of the battery collection and logistics. The EC should bring clarifications on the end-of-life and second-life batteries as well as on their price and could consider a battery recycling tax to vehicle sales (p.3). UFE calls also to further integrate technology advancements and enhance their effectiveness. 3) Ensure a non-discriminatory access to data on batteries The revised Directive needs to address the access to data on batteries. Managing EV charging (smart charging) has economic, social and environmental benefits. It can provide a better experience for EV users and secure their mobility needs while reducing energy costs. In France, an EV user can save up to 200€ comparing to a normal recharge of its vehicle by traveling 14 000 km per year from home to work. It can also contribute to bring flexibility and stability to the power electricity system at any time and facilitate the integration the REs into the grids by managing more efficiently their intermittence. It also allows DSOs to better anticipate the impact of EVs and smart charging on the network and to better inform market players on the EV charging and battery potential for flexibilities. UFE points out the importance of adopting a non-discriminatory approach regarding the access to battery data for dynamic charging management services and electricity reinjection (V2H, V2B, V2G) as it can be seen as an extension of EV charging services. The EC needs to guarantee available information to all actors on the state of battery charge (battery load factor), the minimum and maximum import (even export) capabilities in kW, as well as the kW capacity of the battery of each vehicle in order to better anticipate the options available for the batteries (natural or piloted recharge). Report RTE on e-mobility, May 2019 [In French]: https://www.concerte.fr/system/files/concertation/Electromobilite%CC%81%20-%20Synth%C3%A8se%20vFinale.pdf
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Response to Commission Communication – "Renovation wave" initiative for the building sector

8 Jun 2020

UFE welcomes the willingness of the EC to release a Renovation Wave (RW) initiative to support a renovation of the EU building stock in line with the European Green Deal. Indeed, the renovation of buildings will play a key role to achieve carbon neutrality by 2050 by creating jobs and tackling energy poverty, in particular in the context of Europe’s post-COVID 19 economic recovery. UFE supports the RW initiative and calls for a stronger consistency between policies in building and EU climate objectives. The renovation of the existent residential and non-residential buildings is a major enabler to achieve carbon neutrality by 2050 and, in this regard, electrification will play a key role. Electrification has the potential to provide massive benefits for the building sector and its decarbonisation by bringing more flexibility through the installation of heat pumps and the integration of renewables (RES). Firstly, UFE believes that a stronger climate-centric approach is needed alongside the focus on energy efficiency to achieve the decarbonisation of the building sector and help to reduce its GHG emissions. Indeed, energy efficiency savings does not automatically map an equivalent GHG emission reduction. Therefore, all EU regulations should integrate a minimum carbon requirement for residential and non-residential buildings and introduce complementary obligations for carbon component and GHG emission reduction. Secondly, it is crucial that the RW address the issue of the lack of information, visibility and awareness on the financial support to building renovation. UFE thinks that more specific funds should be created to assist the households and building owners in their efforts. The selection and cost-effectiveness of the projects financed by EU funds should be addressed to deliver more GHG emission and energy savings per euro invested. The Cohesion Fund and the European Structural and Investment Funds can both contribute to address these barriers and to create more synergies with the Energy Performance Contracting. Furthermore, UFE welcomes the will of the EC to fight energy poverty and empower consumers. UFE fully supports the generalisation of aid advice among Member States, such as the energy checks set up in France, and the focus put on the buildings inhabited by the low-income households. In this regard, digitalisation and smart meter data can help improving the living conditions and managing the energy expenses of customers. UFE firmly believes the EC should prioritise low-carbon and efficient technologies, such as heat pumps, to strengthen the climate resilience of the EU building stock. The EC should also give a special attention to the renovation of the public buildings (e.g. schools, administration, hospitals, etc.). For the power system and the building sector, the integration of RES is a top priority which should also contribute to empower the consumers and reflect their new role as prosumers and notably be enhanced by developing heating networks. Another priority is the deployment of recharging infrastructure in all buildings by implementing ambitious targets and re-opening the article 8 of the Energy Performance Building Directive. The distribution networks are prepared to provide and reinforce the grid connections to assist the development of e-mobility. UFE presents here some of its recommendations further developed in the document attached: - Mandatory objectives for the reduction of energy consumption and of GHG emissions in the residential and tertiary buildings should be set. - The EC should encourage the phasing-out of fossil energies towards low-carbon energies for the renovations of residential and non-residential buildings. - Indicating the GHG emissions produced within energy performance diagnosis should be mandatory to raise knowledge among citizens about the climate efficiency of buildings.
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Response to Revision of Alternative Fuels Infrastructure Directive

4 May 2020

UFE welcomes the revision of the Directive 2014/94/EU and supports the Inception Impact Assessment (IIA) proposed by the EC to adapt the Directive to the EU Green Deal. The AFID revision is needed to address a fragmented European charging infrastructure market, to support investment and remove market barriers, with the aim to allow a smooth uptake of e-mobility and a seamless driver experience for EU citizens. The current AFID does not promote sustainable transport and must be modified to address the surge of the EV market by 2030. Nevertheless, UFE would also like to provide further elements that should be included in the IIA. The scope of AFID should be extended and set minimum requirements for all charging infrastructure accessible to the public. UFE considers that some rapid technological developments have not been well enough integrated in the AFID. In particular, the scope extension should recognise smart charging technologies and the differentiation of various charging power levels in line with the progress made on high-power charging to accommodate the needs of the HDV segment (e.g. trucks, long haul, coaches, buses). The underlying technologies facilitating communication between parties and systems should be interoperable. The EC should assess the disparities in the deployment of alternative fuel infrastructures between MS under Problem 1. Such an assessment is required to capture the actual need for charging infrastructure across the EU and push for an EU-wide coherent approach considering the diversity of needs and uses of charging infrastructures between the Member States’ territories. “Interoperability” under Problem 3 should be addressed through a consumer approach, by guaranteeing payment solutions, ensuring open networks based on open standards, as well as making available information on the infrastructure location and access to ease the access and use of charging infrastructures throughout the EU. Unlike the IIA, UFE is confident that the electricity system will be able to integrate the important EV deployment by 2030. However, the deployment of smart charging in the public infrastructure could be developed in the residential district and tertiary areas especially where a lack of private charging infrastructure can be observed in condominiums. UFE believes that the IA should assess: - The revision of the “alternative fuels” definition to ensure its consistency with the targets defined in the CO2 regulations. A new specific definition for cars and vans (LDV) should be introduced with a CO2 emission threshold to support only zero-emission fuels. The current “alternative fuels” definition should keep applying to HDVs while ensuring their compatibility with the 2030 and 2050 targets through the development of electric and decarbonised hydrogen refuelled HDVs. - The need of national binding targets for the deployment of recharging points through a new metric reflecting the diversity of needs and uses in the Member States and their current level of infrastructure deployment. Such targets must be adapted to the vehicle type considering the stage of the infrastructure deployment for LDVs is more advanced than for HDVs, and that both use different types of charging points. - The importance of the role of local and regional authorities in the deployment of recharging points depending on the territory needs through a global approach, at the EU and national levels. In France, for instance, master plans will be implemented with local authorities to ensure that the infrastructures deployed comply with the territory needs and specificities. - Regarding the TEN-T Core Network, the target of one charging point/60 km should be mandatory and the need for ad-hoc subsidies assess to support the expected costs of infrastructures. - The incentivisation of the electrification of maritime transport should be examined in the new AFID as the increase of the electricity usages are foreseen in initiatives (e.g. EUFuel Maritime).
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Meeting with Ditte Juul-Joergensen (Director-General Energy)

18 Feb 2020 · Role of electricity in the clean energy transition

Response to Climate Law

5 Feb 2020

The Union of the French Electricity industry (UFE), the trade association for the French electricity sector, warmly welcomes the European Commission’s ambition to adopt a text that would enshrine in law the carbon neutrality objective in 2050. However, UFE believes that to achieve climate-neutrality, the right regulatory and financial framework must be in place. UFE also supports a trajectory to reduce the CO2 emissions by at least 50 % and up to 55 % by 2030. By doing so, Europe would avoid carrying the burden of the effort solely on the 2030 – 2050 period and would help accelerate the transition towards low-carbon sources of electricity generation. To that extent, UFE would like to recall the fact that electrification and energy efficiency are essential to enable the European Union to reach the carbon neutrality expected within 30 years. Indeed, according to various forecasts, the electricity needs of the EU should double by 2050. Therefore, only a massive electrification of certain sectors such as transport (which currently accounts for nearly a quarter of the continent’s emissions), could allow the EU to follow the decarbonisation path, mapped out by the European executive. In addition, Europe should take into account the key role of networks (transmission and distribution) from an investment point of view (e.g. TYNDP, PCIs, EIR), and from a more operational point of view (e.g. expected digitalisation of infrastructures). Indeed, with an increased use of electricity and an increasing and planned integration of renewable energies, the energy system will become more and more complex. Crucial and structuring reforms for the future of the energy transition will have to be carried out during this mandate in order to achieve the stated objective. The ETS system will have to be reformed to achieve the emergence of a satisfactory and sufficiently predictable carbon price, capable of stimulating investment in low-carbon technologies as well as in research and innovation. Such a reform should also go hand in hand with the revision of the Energy Taxation Directive and the establishment of a border adjustment mechanism. Competitive carbon neutral energy options (variable renewables, hydropower, nuclear generation, storage, renewable heat and district heating …) are capital intensive. Long-term price commitments and adapted investment frameworks including long-term arrangements should be made easier, especially regarding competition rules, to ensure their cost-effective and timely development. Thus, this climate law will be an essential tool to establish Europe’s ambition, position itself as a leader in the world’s energy transition and send a strong message to its citizens. Indeed, social acceptability is crucial to meet the objectives, both from the point of view of consumers – for whom it is necessary to alleviate the cost of the transition – and from a social point of view, where the workforce directly affected by the changes in the electricity sector will have to be accompanied and protected.
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Meeting with Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans)

30 Jan 2020 · Speech on the European Green Deal at the UFE Internal European Seminar

Meeting with Dominique Ristori (Director-General Energy)

3 Oct 2018 · la place et le rôle stratégique du secteur électrique dans la transition énergétique et la décarbonisation de l'économie

Meeting with Dominique Ristori (Director-General Energy)

17 Feb 2017 · Energy policy

Meeting with Dominique Ristori (Director-General Energy)

3 Nov 2016 · Energy Union, Market design

Meeting with Miguel Arias Cañete (Commissioner)

2 Jun 2016 · Climate change, decarbonisation of the economy, security of electricity supply and the role of consumers in the energy transition.

Meeting with Maria Cristina Lobillo Borrero (Cabinet of Vice-President Miguel Arias Cañete)

26 May 2016 · Electricity Market Design

Meeting with Dominique Ristori (Director-General Energy)

4 Sept 2015 · European Energy policies

Meeting with Juraj Nociar (Cabinet of Vice-President Maroš Šefčovič)

13 Apr 2015 · Energy Union

Meeting with Joachim Balke (Cabinet of Vice-President Miguel Arias Cañete), Maria Cristina Lobillo Borrero (Cabinet of Vice-President Miguel Arias Cañete)

26 Mar 2015 · Renewable energies

Meeting with Eric Mamer (Digital Economy)

25 Mar 2015 · DSM

Meeting with Joachim Balke (Cabinet of Vice-President Miguel Arias Cañete), Maria Cristina Lobillo Borrero (Cabinet of Vice-President Miguel Arias Cañete), Silvia Bartolini (Cabinet of Vice-President Miguel Arias Cañete)

20 Jan 2015 · European electricity market, future of European energy and climate polices