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Vattenfall

Vattenfall is a European energy company with approximately 20,000 employees working to enable fossil-free living through electrification of industries, transportation and heating.

Lobbying Activity

Meeting with Christian Ehler (Member of the European Parliament) and EnBW Energie Baden-Württemberg AG and

12 Dec 2025 · Energiepolitik

Meeting with Pierre Schellekens (Director Energy)

2 Dec 2025 · Commission 2026 work programme and renewable energy

Vattenfall urges aligning Taxonomy rules with existing EU laws

27 Nov 2025
Topic — This review updates technical screening criteria for the EU Taxonomy environmental delegated act.
Message — Vattenfall requests that "Do No Significant Harm" criteria match existing EU legislation and permits. They advocate for using certified environmental management systems to demonstrate compliance efficiently. Finally, they suggest removing specific technical mandates for nuclear and hydropower plants.123
Why — This would reduce administrative burdens and lower compliance costs for energy operators.4
Impact — Environmental groups lose the power to demand ecological measures that exceed national economic exemptions.5
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Meeting with Tomas Tobé (Member of the European Parliament)

4 Nov 2025 · Energy Policy

Meeting with Christian Ehler (Member of the European Parliament) and EPIA SolarPower Europe and

26 Sept 2025 · Energy policy

Vattenfall Backs 90% Emissions Cut by 2040

12 Sept 2025
Topic — EU's 2040 climate target amendment to achieve net-zero by 2050.
Message — Vattenfall urges EU legislators to adopt the 90% net GHG reduction target by 2040 and establish a separate target for permanent carbon removals. They request allowing limited international carbon removal credits in EU ETS for compliance.123
Why — This provides long-term investment certainty for their fossil fuel phase-out plans.45
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Meeting with Michael Bloss (Member of the European Parliament) and Schneider Electric

9 Sept 2025 · Energiepolitik

Vattenfall warns offshore wind costs will rise under expanded CBAM

26 Aug 2025
Topic — EU proposal to extend carbon border adjustment mechanism to downstream products like steel foundations.
Message — Vattenfall requests a phased implementation with at least two years' notice before extending CBAM to downstream products. They warn that including foundations would increase offshore wind project costs and burden suppliers already facing cost pressures and reporting requirements.123
Why — This delay would allow their suppliers to adapt cost-efficiently and avoid driving up offshore wind prices.45
Impact — Chinese steel and foundation manufacturers lose cost advantages that currently help them compete in EU offshore wind projects.6
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Meeting with Christian Ehler (Member of the European Parliament)

22 Aug 2025 · 2040 target and climate policy

Meeting with Jessika Roswall (Commissioner) and

12 Jun 2025 · EU’s Industrial and Sustainability Agenda

Meeting with Christian Ehler (Member of the European Parliament) and BDEW Bundesverband der Energie- und Wasserwirtschaft e. V. and

23 May 2025 · EU Energiepolitik

Meeting with Abir Al-Sahlani (Member of the European Parliament) and Ericsson and

14 May 2025 · Regelförenkling och hållbarhetsarbete

Meeting with Isabella Lövin (Member of the European Parliament) and Ericsson and

14 May 2025 · Swedish businesses on the Omnibus Simplification Package and practical implementation of sustainability due diligence

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

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

Vattenfall urges EU to simplify sustainability reporting rules

26 Mar 2025
Topic — The initiative aims to make EU Taxonomy reporting simpler and more cost-effective.
Message — Vattenfall proposes replacing cumulative materiality thresholds with fixed limits per activity to reduce complexity. They also want to eliminate mandatory operating expenditure reporting and specific nuclear fuel requirements.12
Why — Vattenfall would lower its operational costs by no longer tracking numerous minor activities.3
Impact — Transparency advocates lose detailed visibility into the environmental impact of smaller economic activities.45
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Response to Implementing Act on non-price criteria in renewable energy auctions

20 Feb 2025

We appreciate the European Commissions commitment to swiftly developing the necessary implementing and delegated acts following the adoption of the Net-Zero Industry Act. A clear and well-designed implementation framework is essential for providing regulatory certainty to market participants and governments. While we fully support the broader ambition of enhancing Europe's industrial resilience and sustainability, we believe that the current proposal raises some practical concerns: Administrative feasibility should be prioritised, particularly regarding supplier reporting and resilience contribution complexity. Clearer sustainability criteria will help ensure effective, fair, and comparable assessments. A system needs assessment should be conducted to ensure that non-price criteria on system integration support actual market requirements. Further transparency is needed on the impact of the proposed resilience requirements on the energy transition. To support the development of a balanced and effective framework, we provide in the enclosed document detailed observations and recommendations. We look forward to continued dialogue to ensure that the implementation framework effectively supports the EUs climate and industrial goals.
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Meeting with Isabella Lövin (Member of the European Parliament)

29 Jan 2025 · Clean Industrial Deal

Meeting with Pär Holmgren (Member of the European Parliament)

29 Jan 2025 · Industry and Energy policy

Meeting with Christian Ehler (Member of the European Parliament) and EPIA SolarPower Europe and

13 Dec 2024 · Energy policy

Meeting with Miguel Gil Tertre (Cabinet of Executive Vice-President Teresa Ribera Rodríguez) and WindEurope and

5 Dec 2024 · To discuss European wind industry

Meeting with Stine Bosse (Member of the European Parliament)

6 Nov 2024 · European environmental policy

Meeting with Pär Holmgren (Member of the European Parliament)

6 Nov 2024 · Hydropower

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

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

Meeting with Tomas Tobé (Member of the European Parliament)

14 Oct 2024 · Energy Policy

Meeting with Thierry Breton (Commissioner) and

11 Apr 2024 · Speech on the role of nuclear industry in the decarbonisation of the EU economy with focus on small modular reactors in particular

Vattenfall Urges Higher Weighting for Qualitative Auction Criteria

28 Feb 2024
Topic — European Commission guidance on non-price criteria and design elements for renewable energy auctions.
Message — Vattenfall recommends weighting non-price award criteria higher than financial bids and limiting developers to one site per auction round. They also advocate for indexed strike prices to manage inflation and support sealed-bid contracts in emerging markets.123
Why — These measures would lower financial risks and ensure a more diverse competitive landscape.45
Impact — The supply chain loses out when uncapped negative bidding drives up project costs.67
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Response to Network Code on Cybersecurity

16 Nov 2023

Vattenfall appreciates the opportunity to provide our feedback on the NCCS. We support the Commission's efforts to enhance the cybersecurity resilience of the EU and to foster a harmonised approach across Member States. We recognise the importance of the NCCS as a key instrument to ensure a high level of security of network and information systems across the EU. To ensure efficient implementation of the NCCS, we request upfront clarification of the scope and link to other legislation. The proposal introduces high-impact entities and critical-impact entities, which cover a wide range of sectors and subsectors, as well as digital service providers. However, the criteria for identifying these entities leave room for interpretation by the competent authorities. This could result in inconsistent and fragmented implementation across the EU, creating legal uncertainty for entities operating in multiple jurisdictions. We urge the Commission to provide upfront guidance and clarity on the scope and criteria for identifying essential and important entities, as well as the thresholds and indicators for assessing the impact of incidents. Vattenfall welcomes the introduction of a regular review cycle, which will allow for periodic evaluation and adaptation of the legal framework to the evolving cyber threat landscape and technological developments. We believe that this will enhance the effectiveness and coherence of the NCCS. We suggest that the review cycle should be aligned with the review cycle of other relevant EU legislation, such as the NIS 2.0 Directive and the Cyber Resilience Act, to ensure consistency and avoid duplication. This would also reduce the number of time dependencies and thus lower the risk for waiting periods if a party misses a deadline. We also call for more alignment and compatibility between the revised NIS 2.0 Directive, which is currently being implemented by Member States. We believe that both initiatives should complement each other and avoid creating conflicting or overlapping requirements for entities subject to both regimes. Regarding certification, Vattenfall supports omitting mandatory ISO 27000 certification from the NCCS, but introducing an open approach risks adopting a more convoluted approach via national verification schemes. However, we also support that entities certified under NIS 2 are recognised as complying with the NCCS and the other way around. Relatedly, we would suggest increased cooperation and coordination between the relevant authorities and bodies at the European level, in addition to the national level. We note that the proposal introduces a new article on the cooperation between competent authorities and CSIRTs at the national level, but we miss a similar article on the cooperation between relevant authorities and bodies at the European level. Thus, entities operating in multiple member states risk a double reporting at both the national and EU level. We propose that the Commission facilitates the exchange of information and best practices among the national authorities and CSIRTs, as well as the European authorities and bodies, such as ENISA, the European Cybersecurity Board, and the Cooperation Group. We also suggest that the Commission should establish a single point of contact for cross-border entities, to streamline the reporting and notification processes and to ensure a consistent and harmonised implementation of the NCCS. As concerns the contact points for affected entities, we suggest clarifying the single point of Contact should be a single address and not a person, to ensure 24/7 availability. To ensure a balanced reporting, the 4 hour reporting standard could be harmonised with 24 hours pick-up for competent authorities.
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Meeting with Tiemo Wölken (Member of the European Parliament, Shadow rapporteur)

7 Jul 2023 · Carbon Removals (Staff level)

Meeting with Nils Torvalds (Member of the European Parliament)

13 Jun 2023 · Carbon removals

Vattenfall demands technology neutral approach for heat pump expansion

25 May 2023
Topic — The European Commission is developing a plan to accelerate heat pump deployment.
Message — Vattenfall advocates for technology-neutral strategies including district heating. They request aligned regulations to support natural refrigerant use.123
Why — Restricting individual subsidies protects Vattenfall's district heating market share.4
Impact — Individual heat pump suppliers lose access to urban district heating zones.5
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Meeting with Erik Bergkvist (Member of the European Parliament)

24 May 2023 · Möte

Meeting with Pascal Canfin (Member of the European Parliament) and ArcelorMittal and DHL Group

23 May 2023 · Green Deal

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

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

Meeting with Kadri Simson (Commissioner) and

4 May 2023 · Importance of hydropower in ensuring electricity system flexibility; The application of the electricity market reform to hydropower; How to strengthen the visibility of hydropower as one of the key sources of renewable energy.

Meeting with Riccardo Maggi (Cabinet of Executive Vice-President Frans Timmermans) and ELECTRICITE DE FRANCE and

4 May 2023 · Presentation of new business group

Vattenfall Calls for Simpler EU Taxonomy Reporting Standards

3 May 2023
Topic — The initiative defines sustainable economic activities for the remaining four EU environmental objectives.
Message — Vattenfall recommends harmonized reporting templates across all objectives to improve clarity and reduce administrative work. They propose a materiality threshold based on international accounting standards to focus reporting on significant activities. Furthermore, they advocate for the inclusion of waste-to-heat in the circular economy criteria.123
Why — Using materiality thresholds and single templates would lower the company's regulatory compliance costs.45
Impact — Investors lose detailed data on smaller business activities that fall below the materiality threshold.6
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Vattenfall Urges Inclusion of Waste-to-Heat in EU Green Taxonomy

3 May 2023
Topic — Defining sustainable investment criteria for circular economy, water, pollution, and biodiversity objectives.
Message — Vattenfall requests including waste-to-heat incineration and applying a materiality threshold to reporting requirements. They suggest aligning reporting templates to avoid redundant mapping and inconsistent activity codes.12
Why — This would reduce their administrative burden and allow waste assets to qualify for green financing.3
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Meeting with Nicolás González Casares (Member of the European Parliament, Rapporteur) and Uniper and Nord Pool European Market Coupling Operator AS

3 May 2023 · Electricity Market Design

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

3 May 2023 · REMIT (Staff Level)

Meeting with Emma Wiesner (Member of the European Parliament)

2 May 2023 · Framtidens kärnkraft

Vattenfall Backs Gradual Evolution of EU Power Market Rules

26 Apr 2023
Topic — Reforming EU electricity market rules to increase resilience and lower consumer energy bills.
Message — The company supports a gradual reform approach while opposing revenue caps and regulated wholesale prices. They suggest that financial support schemes for clean energy should remain voluntary.123
Why — Avoiding mandatory caps and rigid regulations protects their investment returns and maintains competitiveness.4
Impact — Governments and struggling consumers lose access to relief funds from redistributed energy profits.5
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Meeting with Emma Wiesner (Member of the European Parliament)

11 Apr 2023 · Kärnkraftens roll i framtidens energisystem

Meeting with Jessica Polfjärd (Member of the European Parliament)

11 Apr 2023 · Panel on the future of Nuclear energy

Meeting with Emma Wiesner (Member of the European Parliament)

27 Mar 2023 · Framtidens elmarknad

Vattenfall urges priority for industrial carbon removals by 2026

23 Mar 2023
Topic — The European Commission is proposing a regulatory framework to certify and monitor sustainable carbon removals.
Message — Vattenfall requests that the certification system becomes fully operational by 2026. They argue industrial removal methodologies should be adopted quickly, while ensuring credits go to the company capturing the emissions.123
Why — This would provide Vattenfall with direct financial rewards and regulatory certainty for its carbon capture projects.45
Impact — Carbon farming initiatives face potential delays and stricter scrutiny compared to the company’s preferred industrial methodologies.6
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Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans)

13 Mar 2023 · Electricity market design reform

Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur) and BUSINESSEUROPE and

8 Mar 2023 · Corporate Sustainability Due Diligence

Meeting with Emma Wiesner (Member of the European Parliament) and Energiföretagen / Swedenergy

8 Mar 2023 · Elmarknadsdesign

Meeting with Jens Geier (Member of the European Parliament)

8 Mar 2023 · Exchange on the electricity market design

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

8 Mar 2023 · Energy Market design

Meeting with Penelope Papandropoulos (Cabinet of Executive Vice-President Margrethe Vestager), Thomas Woolfson (Cabinet of Executive Vice-President Margrethe Vestager)

17 Feb 2023 · European energy sector and the upcoming electricity market design reform.

Meeting with Thor-Sten Vertmann (Cabinet of Commissioner Kadri Simson)

16 Feb 2023 · The reform of the electricity markets framework.

Meeting with Emma Wiesner (Member of the European Parliament)

9 Feb 2023 · Panel om EUs industrins roll i energiomställningen

Meeting with Mauri Pekkarinen (Member of the European Parliament)

8 Feb 2023 · Discussion on electricity market reform

Meeting with Tom Berendsen (Member of the European Parliament)

25 Jan 2023 · Electricity Market Design - Meeting with APA

Meeting with Barbara Glowacka (Cabinet of Commissioner Kadri Simson)

12 Jan 2023 · Biomass

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

12 Dec 2022 · Energy Policy (Staff Level)

Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur) and EUROPEAN TRADE UNION CONFEDERATION and

7 Nov 2022 · Corporate Sustainability Due Diligence

Meeting with Peter Liese (Member of the European Parliament, Rapporteur) and European Environmental Bureau and

14 Oct 2022 · ETS

Meeting with Virginijus Sinkevičius (Commissioner) and

7 Oct 2022 · To discuss maritime spatial planning (MSP), co-existence and multi-use of the space, permitting, regional cooperation, sustainability and recycling.

Meeting with Pär Holmgren (Member of the European Parliament)

24 Aug 2022 · Plans to rearrange the thermal power plant, both in terms of materials that are burned and plans for the CCS plant

Meeting with Pilar Del Castillo Vera (Member of the European Parliament, Rapporteur) and Apple Inc. and

24 May 2022 · Data Act

Vattenfall urges faster and more ambitious industrial carbon removal certification.

2 May 2022
Topic — A new EU regulatory framework to certify and monitor carbon removals.
Message — Vattenfall requests an operational certification system by 2026 that prioritizes industrial solutions. They also advocate for higher 2030 targets and ensuring credits reward the capturing companies.123
Why — This would create financial incentives and market value for Vattenfall's bio-energy projects.45
Impact — Nature-based projects may face delays as Vattenfall pushes for industrial priority.6
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Meeting with Frans Timmermans (Executive Vice-President) and SSAB AB and

31 Mar 2022 · Signing ceremony for Innovation Fund contributions to decarbonisation projects

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

23 Mar 2022 · RED III

Meeting with Damien Carême (Member of the European Parliament)

21 Jan 2022 · Fit for 55

Meeting with Christophe Grudler (Member of the European Parliament, Shadow rapporteur)

12 Jan 2022 · Révision de RED II

Meeting with Didier Reynders (Commissioner)

12 Jan 2022 · Les consommateurs Véhicules électriques

Response to Carbon Border Adjustment Mechanism

8 Nov 2021

Vattenfall strongly supports the EU’s target of becoming a climate-neutral economy by 2050. To reach the Paris Agreement’s 1.5 °C goal, other regions must move in the same direction, though we recognise that it will be done in different pace and by different policies. The best solution is always if an equally strong climate policy framework is put in place also with respect to industry located in the counties which are the EU’s main trading partners. Hence, further international collaboration and expansion of carbon pricing globally remains a priority. In the meantime, policies that secure a level playing field for the EU industries who compete on a global market will be needed. For that reason, we welcome the European Commission’s proposal to implement a Carbon Border Adjustment Mechanism (CBAM) that effectively puts a CO2 price on certain goods imported to the EU, thereby creating equal conditions in terms of the CO2 price faced by energy-intensive industry and incentivising third countries to decarbonise their industry production and society towards ‘net-zero’ GHG emissions by 2050. Most importantly, the discussions on a CBAM must not delay the urgent revision of the EU ETS in any way. We believe that the EU ETS is one of the most important tools the EU has at its disposal to deliver on its new 2030 and 2050 climate targets. The EU ETS policy needs to be fully and swiftly aligned with the EU’s increased climate ambition. Until the CBAM has been established, the industry sectors will continue to receive free allocation of ETS allowances. In terms of the actual design of a CBAM, we support the Commission’s proposal to create a separate pool of CBAM certificates with a price reflecting the weekly average of closing prices in the EU ETS market. We believe that it is essential to maintain the integrity of the EU ETS at all times, and therefore it is not advisable to include importers of products from third countries directly into the EU ETS bearing in mind the strong compliance regime (monitoring and verification of actual CO2 emissions) and the need for a predictable supply and demand. To build credibility of the measure globally and ensure compatibility with international trade rules, double protection in the form of both free allocation and a CBAM needs to be avoided. Hence we support the phasing out of free allocation in sectors where a CBAM will be applied. Furthermore, we believe it is equally important to ensure that the EU’s industrial competitiveness is protected in energy-intensive sectors that mainly export outside the EU, which is currently not addressed by the CBAM proposal. We urge the Commission to consider this issue and to come up with a proposal to address the situation, for example through a rebate system. Next to the five sectors proposed as CBAM pilots, cement, iron & steel, aluminium, fertilizers and electricity, we propose to also include hydrogen production as a pilot sector. Hydrogen will play a very important role in decarbonising the energy system and when hydrogen is imported to the EU it will be equally important to encourage fossil-free hydrogen over grey hydrogen since it furthers this goal. Hydrogen is already included in the EU state aid guidelines as a sector susceptible to carbon leakage and the EU is currently a global frontrunner on green hydrogen development. Without a CBAM on hydrogen, a significant share of hydrogen imports risks being fossil-based, thereby undermining the EU’s efforts to decarbonise these sectors . Carbon leakage can also be a problem in the EU power market. Therefore, we support the Commission’s proposal to include electricity in the CBAM framework. To reflect the real environmental performance and give producers of electricity imported into the EU a strong incentive to provide actual CO2 emissions data, the specific default values should be based on marginal production e.g. the 10 % worst performers in the exporting country, instead of the average performers.
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Response to Updating Member State emissions reduction targets (Effort Sharing Regulation) in line with the 2030 climate target plan

8 Nov 2021

Vattenfall supports the European Commission’s proposal to revise the Effort Sharing Regulation (ESR) in line with the EU’s increased 2030 climate ambition. All sectors must contribute towards the unprecedented task of making the EU a climate-neutral welfare economy. Without significant progress in all sectors this EU-wide ambition may not become a reality. A prerequisite for a cost-effective target achievement is that also the emissions from non-EU ETS sectors become subject to a corresponding CO2 price incentive. For these reasons, Vattenfall supports the Commission’s proposal to establish a new, separate and adjacent ETS covering all the EU’s emissions in buildings and road transport sectors from 2025. In principle, emissions from sectors covered by an ETS policy should not be regulated by the Effort Sharing Regulation at the same time. The CO2 emissions covered by the ETS are strictly limited by the total number of allowances that are issued and the market steers the required CO2 emission reductions to where they can be achieved most cost-efficiently across the EU. Hence, it would go against the logic of the cap-and-trade policy if CO2 emissions under the ETS are also subject to a effort sharing legislation that puts individual emission ceilings on Member states. Ultimately, the contribution by these sectors towards achieving the EU’s climate targets is determined by the declining absolute cap and more specifically the Linear Reduction Factor (which the Commission has proposed should be 5.15 % from 2026 and 5.43 % from 2028 in the new, separate ETS). We see, however, that these sectors could remain a part of the ESR during a pilot until the proper functioning and desired results of the new ETS have been demonstrated. Due to the specific distribution key used in the ESR (mainly the GDP/capita of Member states), it is important for the overall cost-efficiency of the EU climate policy framework that Member states can collaborate across the borders in meeting their ESR targets and thereby transferring Annual Emission Allocations (AEA) between themselves. For the same reason, it is also positive that the Member states with the most ambitious ESR commitments are given a possibility to achieve a part of their ESR targets by using ETS allowances, though it must always be supplementary to non-ETS sector abatement and done with a large degree of predictability. We are questioning the Commission’s proposal to move the non-CO2 greenhouse gas emissions in the agriculture sector from the ESR to the LULUCF regulation. Putting these sectors under a separate ‘net-zero’ GHG target for 2035 would mean that the forestry sector must compensate for insufficient progress in the agriculture sector specifically, which could limit the potential for using sustainable biomass for high-efficient CHP production as well as BECCS.
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Response to Updating the EU Emissions Trading System

8 Nov 2021

Vattenfall strongly welcomes the European Commission’s initiative to further improve and strengthen the EU ETS in line with the EU’s increased climate ambitions for 2030 and 2050. Most importantly, the new LRF (4.2 %) should take effect as early as possible to promote early action and investor certainty. This should be combined with a one-off reduction of the ETS allowance cap to better reflect actual emissions and to align with an EU ETS cap trajectory as if the new LRF would have been applied from the start of Phase 4 (2021). We fully support the proposals to keep the MSR’s intake rate at 24 % and to permanently invalidate the most excessive surplus of EUAs from the Reserve above 400 M EUAs on a regular basis. At the same time, we question why the Commission did not propose a lowering of the MSR’s upper activation threshold (833 M EUAs) to reflect a more decarbonised energy system and hence lower hedging needs. The proposal for a more dynamic MSR intake rate, in the 833-1,096 TNAC interval (‘buffer zone’), could have its benefits, but without a lowering of the 883 threshold, it will actually lead to a less ambitious MSR mechanism, ceteris paribus, allowing more unused EUAs in circulation in the market. It is important to further enhance and expand the use of CO2 pricing to other sectors of the economy. More specifically, it is the right approach to include the shipping sector in the existing EU ETS while at the same time establish a new and separate ETS for the buildings and road transport sectors, as proposed by the Commission. Although not every sector is suited for a direct inclusion in the EU ETS, all sectors need to pay for their emissions and contribute to cutting the EU’s GHG emissions by at least -55 % until 2030. The new separate ETS for the building and transport sectors should be entirely parallel and not lead to any double CO2 pricing for installations already covered by the existing EU ETS. We support the proposal to ensure that the free allocation regime does not discourage investments in new break-through technologies, such as fossil-free steel production. For the same reason, we do not agree with the Commission’s proposal to exclude certain combustion installations from the EU ETS just because they have switched to using a certain share of biomass (‘95 % rule’). This could result in both adverse incentives and instable regulatory conditions. Clearly, a fuel-independent approach is required also here. It is positive that the Commission wants to ensure that CHP plants in district heating are treated equally with industrial cogeneration. Industry will require further support to move to fossil-free production. Therefore, it is positive that the EU Innovation Fund will be increased by setting aside a larger share of the ETS allowance cap and that Carbon Contracts for Difference (CCfD) are recognised as an efficient tool to provide additional incentives that can work well together with the EU ETS. The road toward making the EU a climate-neutral economy by 2050 must be a socially fair transition. Although the rising electricity prices in 2021 are mainly caused by soaring fossil fuel prices, the impact on low-income households can be mitigated by using revenues from the EU ETS. The solution to avoid similar energy crisis in the future is to speed up the energy transition, not the other way around. In the spirit of EU solidarity, we also support an increase of the Modernisation Fund, however it should not support the use of fossil fuels. We agree with the intention that all means of CO2 transportation to the storage site should be recognised when reducing emissions by Carbon Capture and Storage (CCS) and that the obligation to surrender EUAs is removed also when emissions are reduced by Carbon Capture and Utilisation (CCU). However, there is still a lack of incentives for ETS operators to achieve negative CO2 emissions via Bio-Energy CCS (BECCS), although highly needed to reach ‘net-zero’ GHG emissions.
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Response to Commission Delegated Regulation on taxonomy-alignment of undertakings reporting non-financial information

2 Jun 2021

Vattenfall acknowledge the role of the taxonomy in providing a common language for investors and promoting investments in sustainable technologies to drive the green transition and the necessity of reporting obligations to fulfil the purpose of the Taxonomy. As such, it is of importance that the taxonomy and the included reporting obligations steers in the desired direction, to achieve the objectives. Any sustainable finance disclosure should not only be meaningful and relevant for the stakeholders but also not place a disproportionate burden considering cost and administration. The disclosure requirements should be sound and clear to apply, proportionate; be coherent with existing financial reporting practices and with the requirements put forward under the Taxonomy Regulation. We generally welcome the phased-in approach towards the reporting obligations. However, there are still many uncertainties on the actual requirements. Even if the draft includes a simplification for the first reporting year, the time for preparation is seen as too short (the first reporting year has started while the requirements are yet not published. Vattenfall believes that a clear timeframe related to the adoption of the Delegated Act will set a level playing field for the reporting obligations. The delegated act needs to be directed towards a materiality perspective in reporting throughout. There ought to be a materiality threshold for activities reported to avoid unjustified administration. Vattenfall recommend to include a reference to materiality as defined by the International Accounting Standards Board International Accounting Standards Board (IASB). The reporting under the Taxonomy should be aligned with the International Financial Reporting Standards (IFRS). In addition, the delegated act should be principle based, like IFRS, rather than, with current proposed wording, rule based on detailed level. Vattenfall stress that for the first time adaptation in 2022 (for financial year 2021) reporting on only eligible / non-eligible activities should not require comparable figures, nor a five year overview. We also want to point out that retroactivity, in some cases, is impossible to present, especially for divested companies where there is no possibility to retrieve needed information after date of divestment. Vattenfall propose no requirement on disclosure of CapEx plan until the year that the capex is reported for a specific activity. Even though utilities want to transform as quick as possible, the nature of our business has a long time horizon and infrastructure projects in our utilities sometimes take more than 7 years to be finalized due to size and permits etc. Vattenfall suggest to include ESMA’s proposed wording “maximum period of five years unless a longer period can be justified”. Vattenfall’s opinion is that we should have an objective on what should be reported rather than having detailed rules. It should be enough to focus on reasonable details on key assumptions or significant judgements used in calculating the figures rather than having av set of detailed mathematical formulas to compute the KPI’s. To provide disclosures on substantial deviations related to the CapEx plans would require increased administrative burden. Vattenfall recommend that the assessment of substantial is an estimation that need to be made by respective reporting company.
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Meeting with Thor-Sten Vertmann (Cabinet of Commissioner Kadri Simson) and Fortum Oyj and Statkraft AS

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

Response to Commission Delegated Regulation amending Regulation (EU) 2019/856 as regards the application procedure

14 Apr 2021

• We are in favor of a one-stage application procedure where it is possible to do additions or supplements after an initial evaluation if there are questions from the evaluators. The main benefit would be a faster decision procedure and avoidance of overlap of the next planned EIF call. However, since this would require more effort from all applicants it is very important with clear instructions what is required to be considered for funding and the principles for evaluation and ranking. • The present 2-stage application procedure takes quite a long time from close of the call to final decision of funding. It is unclear if the applications selected for stage 2 will have the possibility to take part in the next EIF call if rejected. It would be very unfortunate if they have to wait for another year. • Independent of a 1- or 2-stage procedure the requirements need to be very clear. This is especially important for a 1-stage procedure. As an example, it has been difficult to interpret how the absolute GHG emission avoidance has been evaluated. If the ranking is based on absolute amount, more cost effective (EUR/ton) but smaller projects may have been disqualified. It would have been good to know the minimum requirements beforehand. • We suggest that cost efficiency (EUR/ton) is used together with absolute GHG emission avoidance as evaluation criteria. • In the present 2-stage application procedure the information om what is required for stage 2 is very vague. Important that also these requirements are clear from start. • Instructions for templates and excel calculation’s tools need to be more clear. Written instructions are important. Webinar can be used as complements, but not as substitutes for written documentation. The Q&A was very useful, but could be improved further by shorter
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Response to Revision of EU rules on Gas

10 Mar 2021

Electrification and sector integration play an essential role in Europe’s ambition achieving climate neutrality by 2050. Vattenfall believes in a future where electrification is an efficient tool to realise the decarbonisation of, for instance, the transport and industrial processes to the greatest extent possible. The conversion of electricity into another energy carrier can extend the reach of electrification and through this reduce greenhouse gas emissions. Hydrogen is one energy carrier, for which Vattenfall envisages an important role to play. Against this background we are actively engaged in the discussions on the development of a European hydrogen market, have initiated and are looking into the launch of (industrial) partnerships and projects often making use of hydrogen and are in close contact with national policy makers regarding our activities in the various European markets. Thus, we would like to thank the European Commission for giving stakeholders the possibility to react to the combined evaluation roadmap/inception impact assessment of the “Hydrogen and Gas markets Decarbonisation Package” and to make use of this opportunity. We recommend the following to be included in the work of the European Commission on a "Hydrogen and Gas markets Decarbonisation Package": • The operation and ownership of Power-to-Gas installations belong to the domain of competitive non-regulated entities and existing European unbundling rules should be extended accordingly. • Planning on the location of electrolysers should be evaluated by all involved parties and should not result in stranded-assets • The European Commission should conduct a study to evaluate and compare the costs of a future hydrogen infrastructure and build-out of the electricity transmission grid • Amendment of European Network Codes are necessary to accommodate fossil-free hydrogen into the energy system A regulatory framework for hydrogen should follow the same unbundling principles as the gas sector, ensure coordinated infrastructure planning between gas/hydrogen and electricity, make sure that stranded-assets are being avoided, guarantee Third Party Access (TPA) and boost the hydrogen market by e.g. exempting hydrogen from network tariffs. Finally we want to stress that on a general level electricity network charges and levies must be adapted so that the use of electricity for energy system integration e.g. Power-to-Gas and Power-to-Heat applications is competitive in other sectors
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Meeting with Stefanie Hiesinger (Cabinet of Executive Vice-President Frans Timmermans) and Fortum Oyj and Statkraft AS

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

Meeting with Charlina Vitcheva (Director-General Maritime Affairs and Fisheries) and WindEurope and

1 Feb 2021 · Meeting with the European offshore wind industry on the follow-up of the EU offshore renewable energy strategy adopted in November 2020

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

22 Jan 2021 · 2030 climate and energy framework

Response to Climate change mitigation and adaptation taxonomy

16 Dec 2020

Vattenfall acknowledge the role of the taxonomy in providing a common language for investors and promoting investments in sustainable technologies to drive the green transition. As such, it is of importance that the taxonomy steers in the desired direction, to achieve the objectives. This is also where we would like to raise some concerns: Technology neutrality: All technologies should be treated equal. Vattenfall regrets that not all electricity production activities are included in the assessment, e.g. nuclear and waste-to-heat, thus making the basis incomplete. The Taxonomy should focus on best available technologies. Respect of EU acquis: The delegated acts and the proposed technical screening criteria should respect relevant EU acquis. EU legislation has world leading environmental ambitions and are already set to meet the six environmental objectives under the EU Taxonomy regulation. The do-no-significant harm (DNSH) criteria should therefore be considered fulfilled by complying with existing EU legislation, or the national implementation thereof. Vattenfall is pleased to see that the Commission confirms the contribution of hydropower to climate change adaptation and mitigation. However, we are concerned about its technical screening criteria. Existing hydropower, despite being key to decarbonize the energy system, risks to be considered not fully sustainable if the draft delegated acts do not change substantially. The proposed Do no significant harm (‘DNSH’) criteria for hydropower, especially those for “Sustainable use and protection of water and marine resources”, are not warranted or even ecological desirable everywhere. Applying indistinct generic environmental measures to all hydropower plants might not only be counterproductive, but could lead to negative ecological effects, especially due to the fact that each hydropower plant is tailor-made to fit local conditions and needs. Therefore, Vattenfall strongly argues that the specific requirements listed under (3) “Sustainable use and protection of water and marine resources”, are removed and replaced by: The activity complies with the provisions of Directive 2000/60/EC and in the Directive 2008/56/E. The same standard of reference to existing EU law must be set for all renewable electricity generation technologies. Vattenfall believes that the use of sustainable woody biomass can and should make a meaningful contribution to climate change mitigation. Misleading classification can risk stakeholder confidence in EU bioenergy. In our opinion, the DNSH requirements should be streamlined with the sustainability and greenhouse requirements, as well as the applied installation thresholds established in the Renewable Energy Directive. A technology neutral approach is needed for all different storage technologies, to ensure a level playing field for all flexibility technologies. Vattenfall argues that pumped hydropower storage should be eligible under the Taxonomy in the same way as all other storage technologies, without the need to fulfil additional and technology specific requirements. Cogeneration of heat/cool and power from gaseous and liquid fuels (CHP) is important for the phase out of coal from the heating sector. In a next step, natural gas is to be gradually replaced by CO2-neutral fuels, above all by increasing shares of renewable based hydrogen. To facilitate the transition, Vattenfall recommends that the input threshold should be raised at least to 165 gCO2e/kWh for fuel input and should be fixed until 2030, in order to avoid jeopardizing important investments in replacing coal and to enable significant contributions to the achievement of the 2030 and 2050 GHG reduction targets.
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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

The effort to reach the EU’s new climate targets must be shared between all sectors of the economy in a fair, coherent and cost-efficient manner. The additional effort of reducing GHG emissions that comes with the increased EU 2030 and 2050 climate ambition should be fairly distributed between the EU ETS policy and the non-ETS sectors which are regulated by the EU Effort Sharing Regulation (ESR). Until today, the largest GHG emissions reduction effort has been borne by the EU ETS, and the power sector in particular. Looking ahead, it is crucial that the CO2 emissions abatement pace is increased also in the non-ETS sectors and that CO2 pricing is used to a greater extent across all sectors. The European Commission’s Impact Assessment on EU ETS and Effort Sharing Regulation should carefully look into what is the optimal split of the GHG emissions mitigation requirement between these two key EU climate legislations that regulate approximately ½ of the EU’s total GHG emissions each. We believe that flexible instruments need to play a central role in the achievement of the EU’s climate target in all dimensions. While the ambition level for the EU ETS sectors is determined by one single EU-wide cap and allowances are constantly traded across borders, the ambition level for the non-ETS sectors is broken down to 27 national GHG reduction commitments. Depending on the distribution key used in the ESR (currently based on the GDP/capita of Member states), it is important for the overall cost-efficiency of EU climate policy framework that Member states can jointly meet their ESR commitment and thereby transferring Annual Emission Allocations (AEA) between themselves. For the same reason, it is also positive that the Member states with the most ambitious ESR commitments maintain a possibility to meet a part of their ESR targets by using ETS allowances, although it must be supplementary to non-ETS sector climate action and done with a large degree of predictability.
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Response to Updating the EU Emissions Trading System

26 Nov 2020

Vattenfall input to European Commission’s Inception Impact Assessment roadmap on the revision of the EU ETS directive. Vattenfall believes that the EU Emissions Trading System (EU ETS) needs to play a central role in achieving the EU’s ambitious climate objectives with regards to the sectors that it covers. It has potential to be a powerful and cost-efficient tool to deeply reduce GHG emissions in a market-based, technology-neutral and environmentally predictable manner. The following key measures to further improve and strengthen the EU ETS policy on the back of an increased EU 2030/2050 climate ambition can be defined already at this stage: ▪ The ETS allowance trajectory should decline more steeply based on a higher Linear Reduction Factor (LRF) set in line with the EU’s target of achieving a climate-neutral economy by 2050 and at least -55 % reductions of GHG emissions by 2030. The higher LRF needs to take effect as soon as possible, preferably as from 1 January 2023. The remaining years until 2030 will be decisive for achieving the EU’s climate ambitions. ▪ It is important that the Market Stability Reserve (MSR) is equipped with a strong ability to safeguard a robust ETS market development also in the future. Therefore, the review should result in the annual intake rate being kept at 24 % also in the period after 2023, in order to prevent new structural over-supply of ETS allowances and market distortions. ▪ In principle, it would be positive to further expand the scope of the EU ETS to other sectors. However, sectors that are not exposed to any CO2 price (e.g. maritime) or an insufficient CO2 price (e.g. individual heating, in some Member states) should be prioritized. In contrast, road transport is unlikely suited for this. What is absolutely crucial, though, is that all sectors of the economy are subject to a CO2 price signal. We particularly look forward to the following key aspects being further investigated by the European Commission in the Impact Assessment for the next reform of the EU ETS: ▪ Although we believe that the EU ETS should be the principal instrument to reduce GHG emissions, its role in the wider EU climate and energy policy framework varies a lot in the European Commission’s impact assessment on the EU 2030 Climate Target Plan. Thus, it should be carefully assessed what different ETS price trajectories follow from the perspectives of cost-efficiency, displaced CO2 abatements, low-carbon financing, etc. ▪ The actual level of the higher LRF depends on a number of different factors, not only from which year it starts to take effect, but also the distribution of the overall EU climate target between EU ETS and non-ETS sectors, to what extent a “rebasing” of the ETS allowance cap is made in Phase 4, etc. These types of relationships need to be clearly addressed in the upcoming impact assessment in order to derive the required LRF level. ▪ Next to maintaining a high intake rate of the MSR, it is also likely that the MSR’s two activation thresholds (400 and 833 M EUAs) needs to be adjusted in the upcoming review. To what extent the thresholds need to be lowered to reflect an increasingly decarbonised economy and gradually declining hedging needs in the EU ETS should also be a part of the European Commission’s impact assessment and MSR review. ▪ To reach the EU’s climate-neutrality target for 2050, it will also be necessary to achieve negative CO2 emissions. These removals can be of both natural and technological origin. The European Commission should investigate in its Impact Assessment how EU climate policy can be developed to not only incentivise a reduction of CO2 emissions but also the attainment of negative CO2 emissions, using e.g. Biomass-CCS (BECCS). [Please see the attached document for a more detailed response]
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Meeting with Kadri Simson (Commissioner) and

20 Oct 2020 · Discussion on the future adoption of the Offshore Renewable Energy Strategy. Presentation of the sector coordinated by Wind Europe.

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

21 Sept 2020

Vattenfall welcomes the opportunity to comment on the roadmap proposal for the Renewable Energy Directive (2018/2001) which will set the framework in which renewables will be deployed. Vattenfall is a European energy company with approx. 20,000 employees. For more than 100 years we have electrified industries, supplied energy to people's homes and modernized our way of living through innovation and cooperation. Our goal is to make fossil-free living possible within one generation. Everything we do and the decisions we take shall lead to this goal. This is the basis of Vattenfall’s strategy, and we advocate for a regulatory environment that makes this transition possible – in the energy sector and beyond in transport, industry, etc. In our opinion, • a potential opening of the REDII should focus on clarifying the usage of renewable electricity for power-to-heat applications and how it can be fully accounted for in the sub-targets for the share of renewable heat. A simple and appropriate methodology should be established which should also be applicable for various reporting requirements. • Before re-opening Art. 29ff on biomass sustainability criteria, the criteria for biomass fuels should be implemented first and experience should be gained. In line with Art. 29 par. 9 a review of the sustainability criteria shall be carried out in 2026 to take-stock on the effectiveness of the criteria. The European Commission in its roadmap document, rightly highlights the need to reflect on findings in the Hydrogen and System Integration strategies in the Renewable Energy Directive. In specific we think: • More clarification and guidance is needed on the policy instruments that stimulate demand and supply of hydrogen: In the European Hydrogen Strategy the European Commission is referring to the introduction of policy instruments, such as quotas to stimulate the demand for renewable hydrogen in specific end-use sectors but also supply-side instruments, e.g. Carbon Contract for Differences and the development of a respective pilot scheme. • The definition of renewable hydrogen used by the European Commission in the European Hydrogen Strategy needs to be linked to and anchored in the revision of REDII. Generally speaking, common definitions of the various forms of hydrogen need to be anchored in European legislation in order to become applicable but the revision of the gas package (Directive 2009/73/EC and Regulation 715/2009/EC) scheduled for June 2021 might be a more suitable legislation than the revision of the REDII as not all forms of hydrogen are being produced from renewable energy sources. However, in order to ensure that renewable hydrogen is eligible for counting towards the 14% renewables target of the transport sector according to Art. 25 para. 1 REDII, a definition of renewable hydrogen needs to be integrated or linked to the revision of the REDII. • The revision of the REDII should introduce a transparent European-wide GO scheme for renewable and low-carbon hydrogen. A European-wide GO for hydrogen could provide traders and end-consumers with genuine information on the origin of the hydrogen supplied to them. In terms of efficiency, legal certainty and to make use of synergies between the existing issuing bodies, a common European issuing body for all renewable, fossil-free and decarbonised energy, including hydrogen and subsequent conversion into synthetic fuels, should be taken into consideration.
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Response to Offshore renewable energy strategy

11 Aug 2020

At Vattenfall, accelerated growth in renewable energy is key to supporting our purpose to Power Climate Smarter Living and realize the transition to fossil-free living. We are also actively engaged in the transition of a number of other (industrial) sectors that account for a high degree of CO2-emissions e.g. steel, refineries, transportation and heat. We follow developments in different renewable offshore technologies with interest. As a leading European player in the offshore wind power industry, our input provided to the EU Offshore Renewable Energy Strategy will primarily focus on offshore wind. Generally, we welcome the upcoming EU Offshore Renewable Energy Strategy as an enabler to facilitate and accelerate the deployment of offshore wind. The European Commission estimates that an installed offshore wind capacity of up to 450 GW could be needed to reach carbon neutrality in Europe by 2050.1 Today, Europe installs around 3 GW of offshore wind per year. To become carbon-neutral it will need to accelerate the installation rate over a sustained period. The first half of the 2020s has a well-established pipeline of projects which is set to increase the installation rate to 7 GW per year by the second half of the decade. This rate needs to increase considerably – to over 20 GW per year – by the mid-2030s. We have identified five pillars to be addressed in the Offshore Renewable Energy Strategy that will accommodate an increase in offshore wind capacity of up to 450 GW to reach carbon neutrality in Europe by 2050: # 1 Space # 2 Infrastructure # 3 Investment Framework # 4 Permitting # 5 System integration. While the EU Offshore Renewable Energy Strategy will outline the enabling framework for the longer time horizon, today European countries are working on recovery packages in light of the Covid-19 crisis and the risk of economic recession. Vattenfall calls upon the European Commission to include offshore wind as a key enabler for the currently discussed green recovery, given its great potential in terms of industrial development and job creation.
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Response to A EU hydrogen strategy

8 Jun 2020

Vattenfall welcomes the opportunity to respond to the consultation of the European Commission on the “EU Hydrogen Strategy” (roadmap). Hydrogen, produced from renewable energy, decarbonised gases or fossil-free electricity can play an important role in supporting the decarbonisation of society and economy, where direct electrification is technically not possible or not feasible. The current European legislative framework does not sufficiently reflect the willingness of companies to invest into the production of renewable hydrogen and develop a hydrogen value chain as well. The EU Hydrogen Strategy and respective European legislation need to be revised accordingly and should take into account the following: • A sector integrated regulatory framework addressing the existing barriers – network tariffs, levies and taxes on electricity or accountability of RES-based electricity via the GO system – of every cross-sectoral electricity utilisation by all Power-to-Gas technologies; • Clear EU wide definitions of the various types of hydrogen produced from renewable energy (electricity and gas), decarbonised gases and fossil-free electricity and an EU wide certification scheme for hydrogen; • The introduction of policy measures for the energy intensive industry to scale-up new, industrial decarbonisation technologies in a cost efficient way; • More forward looking and acceleration of planning of permitting process for the development of electricity infrastructure; • Clarification that the existing European unbundling rules are also applicable to Power-to-Gas installations and infrastructure and ensure that the development, operation and ownership of the facilities belong to non-regulated market parties; • Ambitious and swift implementation of the RED II in national law and a non-restrictive methodology to prove additionality when deploying renewable hydrogen in the transport sector and projects financed by the EU ETS Innovation Fund and other European and national support schemes; • EU funding programme should be extended to guarantee financial support of projects scaling-up the hydrogen economy and projects to decarbonise the industrial and transport sector.
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Response to Commission Communication – "Renovation wave" initiative for the building sector

5 Jun 2020

Vattenfall shares the European Commission’s analysis regarding the relevance of the building sector, particularly the building stock, for achieving the European carbon neutrality and energy demand reduction targets as well as being an important part of the European economic recovery under and following the COVID19 pandemic. Vattenfall is continuously working on its strategic purpose to enable fossil free living within one generation. Transforming the buildings sector will both take decades and require substantial financial and human resources as well as integrated approaches and measures to be taken: • An economically, technically, and environmentally optimized individual combination of building renovation, thermal insulation and sustainable supply of the residual demand will be necessary. Though the buildings codes need to be specifically designed to the Member State’s conditions, the renovation strategy should clearly define energy efficiency measures as improvements of the building envelope (i.e. new windows, insulation etc). • The reduction of the total heat demand in the European building stock is the precondition. Focusing on urban areas, the possibilities to substantially reduce the heat demand and to increase the direct use of renewable based heating are technically and financially limited (physical constraints and age of the buildings, limited roof top areas for PV or/and solar thermal, restrictions on biomass, limitation in the power grid or limited geological conditions with regard to heat pumps etc., limited space for heating installations etc.). • Decarbonized supply of the remaining heat demand safeguards European climate neutrality. Various options for decarbonized heat supply are already available, offering the “competition of concepts”, clearly to be preferred against detailed regulatory requirements. However, to achieve the climate neutrality target both the use of mineral oils as well as of coal in the space heating should be consistently finished within uniformly defined periods in Europe. • In urban areas, prioritized climate-neutral districts concepts rather than single building approaches should be prioritised. Comprehensive data on structure and regional distribution of the building stock need to be compiled for local or regional renovation and heating concepts. In addition, medium and long-term interactions with e.g. environmental aspects (resource efficiency, improving air quality, reducing noise, traffic …) should be taken into consideration. • Renovation concepts in urban areas should primarily focus on connecting renovated buildings/districts to efficient district heating and cooling (DHC) systems. Efficient DHC systems are one of the core instruments to implement Europe climate-neutrality by 2050 for densely populated urban areas. DHC systems integrate renewable electricity via power-to-heat installations (electric boilers, large heat pumps), combined heat and power (CHP) plants (fired by natural gas, later by hydrogen or synthetic fuels), heat buffers, excess heat integration and originally renewable sources (e.g. geothermal or solar thermal). Moreover, DHC systems offer complementary flexibility and stability for the volatility of renewable electricity generation and safeguard smart integration of energy systems • Predictability of policy framework strengthens the investment climate for all deciders. The Energy Performance of Buildings Directive as of 2018, the Energy Efficiency Directive and the Renewable Energy Directive II as of 2019 have recently laid down the necessary framework. • Appropriate adjustment of state aid policies will facilitate the promotion of investments into a climate neutral building sector. Less complex criteria and short evaluation processes would be highly supportive.
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Meeting with Daniel Mes (Cabinet of Executive Vice-President Frans Timmermans), Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans) and Fortum Oyj

4 Jun 2020 · European Green Deal and recovery

Response to Strategy for smart sector integration

2 Jun 2020

Hydrogen, produced from renewable energy, and other renewable gasses can play an important role in supporting the decarbonisation of society and economy, where direct electrification is technically not possible or not feasible. The current European legislative framework does not sufficiently reflect the willingness of companies to invest into the production of renewable hydrogen and develop a hydrogen value chain as well. The upcoming EU-legislation on energy system integration should take into account the following: • More ambitious CO2 pricing: both at the EU level as part of the EU ETS and at the national level for all non-ETS sectors (in particular transport and heating); • A sector integrated regulatory framework addressing the existing barriers – network tariffs, levies and taxes on electricity or accountability of RES-based electricity via the GO system – of every cross-sectoral electricity utilisation by all Power-to-X technologies; • The introduction of policy measures for the energy intensive industry to scale-up new, industrial decarbonisation technologies in a cost efficient way; • More forward looking and acceleration of planning of permitting process for the development of electricity infrastructure; • Clarification that the existing European unbundling rules are also applicable to Power-to-X installations and infrastructure and ensure that the development, operation and ownership of the facilities belong to non-regulated market parties; • Ambitious and swift implementation of the RED II in national law and a non-restrictive methodology to prove additionality when deploying renewable hydrogen in the transport sector and projects financed by the EU ETS Innovation Fund; • Clear EU wide definitions for renewable and decarbonised gases, a new and separate definition for energy conversion and an EU wide certification scheme for hydrogen.
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Response to Revision of Alternative Fuels Infrastructure Directive

4 May 2020

E-mobility will not take off without charging infrastructure. Vattenfall therefore welcomes the initiative of the European Commission to evaluate the Directive 2014/94/EU on the deployment of Alternative Fuels Infrastructure. Vattenfall is convinced that e-mobility will play a key role to help the EU economy to reach carbon neutrality by 2050, by progressively reducing GHG emissions. Boosting the deployment of charging infrastructure is a significant component of a post-COVID 19 recovery plan, in line with the European Green Deal ambitions. Vattenfall would like to call upon the Commission, to assess the following elements in its analysis of the AFID: The need for a harmonised European policy framework for alternative fuels infrastructure. The uptake of charging infrastructures needs to go beyond the public domain.The scope of the AFID should be extended to all charging infrastructures which are accessible to the public. The effective deployment criteria have to reflect the vehicle market, demographic and geographic parameters, as well as the power required from both network and user perspective. Technological and behavioural trends also play a key role in determining the charging infrastructure needs and sufficiency. Therefore, adapted metrics and methodologies should be used to assess the right geographical coverage of infrastructure to meet the demand of EV drivers, considering among other criteria, the density of population, the increasing charging speeds, the power level of the charger and the evolution of batteries technology. The need to assess the interoperability and open standards. We believe it should be attractive and easy for citizens to switch from fossil to electrified mobility. Charging infrastructure needs to be readily available, easy to find, charge and pay.The Interoperability between us and third parties will ensure easy access anywhere in Europe. In order to roll-out a technical network between market players, connections need to be standardized, based on open protocols, available for any company. Many market-players have implemented the open protocol OCPI6. This standard is open and enables users of this standards to charge everywhere, with clear information available to this user, about location, availability and price of charging stations. As a result, roaming costs are minimized and EV drivers can get maximum benefit and access to added services. The OCPI standard reduces costs for every charge-point operator and represents an additional stimulus for the industry. To facilitate more data exchange, Vattenfall advocates for the open standards developed by Open Charge Alliance: the OCPP(for hardware communication to charge point operators) and OSCP (for roaming between charge point operator and distribution system operators). Vattenfall also promotes ISO 15118 Plug & Charge, a standard developed by the car industry. It would be a great step forward in the user experience, if authentication was automatic. However, to ensure that roaming functions smoothly, car manufacturers must decrease barriers for all (EMSP)market players to use ISO 15118. Vattenfall recommends the following policy options, to strengthen the deployment of charging infrastructures in the EU: The definition of the AFID should focus on zero emission technology, to achieve the decarbonisation of the transport sector by mid-century. We believe that the revision should prioritize the electrification of transport as the most effective, efficient and zero-emission transition pathway, compatible with the EU’s Green Deal objectives. The revision of the AFID should address the specific recharging needs of electric trucks, by introducing requirements for the deployment of charging infrastructure for electric commercial vehicles. In addition to the above specific points, Vattenfall supports the response from the different associations, of which we are members:Eurelectric, SolarPower Europe, Wind Europe and The Electromobility Platform
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Response to Climate change mitigation and adaptation taxonomy

27 Apr 2020

Please find attached Vattenfalls position on the Climate change mitigation and adaptation taxonomy.
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Response to 2030 Climate Target Plan

15 Apr 2020

Vattenfall welcomes the EU Commission´s impact assessment to analyze how to increase the EU 2030 climate target to at least -50% and towards -55% in a responsible way. - The EU should set the long-term objective of achieving a climate-neutral EU economy by 2050 at latest as well as increase the EU 2030 climate target towards -55 % as proposed by the new European Commission, while ensuring that no country or citizen is left behind. - By taking early action, the societal costs for delivering the EU’s contribution to the Paris Agreement can become more affordable, at the same time as the EU can more strongly contribute to decarbonisation globally by exporting knowledge and clean technologies. - Climate policies, such as the EU ETS regulation, need to be adjusted when climate targets are adjusted. - Electrification is a key enabler for decarbonising other sectors in the economy. Replacing fossil-fuels with clean electricity is one of the most direct, efficient, flexible and sustainable ways of reducing CO2 emissions from sectors such as transport, heating and industry.
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Meeting with Kadri Simson (Commissioner) and

15 Apr 2020 · Risk-preparedness in electricity sector, impact of crisis on clean energy investments, priorities of electricity sector for the upcoming energy initiatives under the Green Deal

Meeting with Frans Timmermans (Executive Vice-President) and Eurelectric aisbl and

15 Apr 2020 · Risk-prepardness in electricity sector, impact of crisis on clean energy investments, priorities of electricity sector for the upcoming energy initiatives under the Green Deal.

Meeting with Asa Webber (Cabinet of Commissioner Ylva Johansson)

26 Feb 2020 · Impact of regulations

Response to Climate Law

5 Feb 2020

It is time for stronger climate action and the opportunity is now • Vattenfall has the ambition of enabling fossil-free living within one generation. This has already led to significant changes in our portfolio. We are continuously moving out of CO2 heavy production assets, while investing largely in renewable energy and low carbon technologies. At the same time, we recognise that it will not be enough just to make the energy sector CO2-neutral. For that reason, we have entered a number of strategic partnerships to support the decarbonisation of other major CO2 emitting sectors, such as industry and transport, primarily though electrification. In this endeavor we need EU climate targets which are made fully consistent with the goals of the Paris Agreement, as well as a robust regulatory framework which guides the whole energy sector in the same direction. • We welcome the EU Commission´s initiative to enshrine the EU objective of climate neutrality by 2050 in legislation and to set the long-term direction of travel for meeting the 2050 climate-neutrality objective through all policies, in a socially-fair and cost-efficient manner. • It is important to agree on ambitious target for 2030 as fast as possible. A target for 2040 will also be needed. By taking early action, the societal costs for delivering the EU’s contribution to the Paris Agreement can become more affordable, at the same time as the EU can more strongly contribute to decarbonisation globally by exporting knowledge and clean technologies. Early action also creates more visibility for business on the GHG emission reductions which are required, and caters for a cost-efficient transition path of decarbonising the EU’s energy system. • Climate policies always need to be adjusted when climate targets are adjusted to make sure policies are designed to meet the target. • The EU’s Emissions Trading System (EU ETS) should be further strengthened. The LRF should be adjusted in the EU ETS Directive as soon as possible after the adoption of a more ambitious EU 2030 climate target. An early adaption will create more predictability and a more cost-efficient reduction pathway. The review of the Market Stability Reserve (MSR) to be conducted by 2021 should lead to a continuation of the 24 % annual intake rate into the reserve. • Electrification is key for reaching the climate targets. Negative emissions will also be needed. Replacing fossil fuels with clean electricity will be an increasingly important tool for reducing CO2 emissions within transport, heating and industry sectors. Electrification is the most direct, efficient, flexible and sustainable way to decarbonise the economy, while also bringing significant co-benefits such as better air quality in urban areas, lower import dependency and higher energy-efficiency. • District Heating and Cooling (DHC) can provide necessary flexibility to ensure the stability of the grids and security of supply and enable smart sector integration by smartly combining power-to-heat (electric boilers, large heat pumps etc.), CHP plants, heat storage, use of waste heat from industrial and tertiary sources and utilisation of renewable sources. • A global carbon market instrument, governed by the Paris Agreement, may stimulate GHG emissions reduction measures in countries and sectors which would otherwise not have occurred. The new global mechanisms should result in a net-mitigation of global GHG emissions, which is an improvement compared to the Kyoto Protocol. • A decision on introducing verified global credits in the EU ETS market, as a compliance tool, should only be considered in the context of sharpening the EU’s climate targets. It is absolutely essential that the EU-internal transformation pressure is maintained for achieving the EU decarbonisation goals and ensuring a strong and effective CO2 pricing signal from the EU ETS policy.
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Meeting with Mauro Raffaele Petriccione (Director-General Climate Action) and Fortum Oyj and Statkraft AS

7 Nov 2019 · European Green Deal

Meeting with Miguel Arias Cañete (Commissioner) and Fortum Oyj and Statkraft AS

27 Nov 2018 · EU climate and energy policies

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

15 Nov 2017 · Energy Union

Meeting with Jos Delbeke (Director-General Climate Action)

19 Apr 2017 · ETS

Meeting with Miguel Arias Cañete (Commissioner) and ENGIE and

7 Feb 2017 · Decarbonization of Transport electric-vehicules

Meeting with Maria Asenius (Cabinet of Vice-President Cecilia Malmström)

3 Oct 2016 · Information on timeline case Vattenfall against Germany

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

13 Oct 2015 · Renewable energy policy

Meeting with Miguel Arias Cañete (Commissioner) and

23 Jun 2015 · Internal Electricity Market

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

8 Apr 2015 · Markets in Financial Instruments Directive

Meeting with Miguel Arias Cañete (Commissioner) and

8 Apr 2015 · Financial Market legislation

Meeting with Miguel Arias Cañete (Commissioner) and

4 Dec 2014 · EU Energy Policy, 2030 Framework internal Energy Market, 315b eur investemnt package