Veolia Environnement
Veolia
Veolia designs and deploys solutions for water, waste, and energy management.
Lobbying Activity
Meeting with Valérie Hayer (Member of the European Parliament) and Amazon Europe Core SARL and
28 Jan 2026 · Politique commerciale de l'UE
Meeting with Anna Nykiel-mateo (Cabinet of Executive Vice-President Stéphane Séjourné) and Xylem Inc. and Grundfos A/S
15 Jan 2026 · UPFAS restriction and water filtration technologies
Meeting with Vita Jukne (Cabinet of Commissioner Jessika Roswall) and Danfoss A/S and
13 Jan 2026 · Impact of Per- and polyfluoroalkyl substances (PFAS) restriction on Water Technologies
Meeting with Thomas Pellerin-Carlin (Member of the European Parliament)
8 Dec 2025 · Plastic recycling
Veolia calls for removing redundant climate adaptation criteria
4 Dec 2025
Meeting with Susana Solís Pérez (Member of the European Parliament)
6 Nov 2025 · Circular Economy Act
Veolia calls for EU funds to digitalize energy networks
5 Nov 2025
Message — Veolia proposes mandating data center waste heat recovery and creating a dedicated European fund for digitalizing aging energy networks. They also suggest harmonizing data sharing regulations and establishing interoperability standards for energy equipment.123
Why — Veolia would secure substantial public subsidies for its digital infrastructure and new regulatory credits for its AI solutions.45
Impact — Foreign technology firms would be disadvantaged by proposed rules favoring European-developed AI in public contracts.6
Veolia urges expanded recycled content targets and financial incentives for circular materials
5 Nov 2025
Topic — EU act to boost circular economy, enhance competitiveness and increase recycled material supply.
Message — Veolia calls for expanding recycled content obligations to new sectors including vehicles, textiles, household appliances, agriculture and construction. They seek financial instruments like reduced VAT, EPR bonuses and a virgin plastics tax to level the playing field. They want stricter import rules allowing only EU/OECD recyclates to count toward obligations.123
Why — This would create guaranteed demand for their recycled materials and reduce competition from cheaper virgin and imported alternatives.456
Meeting with César Luena (Member of the European Parliament)
3 Nov 2025 · PFAS and Plastics recycling
Meeting with Ewa Malz (Head of Unit Environment)
16 Oct 2025 · Omnibus
Veolia urges regulatory stability to protect consumers during heating network transformation
9 Oct 2025
Topic — EU strategy on decarbonizing heating and cooling sector through renewable energy and efficiency.
Message — Veolia requests regulatory stability, extended implementation periods for new standards, and increased EU funding to reduce transformation costs for consumers. They advocate for technology-neutral approaches that allow Member States to choose heating sources based on local conditions, including waste heat, geothermal, and biomass.1234
Response to Roadmap towards Nature Credits
30 Sept 2025
Please find attached Veolia's contribution to the European Commission's consultation on the Roadmap towards Nature Credits. Our key recommendations are: 1° Establish a high-integrity, science-based EU system compatible with existing legislation, with clear eligibility criteria, ecosystem-specific methodologies, and safeguards against reversals and double counting. 2° Certify both ecosystem restoration and the maintenance of high-quality habitats, with a focus on preserving aquatic environments by integrating soil and water quality improvements into certification criteria. 3° Promote advanced, scientifically validated monitoring methods (e.g., bioassays, biosensors, bioacoustics, bioindicators) alongside conventional approaches. 4° Integrate biodiversity performance criteria into public procurement processes to stimulate demand for certified nature-positive actions. 5° Allow voluntary inclusion of certified nature-positive actions in corporate reporting disclosures. 6° Ensure the certification process is practical for local authorities, SMEs, farmers, and communities, and aligned with global initiatives.
Read full responseMeeting with César Luena (Member of the European Parliament)
22 Sept 2025 · Plastic policies and PFAS
Meeting with Kathleen Van Brempt (Member of the European Parliament)
15 Sept 2025 · Energy policy
Meeting with Stéphane Séjourné (Executive Vice-President) and
8 Sept 2025 · - Compétitivité des entreprises - Marché intérieur - Protection de la souveraineté et du pouvoir d’achat - PFAS - Santé publique
Veolia urges unified EU climate standards and procurement reforms
4 Sept 2025
Topic — The initiative seeks an integrated framework for European climate resilience and risk management.
Message — Veolia advocates for unified EU climate reference scenarios to replace the current fragmented national models. They propose a standard four-step methodology for risk assessments and want climate adaptation criteria to be mandatory in public procurement.123
Why — Standardized rules would reduce planning costs and boost their competitive edge in tenders.4
Impact — Firms offering the lowest prices will lose their advantage as tenders prioritize climate resilience.5
Veolia Urges Stronger Traceability to Protect Mechanical Plastic Recycling
18 Aug 2025
Message — Veolia requests legal priority for mechanical recycling based on environmental impact. They demand physical traceability to ensure consumers receive credible recycled content information.12
Why — This would protect Veolia's mechanical recycling investments from unfair competition and market volatility.34
Impact — Consumers face a high risk of greenwashing through misleading allegations about plastic circularity.5
Meeting with Jan Ceyssens (Cabinet of Commissioner Jessika Roswall) and TotalEnergies SE and
22 Jul 2025 · EU environmental policies
Meeting with Arthur Corbin (Cabinet of Executive Vice-President Stéphane Séjourné) and TotalEnergies SE and
10 Jul 2025 · Clean industrial deal Financement Simplification
Veolia Urges Green Standards and European Digital Sovereignty
3 Jul 2025
Message — Veolia seeks support for European champions and enforcement of fair commercial practices. They propose energy and water efficiency standards for data center infrastructure.12
Why — Harmonised standards would reduce operational costs and strengthen Veolia's digital infrastructure resilience.345
Impact — Dominant tech firms lose the ability to bundle products and restrict market entry.6
Meeting with Manuel Mateo Goyet (Acting Head of Unit Communications Networks, Content and Technology) and OVH Groupe and
3 Jul 2025 · Exchange on cloud policies
Meeting with Stéphane Séjourné (Executive Vice-President) and
2 Jul 2025 · EU Clean Industrial Dialogue on Circularity
Meeting with Henning Ehrenstein (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)
20 Jun 2025 · Public procurement framework
Meeting with Felix Fernandez-Shaw (Director Directorate-General for International Partnerships) and Airbus and
12 Jun 2025 · High-level Roundtable on Colombian energy sector with exchange of views between Minister of Mines and Energy, IFIs and EU companies.
Meeting with Arthur Corbin (Cabinet of Executive Vice-President Stéphane Séjourné), Laia Pinos Mataro (Cabinet of Executive Vice-President Stéphane Séjourné) and
12 Jun 2025 · Challenges and opportunities in Europe’s Water Sector
Veolia urges EU to prioritize European cloud and AI
3 Jun 2025
Message — Veolia requests a framework that prioritizes European infrastructure to ensure digital independence. They advocate for procurement policies that favor local providers and support European startups.12
Why — Stronger European digital autonomy would protect Veolia's critical infrastructure and sensitive data.3
Impact — Foreign software companies could lose market share if Europe adopts local preference policies.4
Meeting with Anne-Maud Orlinski (Cabinet of Commissioner Dan Jørgensen) and SUEZ Group and
28 May 2025 · Water Resilience Strategy Water Energy Efficiency Solutions
Meeting with Ruth Reichstein (Cabinet of President Ursula von der Leyen) and SUEZ Group and
27 May 2025 · The EU Water Resilience Strategy
Meeting with Ruth Reichstein (Cabinet of President Ursula von der Leyen) and SUEZ Group and
27 May 2025 · to follow
Meeting with Hildegard Bentele (Member of the European Parliament)
8 May 2025 · EU Water Policy
Meeting with Wopke Hoekstra (Commissioner) and
24 Apr 2025 · Site visit at Veolia site: wastewater management project
Meeting with Pernille Weiss-Ehler (Cabinet of Commissioner Jessika Roswall)
14 Apr 2025 · Water Resilience Strategy
Meeting with Sirpa Pietikäinen (Member of the European Parliament)
8 Apr 2025 · End-of-life vehicles
Meeting with Pernille Weiss-Ehler (Cabinet of Commissioner Jessika Roswall) and SUEZ Group and
27 Mar 2025 · Meeting with Digital Water Coalition on Water Resilience Strategy
Meeting with Veronica Manfredi (Director Environment) and Association of Water Companies, Slovakia
26 Mar 2025 · Exchange on competitive European Water Resilience
Meeting with Teresa Ribera Rodríguez (Executive Vice-President) and
25 Mar 2025 · EU ecological transformation and competitiveness
Meeting with Dan Jørgensen (Commissioner) and
25 Mar 2025 · Heating and cooling
Meeting with Alexandre Adam (Cabinet of President Ursula von der Leyen)
24 Mar 2025 · Challenges and opportunities in the energy and water management industry in the context European Climate change adaptation plan
Meeting with Wioletta Dunin-Majewska (Cabinet of Commissioner Dan Jørgensen)
18 Mar 2025 · - EU heating and cooling strategy and the geothermal action plan
Meeting with Lukasz Kolinski (Director Energy) and Innargi A/S
18 Mar 2025 · Development of large-scale geothermal energy projects for district heating in Poland
Meeting with Pierre Jouvet (Member of the European Parliament, Shadow rapporteur) and PETITA I MITJANA EMPRESA DE CATALUNYA
14 Mar 2025 · marchés publics
Veolia Urges Shift From Price to Sustainable Public Procurement
7 Mar 2025
Message — Public authorities should shift away from a mainly price-driven public procurement approach. Criteria must be standardized and aligned with European policies on water and waste. Public authorities should keep in-house service provision within its limits.123
Why — This would boost the demand for Veolia's services and improve the operator's financial security.45
Impact — Providers of established solutions that benefit from economies of scale would lose their advantage.6
Meeting with Luis Planas Herrera (Cabinet of Commissioner Jessika Roswall)
5 Mar 2025 · Clean Industrial Deal and Circular Economy Act
Meeting with Piotr Müller (Member of the European Parliament, Rapporteur) and Confederation of European Security Services
5 Mar 2025 · Evaluation of the Public Procurement Directives
Meeting with Claudia Olazabal (Head of Unit Environment) and Siemens AG and
25 Feb 2025 · Exchange of views on digitalisation in the water sector
Meeting with Alexandr Vondra (Member of the European Parliament, Shadow rapporteur)
19 Feb 2025 · End of life vehicles regulation
Meeting with Gaelle Marion (Head of Unit Agriculture and Rural Development) and SUEZ Group and
19 Feb 2025 · Water Resilience Strategy and Agriculture
Veolia urges EU to fast-track water infrastructure permits
18 Feb 2025
Message — Veolia requests faster permitting for water infrastructure and sector-specific efficiency standards for major users. They also support a digitalized, pan-European system for tracking water usage and resources.123
Why — Fast-tracked approvals and dedicated EU funding would lower their operational risks and boost revenue.45
Meeting with Grégory Allione (Member of the European Parliament, Shadow rapporteur)
12 Feb 2025 · Réunion Veolia
Meeting with Thomas Bajada (Member of the European Parliament, Rapporteur)
24 Jan 2025 · Meeting on Water Resilience Strategy
Meeting with Andreas Glück (Member of the European Parliament) and FORVIA
15 Jan 2025 · ELVR
Meeting with Javi López (Member of the European Parliament)
2 Dec 2024 · Green transition
Meeting with Hildegard Bentele (Member of the European Parliament)
2 Dec 2024 · Energy, Water and Waste Policy
Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs) and Orange and
8 Oct 2024 · General discussion on Taxonomy and CSRD deployment.
Meeting with Nicolás González Casares (Member of the European Parliament) and European Environmental Bureau and
25 Sept 2024 · Energy transition
Meeting with Mairead McGuinness (Commissioner) and Orange and
26 Jun 2024 · Sustainability policies, in particular CSRD, Taxonomy
Meeting with Daniel Mes (Cabinet of Commissioner Wopke Hoekstra)
19 Feb 2024 · Energy priorities towards 2040
Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs)
25 Jan 2024 · To take stock of strategic files
Meeting with Kurt Vandenberghe (Director-General Climate Action)
25 Jan 2024 · Recognition of avoided emissions, climate change adaptation and mitigation as well as the outcome of COP28
Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans)
29 Jun 2023 · European Green Deal implementation and next steps
Meeting with Cristian-Silviu Buşoi (Member of the European Parliament) and Business Bridge Europe and Norsk Hydro
6 Jun 2023 · speaker at the 3rd European Energreendeal Conference
Veolia seeks optional spending reports and wider water reuse rules
3 May 2023
Topic — Defining which economic activities qualify as environmentally sustainable under new EU rules.
Message — Veolia requests making operational spending reports optional to reduce the reporting burden. They also want the classification system to include recycled industrial and drinking water.12
Response to Carbon Removal Certification
21 Mar 2023
We welcome the European Commissions proposal for a Carbon Removal Certification Framework (CRCF) put forward in November last year with the aim to develop a trustworthy system to quantify and valorise removals and achieve climate neutrality by 2050. The proposal outlines the start of a process that is much needed for this essential sector. There is way too much fragmentation in voluntary space regarding carbon certification and having a scheme developed at the EU level will provide greater certainty, transparency, and clarity for the industry. It is also a chance for the EU to set the standard and lead the way in establishing a world-leading carbon removal certification framework that could be used as a blueprint across the world. However, taken as it is, the proposal requires further improvements to ensure that the QU.A.L.ITY criteria it includes produce reliable and high quality net removals. You can find some concrete elements we would like the Commission to focus on in the attached document.
Read full responseMeeting with Delara Burkhardt (Member of the European Parliament, Shadow rapporteur) and Tetra Pak Group and
21 Mar 2023 · Packaging Waste
Meeting with Deirdre Clune (Member of the European Parliament, Shadow rapporteur) and ECOLAB and
7 Feb 2023 · Urban Waste Water Treatment Directive
Veolia Urges Stricter Wastewater Standards and National Reuse Plans
21 Dec 2022
Message — Veolia supports mandatory quaternary treatment for micropollutants and stricter nutrient limits. They call for national water reuse agendas and more flexible storm overflow targets.123
Why — Higher treatment standards create significant commercial opportunities for Veolia's water management technologies.4
Impact — Pharmaceutical and cosmetic manufacturers will bear the costs of managing micropollutant pollution.5
Meeting with Pascal Canfin (Member of the European Parliament)
28 Nov 2022 · Green Deal
Response to European Critical Raw Materials Act
25 Nov 2022
Please find attached Veolia's input to the call for evidence on the European Critical Raw Materials Act.
Read full responseMeeting with Antoine Colombani (Cabinet of Executive Vice-President Frans Timmermans) and TotalEnergies SE and
25 Oct 2022 · Green Deal state of play
Meeting with Pascal Canfin (Member of the European Parliament) and Skeleton Technologies OÜ
11 Oct 2022 · Green Deal
Meeting with Frans Timmermans (Executive Vice-President)
11 Oct 2022 · Implementation of the European Green Deal and Veolia’s contribution, with focus on biomethane, water reuse and recycling
Meeting with Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans) and SUEZ Group and
5 Jul 2022 · Urban wastewater treatment (Zero Pollution)
Meeting with Arunas Ribokas (Cabinet of Commissioner Virginijus Sinkevičius) and SUEZ Group and
5 Jul 2022 · To discuss the review of the Urban Waste Water Treatment Directive
Veolia backs industrial emission rules while seeking ETS exemptions
23 Jun 2022
Message — Veolia supports new definitions for circularity but urges excluding carbon-priced installations from greenhouse gas rules. They also argue that the strictest emission limits must consider local contexts and cross-media effects.12
Why — Avoiding double regulation would reduce administrative costs and streamline compliance for their plants.3
Impact — Local communities might face weaker local oversight if greenhouse gases are excluded.4
Veolia warns EU carbon reuse ban threatens fuel investments
17 Jun 2022
Topic — Consultation on the methodology for assessing greenhouse gas savings from renewable transport fuels.
Message — Veolia requests the removal of the 2035 time limit on reusing industrial emissions for fuel production. They seek clearer definitions for sustainable carbon and protection for existing investment projects.12
Why — Removing the deadline protects long-term investments in industrial-scale carbon capture and reuse facilities.3
Impact — The energy transition loses momentum, harming progress toward EU climate goals.4
Veolia backs nutrient recovery from wastewater for circular agriculture
25 Apr 2022
Message — Veolia proposes recovering nutrients from urban wastewater to create a circular economy. They call for updating the Sewage Sludge Directive to better manage pollution risks.12
Why — Mandated nutrient recovery creates significant business opportunities for Veolia's water treatment services.3
Impact — Non-EU mineral fertilizer exporters lose market share to local recycled nutrient sources.4
Meeting with Antoine Colombani (Cabinet of Executive Vice-President Frans Timmermans) and Kreab Worldwide
5 Apr 2022 · Sustainable Finance
Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU
31 Mar 2022
We welcome the recast of the Energy Performance of Buildings Directive (EPBD), which should focus on the effective reduction of the energy consumption of the European building stock. In reaction to this recast, we would like to emphasize the following guiding principles that can be translated into concrete amendments of the text.
- Promote energy management solutions as a complement to renovations
The revision of the EPBD is an opportunity to introduce several instruments which focus on improving buildings’ energy performance through renovation actions: these new ambitious standards should also promote a dynamic approach to building’s energy performance and require relevant projects to be carried under an EnPC or at least ensure monitoring of energy performance. Indeed, a high-performance renovation can only be truly efficient if it allows to keep energy performance over time, through proactive energy management.
- Provide an adequate framework for district heating networks in the process of decarbonising and modernizing the building stock
According to the ‘Energy Efficiency First’ principle, the implementation of energy efficiency measures should be considered prior to any fuel switching. Hence, we welcome the calendar provided for the definition of deep renovation to transform first buildings into nearly zero-energy buildings, then into zero-emission buildings by 2030. In this process, it is essential to ensure a non-discriminatory treatment between on-site and nearby renewable energy. The definition of zero-emission building heads in the right direction but we propose to clarify the definition so that a building with a very low amount of energy consumption could be considered as a zero-emission one as soon as it is connected to an efficient DHC network (conform with the definition in the EED directive). Similarly, the definition of “nearby renewable energy” should be adjusted as referring to efficient DHN. In addition, the decarbonization of buildings should be inscribed in broader decarbonization plans addressing entire neighborhoods and districts, automatically linking renovations with decarbonization actions that are part of local energy planning, especially when it comes to heating and cooling - with due consultation of DHN operators.
- Address air quality in the EU building stock
The revision of the EU Energy Performance of Buildings Directive (EPBD) comes at a moment of accelerating efforts to reduce emissions from all polluting sectors, including buildings. However, there are real concerns about the healthiness of built environments, especially in the context of lockdowns imposed as part of the COVID-19 response. While reducing energy consumption of buildings is certainly an important goal, the current EU approach lacks focus on the need to improve buildings in the inside, both homes and workplaces, to ensure better Indoor Air Quality (IAQ) and health outcomes. While we are setting standards for buildings that will get us to 2050 zero net target, we should also prepare them for future respiratory threats. That means transforming our current building stock into net zero buildings that will also be healthy buildings.
The EPBD is one of those EU norms that requires policy coherence across sectors, from jobs to sustainability to health and climate action. For this reason, we propose a series of improvements of the current text to tackle this aspect that has been so far gravely overlooked in successive EPBD revisions.
In the file attached, concrete amendments to the current text proposal are being put forward to help better integrate the above mentioned aspects.
Read full responseResponse to Soil Health Law – protecting, sustainably managing and restoring EU soils
15 Mar 2022
Veolia welcomes the initiative to give the EU a comprehensive and coherent policy framework to achieve healthy soils. In addition to targets on the restoration of our soils, it is vital to provide soil quality standards, harmonised monitoring and reporting requirements, and means to reach the goals set in the Zero Pollution Action Plan.
A first area of action should be to agree at EU level on robust and harmonised indicators for soil health, allowing for their precise monitoring and evolution. The considered indicators should also be cost-effective and appropriate to farm-level investigation.
The Soil Health Law should also aim at protecting drinking water resources by improving groundwater and surface water quality and quantity, and thereby contribute to reaching the goals of the Water Framework Directive. Finally, there should be legislative support to practices contributing to carbon removal.
As such, we support greater coordination of soil and water management, by:
- Enhancing and protecting the organic content of soils is paramount. For example, an harmonised indicator on Soil Organic Matter (SOM) could prove very useful, as SOM improves soil nutrient retention and reduces the potential for soil erosion.
- It would also be useful to add an indicator for land take, as well as an indicator on the impact of biodegradable plastics as they might pose a threat to both recycling and composting processes.
- Maintaining the importance of soil management for rural areas and agriculture. Soil quality can be improved by using available organic matter. For this, it is necessary to privilege first, when possible, the direct return to the ground or in a short circuit (compost) of organic matter such as sewage sludge but also of bio-waste. Economic drivers and incentives must be implemented to enable the production and use of safe fertilizers and soil improvers from the circular economy. This implies more investment in collection as well as economic instruments (such as tax rebates or subsidies) making it viable for local authorities and farmers to use the final product contributing to a circular economy and Europe's progressive autonomy in terms of fertilisers.
Finally, progress is needed in identifying and remediating contaminated sites. We welcome the Commission’s proposition for Member States to establish an inventory of contaminated sites. The identification of contaminated sites, and their remediation needs a proactive approach. For Soil decontamination, where the contamination is such that it cannot be fully remediated, enabling the use of the site for tertiary purposes is possible with adapted soil quality targets (Germany has a proven practice which may inspire the EU). Furthermore, the financial risks pertaining to purchasing contaminated land (liability for pre-existing contamination), could be partially alleviated by setting up structures leasing brownfield lands.
Read full responseResponse to Waste Framework review to reduce waste and the environmental impact of waste management
22 Feb 2022
Please find attached VEOLIA's feedback on the revision of the EU framework Directive.
Read full responseMeeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness)
9 Feb 2022 · Sustainable Finance, Taxonomy
18 Jan 2022
Draft Regulation on recycled plastic materials and articles intended to come into contact with foods
VEOLIA welcomes the revision of Regulation 282/2008.
VEOLIA supports the general idea behind the revision of Regulation 282/2008, i.e. the importance of producing recycled plastics for food contact in accordance with the requirements set out in Regulation 10/2011.
However, we seek clarification on some of the requirements. Please find our comments and proposals in the attached document.
Should you need more information, please do not hesitate to contact us.
Read full responseResponse to Measures to reduce microplastic pollution
17 Jan 2022
Veolia supports the goal of reducing microplastics released into the environment by 30% by 2030, and the list of envisaged measures. Owing to the state of play, two main and pressing actions are needed in parallel: pollution prevention as close as possible to the sources of microplastics, and the standardization of analytical methods to ensure data comparability.
The most urgent need is the adoption at the EU level of standardised sampling and analytical methods (including interlaboratory exercises to ensure consistency of results), as soon as possible, and when possible too, Environmental Quality Standards, as basis for accurate risk management action under various EU instruments (IED, UWWTD etc.) including removal of microplastics from surface runoffs and sewage where needed.
Preventing pollution at-source is paramount, and especially advisable when there is evidence of environmental damage although scientific elements are still missing for a straightforward quantitative risk analysis. Veolia is convinced that clean manufacturing must be boosted by ecodesign requirements, including industrial wastewater treatment standards limiting the release of microplastic during the production, distribution and throughout the lifecycle of the products. This is where the pre-washing of clothes must be envisaged in priority. For such measures to deliver against expectations, it is of paramount importance that the requirements are applied both to goods manufactured within and outside the EU territory. New Extended Producer Responsibility schemes may complete the setting to ensure that the whole value chain is addressed. The other merit is that the polluter-pays principle is fundamental to curtail pollution in all domains including microplastics.
When microplastics from tyres are dispersed on road surfaces, green infrastructure and other stormwater management facilities are an option to be considered, in priority to limit leaching into water courses, provided the sediments/filters from these facilities are duly dealt with. For urban runoffs, the issue must be tackled in the framework of the ongoing revision of the Urban Waste Water Treatment Directive.
Water treatment plants generally remove between 80 and 99% of microplastics discharged in urban wastewaters. Further treatment is possible but would need to be warranted for specific challenges (evidence leading to Environmental Quality Standards, or biodiversity hot-spots, and more generally sensitive areas), whilst also ensuring that the impacts on the sludge disposal route(s) are duly assessed.
Read full responseResponse to Review of Directive 2012/27/EU on energy efficiency
19 Nov 2021
Veolia welcomes the European Commission’s proposal to revise the Energy Efficiency Directive (EED). Together with other proposed initiatives within the Fit-for-55 Package, the new EED can contribute to achieve the greenhouse gas emissions reduction target of 55% by 2030, while consolidating the EU’s role as a global leader in energy efficiency and the overall energy transition.
Taking into account our experience in the field of energy transition and drawing on our expertise of managing transition plans in the water, waste and energy fields, we want to propose the following recommendations for the European policymakers who will shape the final version of the EED.
Setting ambitious targets for a rapid transition towards carbon neutrality also necessitates a strong support environment. It is paramount that for higher ambition at both EU and national levels that appropriate regulatory and financial schemes are mobilised. That also means the need for stability of support schemes and their underlying criteria. To ensure investments in energy efficiency with long term impact the EED should mirror Article 6 in REDII on stability of financial support. This would establish a predictable framework and define precise conditions for introducing, amending and cancelling support for energy efficiency measures.
We welcome Energy Efficiency First as a guiding principle of the Union’s energy policy and its formal introduction as an article in the EED (article 3), providing the legal basis for its application.
It will be of utmost importance to ensure implementation of this principle along the whole energy chain. In that regard, we are glad to note that the overall EU energy efficiency target is expressed both in the final and primary energy, which will contribute to greater system efficiency. The effective implementation of the EEF principle should help speed up decarbonisation of the heating sector. In the attached paper we propose a series of modifications, regarding in particular articles 8 and 24, that would contribute towards this objective. Similarly, amendments to article 25 indicate how energy efficiency first principle can be used to guide optimisation of the energy transformation, transmission and distribution of electricity.
The same EEF principle should also be applied to foster solutions that will profoundly affect reduction of CO2 emissions of the European building stock. Our views of the EED proposal stem from the perspective of Veolia as an ESCO - that is a provider of energy management solutions, such as Energy performance contracts (EnPC). Those solutions play a key role in ensuring that energy performance is improved, monitored and maintained over time. This applies to all types of installations and buildings we manage - in the public and industrial sectors. We propose important changes to articles 2(14) (definition of the energy management system), 6, 11, and 27 so that to better take into account multiple benefits of energy performance contracts.
We are glad to see that the proposal already positions District Heating Networks as key players in the decarbonisation of the EU heating and cooling sector, in line with the Renewable Energy Directive (RED) proposal and other recent Commission communications. THE EED can become a genuine vector of transforming heating and cooling sector provided it defines the right conditions for deployment of efficient district heating and cooling systems as well as of efficient cogeneration. This is why we propose concrete adjustments to articles article 2(10), 5, 20, 23, 24 and Annex III.
For more details on these suggestions, please refer to the document attached.
Read full responseResponse to Revision of the Energy Tax Directive
18 Nov 2021
We welcome the opportunity to comment on the Commission proposal to revise the Energy Taxation Directive. By focusing on environmental performance of energy products as well as the implementation of the polluter-pays principle, the revised ETD will effectively incentivise energy efficiency and decarbonisation efforts. Having said that, we also want to suggest some important modifications to the proposal to enable better coherence with other pieces of the “Fit for 55” package and enable progressive transition towards climate neutrality.
Energy efficiency measures are a prerequisite to any fuel switch and are key to optimizing any heating installation, whether using renewable energy sources or not. This is why applying the “energy efficiency first” principle, in line with the revised Energy Efficiency Directive, means the need to promote the most efficient utilisation of energy products via high efficiency cogeneration. To ensure energy efficiency is prioritised, the full amount of energy products used in high efficiency cogeneration to produce both heat and electricity should be equally exempted.
Additionally, the provision on the possibility for Member States to apply taxation that is lower than the proposed minima for energy products and electricity used in combined heat and electricity production should be upheld (Art. 17a). Likewise, tax reductions for households should be designed in such a way so as to support energy efficiency actions that reduce energy bills.
The revised ETD should also enable accelerating decarbonisation of the heating and cooling sector by guaranteeing a preferential treatment of biomass and biogas, district heating and accurately reflecting the impact of electricity use for the heating purposes.
Indeed, sustainable biomass fuels are the most affordable and common replacement of the most polluting fossil fuels in the heating sector. These solutions are cost-competitive, market-ready, and easy to scale up. To offset the prospective rise of prices in the heating sector, the use of sustainable bioenergy fuels should be promoted and incentivised. Setting a minimum flat tax rate on sustainable biomass would significantly slow down the transition from fossil fuels and lead to unnecessarily high costs for end users.
Regarding biogas, the proposed taxation system leads to the creation of four categories of biogas: non-sustainable biogas, sustainable biogas produced from food and feed crops, sustainable biogas, and advanced sustainable biogas. This system should be simplified, to keep the main categories of sustainable and non-sustainable biogas and apply the adequate tax rates to those categories. It is therefore crucial that sustainable biomass fuels (including sustainable biogas) are excluded from the scope of the proposed legal act;
Also, in order to avoid disproportionate impact in terms of increased heat prices for final consumers, we propose to introduce a transitional period to allow district heating companies located in transitional countries to benefit from reductions in the level of taxation, which shall not go below the minima, for installations covered by the EU ETS, provided for in Article 17 of the Energy Directive, until 2030;
Although we understand the need for electrifying as many sectors as possible in order to accelerate the decarbonisation (including in the heating sector), the revised directive should allow for a minimum taxation rate only for electricity produced from renewable energy sources.
Finally, maintaining a favorable framework for the promotion of renewable fuels of non-biological origin will also be essential as they will play a major role in decarbonising the transport industry. We encourage the Commission to develop guidance for EU countries to detail how they can apply exemptions or reductions in the level of taxation in general for RFNBOs as this is a new field and a new market for them. For more details on these suggestions, please refer to the file attached.
Read full responseResponse to Revision of the Renewable Energy Directive (EU) 2018/2001
18 Nov 2021
We welcome the opportunity to comment on the Commission proposal to revise the Renewable Energy Directive.Taking into account our experience in the field of energy transition and drawing on our expertise of managing transition plans in the water, waste and energy fields, we want to propose the following recommendations for the European policymakers who will shape the final version of REDIII.
The increase of the overall EU objective from 32% to 40% share of renewable energy in the EU’s gross final consumption of energy is particularly important as well as new targets and objectives in the heating and cooling, industry and production of renewable fuels of non-biological origins (RFNBO) sectors. Yet, all those ambitious targets must be accompanied by supportive and enabling measures to ensure the availability and affordability of renewable energy sources for the consumers needing them. The existing provisions on regulatory stability must be maintained.
Encouraging more ambitious RES targets also requires greater emphasis on energy efficiency. Hence, high efficiency cogeneration (CHP) should be prioritised for the use of thermal renewable energy sources. In addition, the “Energy Efficiency First” principle should be better recognised a by a greater focus given to Energy Performance Contracts (EnPCs). Waste heat recovery, an energy efficiency measure, should also be counted towards RES objectives in the buildings and industry sectors. Last but not least, the concept of renewable energy communities should integrate the principle of energy efficiency first so that investments in renewables are always coupled with efforts to reduce consumption first, and optimise the renewable and low carbon energy supply.
The revised RED should also be contributing to fostering development of efficient and low-carbon district heating systems. The proposal already contains great measures to enable district heating to become the backbone of local energy transition but it could be enhanced to guarantee: non-discriminatory treatment between on-site and nearby renewables, that district energy systems having a plan to become efficient DHN according to the EED definition can also contribute to the objective of this article; renewable electricity and gas used for heat production should also be included in the target of article 23 as well as better frame conditions of third party access to district heating networks.
Favorable legal framework for the responsible use of sustainable biomass in the heating and cooling sector, including from the waste sources, is a necessary condition for investment certainty. The Commission’s proposal generally sets the right direction. However, certain aspects regarding the reinforcement of the biomass sustainability criteria could have a negative impact on the ability to use biomass as a heat source, increase the administrative burden for small operators, and disrupt the operation of existing plants. In that regards, we are not favorable to a delegated act on the cascading principle for the use of biomass, retroactive application of measures, including on the GHG savings criteria, the exemption threshold for biomass lowered to 5 MW, and specifics of sustainable forest management to be covered by European energy legislation. In addition, high efficiency cogeneration should remain a key sustainability criterion for biomass use, as well as additional precisions should be made regarding the application of GHG criteria to biomass from waste streams and for recycled wood.
Finally, developing a roadmap and adequate tools for the uptake of low-carbon gases is also a priority identified by our group. For more details on these suggestions, please refer to the document attached.
Read full responseResponse to Updating the EU Emissions Trading System
8 Nov 2021
We welcome the opportunity to comment on the Commission proposal to revise thoroughly the European Emission Trading System. The European ambition of -55% of CO2 emissions by 2030 and carbon neutrality by 2050 requires a strong and efficient system. For Veolia, these objectives have to be completed with the following points to ensure the system remains effective and fosters a transition to a more low carbon and circular economy.
1) A reformed EU ETS to match the overall EU climate ambitions is essential - We welcome the proposals of the Commission both to increase the overall ambition of emissions reductions to be achieved by the EU ETS sectors (from the current -43% to 61% emissions reduction by 2030 for sectors covered by the ETS compared to 2005) as well as instruments that are being put forward to achieve this result.
2) A uniform carbon pricing across the entire heating market is necessary for the successful decarbonisation of the building sector - An adequate carbon price is needed across different sectors to ensure a genuine level playing field and harmonious and fair process of decarbonisation. It is especially relevant in the heating market, given the current fuel mix and challenges of shifting towards low-carbon alternatives in this sector. In particular, in the heating and cooling sector, there is a need for a uniform CO2 pricing signal to make sure solutions that provide numerous positive externalities such as DHC, can compete on equal footing with individual heating solutions. In this sense, the proposal to extend the scope of the EU ETS to the building and transport sectors is welcomed by operators like Veolia, provided that some basic conditions are being met. In that regard, we reiterate that it is absolutely crucial that the carbon pricing introduced through EU ETS2 should not be a replacement for or an excuse for removal of Member States obligation to provide and design active policies in this specific sector.
3) Social safeguards to protect customers from sharply rising energy prices is needed without contest - The creation of the new EU-ETS for buildings and road transport have significant social and distributional impacts that could backfire and end up jeopardizing the ambition of this revision. Hence, we also support the tools proposed by the Commission to mitigate the risks of exacerbated energy poverty, in particular in the context of the current energy prices crisis.
4) Better allocation of resources from the European carbon trading is vital for a successful energy transition - The proposal to reform the EU ETS includes a number of particularly positive measures to increase the ability of the system to channel revenues towards the most urgent and relevant decarbonisation initiatives. According to a set of recommendations on funding mechanisms in the revised EU ETS prepared by CEEP and ERCST, the ETS could generate even €363 billion in auctioning revenues between 2021-2030 pursuant to the current price projections.
5) EU ETS should be also the centerpiece instrument to promote carbon removal technologies - CCUS has the potential to reduce CO2 emissions to the atmosphere and is an important element in the innovation puzzle necessary for a low-carbon and circular economy. We welcome the fact that it is being recognised and promoted by revised ETS directive. This will encourage technology development and investments enabling CO2 reduction and removal.
6) For waste management, increasing recycling rates and reducing the carbon content of the input to incinerators and landfills are the most cost-effective ways to reduce GHG emissions - including waste incineration in the ETS would not lead to a decrease in emissions as operators have no control over carbon content of the input. Upstream actions in the value chain would be more efficient. We welcome the draft ETS Directive as it has taken this fact into account.
For more detailed description of our messages, please refer to the file attached.
Read full responseResponse to Policy framework on biobased, biodegradable and compostable plastics
27 Oct 2021
VEOLIA welcomes the future policy framework on biobased, biodegradable and compostable plastics
The issue of biobased (BBP) and biodegradable/compostable plastics (BDCP) is strongly linked to other topics and legislation, such as the revision of the Directive on Packaging and Packaging Waste, the implementation of the Single-Use Plastics Directive or the work to be done on eco-design and recyclability. As a company active in collection, sorting and recycling, we are witnessing a steady increase in the production of BBP and PDCP, which raises questions in terms of sustainability and impacts on current recycling markets and technologies.
Please find our position in the attached document.
Read full responseResponse to Restoring sustainable carbon cycles
7 Oct 2021
Veolia welcomes the opportunity to provide inputs to Europe's long-term perspective and the integration of carbon removals into the EU climate policies towards 2050.
We recognize the crucial role of carbon removals (CDR) to achieve net-zero emissions by 2050. CDR technologies can offset residual, hard-to-abate emissions not only from the agricultural sector but also from industrial sectors, such as cement or steel. Deploying carbon removal solutions can draw down any emissions overshoot - if emission reductions are not delivered quickly enough - as well as removing historic emissions already in the atmosphere. Whilst CCS is deployed to capture and store CO2 from the flue gas of large industrial point sources for the sake of reducing emissions from fossil fuel use, carbon removals aim to remove CO2 from the atmosphere for the purpose of producing negative emissions.
It is estimated that CDR solutions could and should remove 6-10 gigatons by 2050 from the air worldwide in order to balance residual and reverse historical emissions. Overall, the negative emissions portfolio represents a cost of £7 trillion to £10 trillion to meet net-zero targets. This will require a rapid scaling of CDRs, reaching around 1 Gt of negative emissions by 2030 with efforts to do so starting today. However, there are several key challenges to overcome for carbon removal solutions to play an important role in achieving both the enhanced CO2 emissions reduction target by 2030 and climate neutrality by 2050 in Europe. For Veolia, carbon removals are the only way to efficiently achieve net zero policy goals.
In the attached paper we provide an overview of key priorities to be included in the upcoming EU policy on carbon removals, including: adequately defining the notion of carbon removals (through certification) as well as investing in right technology and nature-based options. We also formulate a number of policy recommendations for specific technology and nature-based solutions. We will need this comprehensive regulatory framework to establish and boost viable markets for carbon removals in Europe.
Read full responseResponse to Detailed implementing rules for the voluntary schemes recognised by the European Commission
27 Jul 2021
Veolia welcomes the opportunity to comment on the Draft Implementing Act on the rules to verify sustainability and greenhouse gas emissions savings criteria and low indirect land-use change-risk criteria.
We support a rapid adoption of a workable text, providing voluntary schemes providers and economic operators with the necessary guidance for demonstrating compliance with the sustainability criteria.
However, we note that the proposed Draft Implementing Act includes several deviations from the actual Renewable Energy Directive text and could result in excessive administrative burden for the market operators. For this reason, we recommend the inclusion of the targeted amendments included in the file attached.
Read full responseMeeting with Pascal Canfin (Member of the European Parliament)
1 Jul 2021 · Green Deal
Response to Commission Delegated Regulation on taxonomy-alignment of undertakings reporting non-financial information
1 Jun 2021
On behalf of Veolia company, please find attached our contribution to the plublic consultation on the draft Article 8 Delegated Act of the green european taxonomy. We welcome the opportunity to bring our contribution on this important element in the construction of a more transparent and homogenous framework for sustainable activities reporting.
The main improvements that we would like to highlight are:
- Art.9.1 Necessity to clarify where to publish, normally in the non-financial report and non the financial one
- Art.9.3 The provision of the KPIs of the 5 previous reporting periods should absolutely avoid any retro-active calculation (neither pro forma nor new TSC application)
ANNEX1
. The mandatory disclosure of detailed information should be limited to a strict minimum in order to avoid breaching normal competition rules on confidentiality
. The calculation of KPIs will impose specific very significant efforts and expenses on the information system, so complexity sould be avoided as much as possible and requirements shoud be focused on the indispensable.
. CapEx plans should not require validation by the company Management Board, which is practically impossible, and their maximum duration should not be limited to 7 years in the case of duly justified heavy investments
. The disclosure of OpEx KPIs won't bring any additional useful information and should absolutely be left to the appreciation of each company
ANNEX2
The templates should be simplified: their current structure is unrealistic and inadequate for Groups operating worldwide thousands of contracts covering activities of many different sorts.
Read full responseMeeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and Kreab Worldwide
6 May 2021 · Presentation of Veolia’s contribution to the implementation of the European Green Deal
Response to Guidance on REDII forest biomass sustainability criteria
28 Apr 2021
We welcome the draft Commission Implementing Regulation on establishing operational guidance on the evidence for demonstrating compliance with the sustainability criteria for forest biomass laid down in Article 29 of Directive (EU) 2018/2001 of the European Parliament and of the Council.
The sustainable biomass will continue to play an important role in the energy transition and contribute to the decarbonisation of district heating networks as well as the European industry. It is one of the available solutions to cut emissions and reduce the dependence on fossil fuels. Achieving the general renewable and specific renewable heating and cooling targets will require predictable and stable conditions for investments, while ensuring the utmost protection of biodiversity and creating and multiplying climate sinks.
Therefore, the focus should be on the robust and harmonised implementation of the existing sustainability criteria. This will ensure that the forest biomass, used for efficient district heat production and cogeneration facilities, meets a high standard of environmental protection while maintaining the legal certainty required for the development of new projects. In this perspective, we would like to present the following comments and targeted suggestions to improve the draft implementing regulation.
Given the delay in the publication of the present implementing regulation, we call for its swift adoption, as well as a speedy process for the recognition of certification schemes to guarantee that sufficient tools are in place to demonstrate compliance for DHC operators. If this cannot be guaranteed, we would like to call for an additional transitional period to be able to meet and demonstrate compliance with the criteria with all the necessary regulatory tools in place;
We are also concerned that the measures of the draft implementing regulation are overstepping the implementation powers granted by the co-legislators to the Commission in the main act, REDII article 29, as well as they anticipate the upcoming revision of REDII. Strengthening the current criteria cannot be a matter of secondary legislation. The guidance should be limited to the clarification of the existing criteria and provide indication on how to fulfill the requirements.
In the file attached, we propose concrete suggestions on how the guidance could be improved
Read full responseResponse to Bathing water quality – review of EU rules
30 Mar 2021
As reported in the European Environmental Agency's 2020 report on Bathing Water management in Europe, the Bathing Water Directive (BWD) has been successful in increasing the quality of bathing sites around the EU. Since its adoption in 1976, the percentage of bathing water sites achieving at least sufficient quality (the minimum quality standard set by the BWD) increased from 74 % in 1991 to over 95 % in 2003. The percentage of bathing waters with the highest water quality (classified as excellent) increased from 53 % in 1991 to 85 % in 2019. Thanks to a common approach set at the european level, more than 8 out of 10 of Europe's monitored bathing waters now have excellent water quality.
But while the quality of bathing water has improved, important challenges remain and emerging issues could be tackled by a revised BWD. To achieve overall excellent quality, the EU must take further action. As a water management operator, Veolia intervenes at many stages of the water cycle, including the monitoring of bathing water. Ensuring the lowest possible level of pollution in bathing waters is a primary goal for our organization. We provide active management of bathing water quality on 171 beaches in France through a rapid analysis method, this tool allows effective monitoring of the quality of sea water and the ability to raise a pollution alert in just one hour for E. coli and within half a day for enterococci.
Considering the importance of safe beaches for touristic activity, timeliness and effectiveness of bathing water monitoring are fundamental in contributing to the local economy. To achieve this goal, the revision of the directive should aim at harmonizing bathing water monitoring, and especially the alternative methods. In France, for example, it has been proved that the alternative method used by competent authorities can regularly produce false positive results under particular climate conditions. Thus, the lack of European recognition of the suitable alternative methods has resulted in conflicting results which jeopardize efforts made by municipalities.
It is imperative that the revision of the directive acknowledges those alternative methods which have proven reliable, to ensure that local authorities can rely on the monitoring of operators. The directive would hence clarify that Health authorities can accept such results and use them as basis to open or close bathing sites, so as to take meaningful action to protect public health and avoid closing sites by doubt on analytical results. In addition to this necessary step, we believe that the frequency of sampling could be increased, in order to have results truly reflecting the bathing water quality and risk management. A higher annual minimum of tests would mean a lesser risk of misclassifying bather water and thus, a lower risk of causing health problems or unnecessary economic costs for the bathing site.
While the monitoring of the bathing water for traces of the two parameters of faecal bacteria is still relevant; the current pandemic also raises the question of monitoring other relevant parameters, such as norovirus for example: New parameters may be suitable, if based on science and evidence of the health impacts of bathing/recreational activities.
Finally, the evaluation of the BWD must ensure its coherence with the Green Deal objectives, and more specifically its interactions with the EU Biodiversity Strategy for 2030, the Zero Pollution Action Plan, as well as future legislation, such as the Industrial Emission Directive and the Urban Waste Water Treatment Directive. Aligning the BWD with these objectives requires to take into consideration the origins of pollution in bathing water, namely up-stream municipal and industrial pollution sources, especially during rainwater events. We therefore call for the revised directive to adopt an integrated approach, to tackle pollution at its sources.
Read full responseResponse to Revision of the Energy Performance of Buildings Directive 2010/31/EU
22 Mar 2021
On 22 February 2021, the European Commission published its inception impact assessment for the Revision of the Energy Performance Directive. Given the challenges of decarbonising the EU building stock identified in the Renovation Wave communication, we agree that the existing legislation is not sufficient to achieve the goal of minimising the carbon footprint of the built environment. Therefore, a revision of the Energy Performance of Buildings Directive (EPBD) is necessary and for that reason, we fully support the third option of the roadmap that consists in thoroughly amending the Directive to translate the actions proposed in the Renovation Wave and the increased ambition towards building decarbonisation into legislation. In this process, we believe the following points should be taken into consideration:
- Necessary introduction of Minimum energy performance standards
- Importance of accelerating the decarbonisation the fuel supply as identified in the Renovation Wave
- Fostering a district approach to energy renovation
- Reinforcing the role of Energy Performance Contracting in the EPBD
- Establishing standards for indoor air quality
- Energy Performance Certificates to be strengthened, in coherence with MEPS
- Introducing Building Renovation Passport
- Making buildings part of an integrated energy system
- Addressing embedded carbon with minimum recycled materials shares
- Reinforcing the policy coherence with other legislations
We develop those ideas more in detail in the attached file.
Read full responseResponse to Modernising the EU’s batteries legislation
1 Mar 2021
VEOLIA is the global leader in optimised resource management. VEOLIA designs and provides water, waste and energy management solutions that contribute to the sustainable development of communities and industries. With the number of electric vehicles on the road around the world expected to increase from eight million in 2020 to 116 million by 2030, access to raw materials will become a strategic challenge. VEOLIA has been dismantling electric vehicle batteries in its recycling plant located in eastern France since 2013. The metals are extracted using a chemical hydrometallurgical process and are then transformed into new materials.
VEOLIA welcomes the proposal for a regulation concerning batteries and waste batteries as a necessary step to create a sustainable European market for batteries, taking into account the collection, treatment and recycling of waste batteries. The comments below are detailed in the attached document.
1/ Batteries are inherently hazardous and must be considered as such when they become waste.
Used batteries must belong to the right category of waste, namely hazardous waste, which is not the case for some of them at the moment. A new hazardous waste code is therefore needed, especially for Li-ion batteries.
2/ Retaining the added value of battery recycling in the EU to maintain the competitive advantage of EU-based companies
Where regulation and costs diverge significantly, restrictions could be assessed and to ensure that EU-based companies can thrive without being penalised by foreign companies that do not share a similar level playing field.
3/ Authorities should work hand in hand with companies to enforce the broader policy objectives of this regulation by investing more in innovation and recycling technologies
VEOLIA asks that competent authorities go beyond the tasks assigned to them and also help companies wishing to invest in this area. This could be done by providing financial and regulatory incentives at local level.
4/ Ambitious targets for recycled contents and increased recyclability will prove highly beneficial to the entire value chain
The current targets are ambitious enough for Co, Li and Ni in terms of scope, recycling levels and timeframe. VEOLIA also wants stress that other materials, such as plastics or metals, should be considered for recycling when designing or treating batteries.
5/ Beyond the proposed performance criteria, financial and regulatory instruments should be set up to incentivise and reward the use of Secondary Raw Materials
Incentivising the use of secondary raw materials would make batteries even more circular in the future, thereby helping the EU to reach its ambitious GHG emissions targets.
6/ National authorities should ensure that the principle of extended producer responsibility is upheld throughout the value chain
For recycling businesses to thrive, individual schemes must not be jeopardized, while collection must be improved where it is insufficient. Existing individual schemes should be maintained and developed, especially for automotive batteries and electric vehicle batteries.
7/ Collection targets should include batteries from light means of transport and traceability should be ensured for automotive, electric vehicle and industrial batteries
Used batteries from light means of transport should be included in the targets. Similar collection targets may not be required for industrial and automotive batteries, but some form of traceability should be ensured for these batteries.
8/ Minimum efficiency criteria for recycling and material recovery are welcome but must be technologically neutral and lead to high-quality recycling
The future revision of recycling efficiencies must be adaptable to different processes and should not lead to the imposition of a single technology on all recyclers. Targets should be seen from a qualitative rather than quantitative perspective.
Read full responseResponse to Revision of EU Ambient Air Quality legislation
14 Jan 2021
Veolia welcomes the initiative of the European Commission to revise rules regarding air quality as announced in the European Green Deal and its zero pollution ambition for a toxic-free environment. We support the need to draw on the lessons learnt from the Fitness Check of the Ambient Air Quality Directives.
While we agree with its central conclusions, namely that the AAQ Directives have been quite effective in achieving their overall objectives (they have guided the monitoring of air quality, set clear air quality standards, and facilitated the exchange of information on air quality), they have not fully ensured that sufficient action is taken throughout the EU to meet air quality standards and keep exceedances as short as possible, resulting an overall mixed picture regarding the overall air quality improvement in the EU. For several air pollutants, especially particulate matter, nitrogen dioxide, ozone and benzo(a)pyrene, widespread and persistent exceedances above EU air quality standards continue, and still lead to significant impacts on human health and the environment as a whole. Air pollution is still the number one environmental health risk in the EU (and world-wide). Therefore, we support the need to strengthen provisions on monitoring, modelling and air quality plans in order to help local authorities achieve cleaner air, as well as align EU air quality standards closely with World Health Organization (WHO) recommendations.
Regarding the specific issues identified in the roadmap, we would like to propose the specific recommendations in areas identified by the inception impact assessments that are:
1) Addressing EU air quality standards allow higher air pollutant concentrations than is scientifically advisable
The existing air quality standards need to be adjusted upright to the level of more ambitious WHO guidelines especially regarding PM 2.5. Especially the discrepancy in fine particulate matter (PM2.5) continues to cause concern, as scientific evidence points to substantial health impacts attributable to exceedance of the WHO Guidelines (noting that there are no observed safe levels of fine particulate matter).
2) Improving the air quality legislative framework, including provisions on penalties and public information, in order to enhance effectiveness, efficiency and coherence
- Availability of information on air pollution to the public should be enhanced;
- As well as availability of information on air pollution to the Commission and other Member States;
- Regarding penalties, in addition to establishing additional mechanisms on sanctions and penalties for non-fulfillment of relevant obligations deriving from the Directives in national systems, there is a very strong need for clearly establishing responsibilities of various stakeholders.
3) Need for a better support to local authorities in achieving cleaner air through strengthening air quality monitoring, modelling and plans
- Regarding options for more detailed rules on the number and location of sampling points: More sampling points are required, the use of micro-sensors should be encouraged and regulated through the Directive, and solutions for air quality measurements should be as efficient and advanced as possible;
- Regarding streamlining and adjusting minimum elements required for an effective air quality plan, air quality monitoring zones should be better designed, there should be a better coordination between air quality plans and other relevant policies at the level of air quality monitoring zones, and finally better guidance should be provided to respective authorities regarding several aspects of the plans .
We have enumerated specific recommendations in the file attached, based on our own in house expertise in this area as well as the conclusions of the Fitness Check on the EU Air Quality Framework.
Read full responseResponse to Commission Decision determining the benchmarks values for free allocation in the period 2021-2025
4 Jan 2021
The EU ETS has been a key instrument to deliver the decarbonisation of the industry and electricity sector. In this context, the free allocation based on the benchmarks system has been important in minimising the risk of carbon leakage between European operators and the rest of the world, as well as the so called “internal carbon leakage” between installations in ETS and outside the ETS. Free allocation should also serve the purpose of putting energy efficiency first, by promoting more efficient combustion solutions like CHP and district heating. Despite these high-level objectives of the EU ETS, the implementing acts for Phase IV appear to deviate from the spirit of the Directive. Veolia would like to raise its serious concerns related to the proposed update of the heat benchmark (i.e. 47.3 allowances/TJ), which contradicts the principles of harmonised free allocation in the EU ETS Directive.
Indeed, in the process of defining free allocation rules for Phase IV, the European Commission has chosen to change the underlying methodology for accounting CHP heat emissions between Phases III and IV, without introducing any correction to ensure consistency between the two phases. In addition, the benchmark update moves away from using natural gas as a reference low carbon and widely available fuel, allowing for biomass use to be accounted.
The change in the CHP allocation methodology applied to a CHP installation allocates fewer emissions to the heat output and higher emissions to the electricity output for the same level of total emissions between phases III and IV. Given that high efficiency CHP represents 16.5% of all heat generated in the EU, it can be assumed that it makes most of the 10% most carbon efficient heat installations. Therefore, the significant reduction of the heat benchmark is likely to be attributed to the change in the CHP emission allocation methodology than any progress in terms of carbon intensity of Europe’s heat generators. Therefore, the heat benchmark update does not reflect the dynamics of heat decarbonization, overestimating the impact of low carbon solutions, and thus slowing down further progress.
In addition, the significant reduction of the heat benchmark between EU ETS Phases III and IV, combined with the application of the linear reduction factor (LRF) to high efficiency CHP classified as “electricity generators” under Annex I , risks disincentivising the uptake of CHP versus less efficient and more emitting heat-only boilers. Depending on the applicable EU ETS regime (i.e. carbon leakage vs. non-carbon leakage) and market conditions (e.g. national clean spark spreads), the gross margin to cover CHP depreciation compared to a boiler is reduced by between 2-8% under the new Phase IV conditions. This shows that the EU ETS rules, including the heat benchmark update, goes against the cost- competitiveness principles in the ETS Directive by narrowing or even reversing the competitive advantage that CHP may have over less efficient and more polluting heat generators.
The heat benchmark is also impacted by the inclusion of biomass heat generators in the 10% most carbon efficient installations. While biomass and its efficient use with CHP is one of the solutions to decarbonise heat, sustainability criteria and its limited availability as a local fuel suggest it should be treated as an outlier in the calculation of the benchmark for the next few years.
To address the concerns above and align with the Free Allocation Rules Delegated regulation (2019/331), we would suggests that what is needed is to:
- Ensure consistency and continuity by correcting the heat benchmark to reflect the same CHP methodology between Phases III and IV. This can be done by theoretically applying Phase IV method to Phase III, thus obtaining a more adequate reduction rate for the heat benchmark (expected to fall between 0.2% and 1.6%);
- Treat biomass installations as outliers in the calculation.
Read full responseResponse to Improving environmental protection through criminal law
21 Dec 2020
Veolia supports the Directive on the protection of the environment through criminal law (ECD) and shares answers to the Inception impact assessment.
The EU needs to strengthen its efforts to combat environment crime and thus contribute to the goals of the European Green Deal and the Biodiversity Strategy for 2030. As long as EU territories are not properly held accountable for the protection of their environment, it may be tempting to adapt the level of ambition according to the current economic activities, especially amidst this pandemic period.
Veolia believes that the first option does not capture the fast evolving practices, and we are very much in favour of more homogeneous practices across the Member States. For the same reason, the second option would be unsatisfactory. Veolia supports option 3, to prioritize amending the ECD and include specific provisions to improve the topics 1 to 5. As a result:
We believe that the legal technique used to define the scope of the Directive should maintain the current approach while updating the definitions in Article 3 and the annexes, including updated legislation adopted more recently (option i).
Certain legal terms and qualifying elements used in Article 3 of the ECD should be clarified:
- (a) and (d): “substantial damage”,
- (f) and (g): "negligible quantity”, “negligible impact”,
- (h): “significant deterioration”.
Concerning the availability and application of appropriate sanctions types and levels to address environmental crimes defined in the ECD, Veolia believes that:
- minimum levels for maximum sanction should be defined, to ensure similar sanctions across the EU, and also to deter any crime that could be “beneficial” even if penalized.
- Aggravating circumstances should be defined as to include:
1. actions of the offender to obstruct administrative controls and inspection,
2. environmental crimes committed in the context of organised crime,
3. the severity of the damage caused.
- accessory sanctions such as the obligation to restore environmental damage done or the seizure and confiscation of illegal profits and material used for committing the crime should be implemented according to the severity of the crime committed.
Concerning the fourth point of this section, we think that the definition of the “profits expected or generated” from environmental crimes should be more precise.
Veolia supports the cross-border cooperation and coordination of law enforcement and judicial authorities to better fight environmental crime. We are in favor of a level playing field for all EU territories and thus of a harmonised list of cross-border investigative tools that should be available in Member States for tackling environmental crime.
We believe that collecting, sharing and reporting statistical data on environmental crime is an effective way to make EU Member States and its various actors in the field of environment more responsible and cautious in their activities. Veolia supports the effective operation of the enforcement chain covering detection, investigation and prosecution, having regard to the findings and the recommendations from the 8th Mutual Evaluation Round and the role of European networks of inspectors, police, prosecutors and judges dealing with environmental crime.
We also believe that the ECD should be linked to the Directive 2004/35/CE of the European Parliament and of the Council of 21 April 2004 on environmental liability with regard to the prevention and remedying of environmental damage.
Read full responseResponse to Climate change mitigation and adaptation taxonomy
18 Dec 2020
Veolia welcomes the opportunity to comment on the Draft Delegated Regulation supplementing Regulation (EU) 2020/852 and its Annexes. The Taxonomy Regulation can be a key enabler for scaling up sustainable investments and achieving the EU’s raised climate ambition of 55% by accelerating the transition. It will considerably influence the investments decision into economic activities by creating a barometer revealing the degree of their contribution to the ecological transformation.
For this legislation to deliver and become a useful tool to trigger sustainable investments, the requirements listed in the delegated regulation and annexes must be scientifically based and measurable with existing metrics, as well as actionable with realistic solutions. We gathered comments regarding the proposed screening criteria for various activities relevant for Veolia business across the EU, in the field of energy, water and waste management. The aim of the proposed amendments is not to hinder the effectiveness of the Taxonomy but, on the contrary, to ensure that the classification variables are as solid and realistic as possible, in order to favor the channeling of sustainable investments towards projects and activities that can actually contribute to the decarbonisation of our sectors.
Our general remarks include the following:
- Coherence should be ensured with existing EU legislation and current investment classifications, for example the European Investment Bank’s Energy Lending Policy. If the Taxonomy requirements are not based on existing metrics, they could constitute an unnecessarily punitive labeling of perfectly sustainable economic activities.
- The future Taxonomy should encourage and support a transition to a climate neutral EU, that is progressive, pragmatic and evidence-based, taking into account the existing situation and the available solutions on the market. Otherwise, it could prove counterproductive in the course of achieving an efficient transformation, by discouraging its funding if extremely ambitious goals are set too early for feasible solutions to be developed.
- Given the expected major impact on the European economy, technical screening criteria must be properly developed and impact assessed, in association with co-legislators and stakeholders, in line with the Better Regulation Agenda. In some cases, it could be relevant to set progressive targets on a pluriannual basis, which could guide the transformation of sectors in a win-win manner and avoid unintended damaging consequences.
- It is crucial to ensure that activities that are compliant with the relevant technical screening criteria at the time when they are evaluated, can be considered as Taxonomy-eligible at least throughout their economic lifetime. This point should be explained and stated in a clearer way, to provide companies and investors with the necessary stability and visibility they need.
- Considering that the Taxonomy is new, incomplete and that it does not adequately take into consideration activities in transition, we consider that potential reference to the Taxonomy in other EU legislation as of today is not appropriate. In particular, we refer to the soon to be revised Energy Efficiency Directive, Renewable Directive, Energy Performance of Buildings Directive, and for all legislation relative to the use of EU funds.
- Whilst article 19.1. (a) of the Taxonomy Regulation sets forth the principle of technological neutrality, this does not seem to be systematically the case in the draft delegated act. All technologies should be treated equally (e.g. performance of full life cycle analysis and specific emissions thresholds for energy generating activities), without any bias towards any technology that is not based on best available practices.
In the file attached, you'll find comments and recommendations for amendments of activities and screening criteria that are relevant for our company.
Read full responseResponse to Revision of the Energy and Environmental Aid Guidelines (EEAG)
10 Dec 2020
Veolia welcomes the European Commission initiative to revise the EEAG and the relevant provisions of the GBER against the backdrop of the twin green and digital transformation of the economy, notably the European Green Deal, that aims to transform the EU into the first carbon neutral economy by 2050 and a circular and zero-pollution strategy. Indeed, the announcement of the Green Deal requires a wider and deeper review of the EEAG. This revision also should serve the purpose of taking into account the impact of the COVID-19 pandemic on the Member States’ economies and their funding capabilities together with the deployment of the Recovery Plan for Europe. Competition policy, and State aid rules in particular, have an important role to play in that regard.
Both the results of the Fitness Check on the State aid modernisation and the interviews we carried with our business units show that the EEAG and corresponding GBER rules have generally delivered on their objectives, in terms of facilitating access to public financing of environmental and energy projects. Yet, certain aspects of the EEAG should be revised and modernised. The revision should result in a modernised, simplified, easy to apply and future-proof enabling framework for public authorities to help reach the EU environmental and energy objectives in a cost effective manner with minimum distortions of competition and trade within the Union. We would like to recommend the following modifications to the current rules to make sure the objectives of the revision are achieved.
I. Simplification and streamlining of current rules defining access to state aid in the field of energy and environment
- Overall simplification of rules
- Ending differentiation in aid intensities between small, medium and large companies
- Clarifying rules applying to in-house undertakings
II. A necessary widening of the scope of the EEAG
- Rules serving reduction of CO2 emissions
- Rules serving the objective of energy efficiency
- Rules serving the objective of smart sector integration
- Rules serving the purpose of circular economy
III. Implications of widening the scope of EEAG and reorganizing state aid categories
- Smart sector integration: clarification of the status of waste heat and better access to state aid
- Smart Sector Integration: the framework should be adjusted to better support investments in District Heating Networks
- Energy efficiency: Enhanced support for energy efficiency services (such as Energy Performance Contracting)
- Energy efficiency: better targeted support for high efficient CHP
- Circular Economy: State aid should cover all chains of the circular economy
- Overall, better alignment with existing and future legislation is needed
IV. Creating green bonus for projects providing extra-benefits in terms of environmental services and other positive externalities
- Bonus for undertakings covered by energy management services
- Bonus for projects with significant benefits beyond economic and environmental aspects
- Bonuses for projects developed in the framework of a district approach
V. Greater transparency is needed but not based on the EU Taxonomy.
For more details on those elements, please see the attached file
Read full responseResponse to New EU Soil Strategy - healthy soil for a healthy life
4 Dec 2020
The EU soil policy action is necessary to create a level playing field for all economic operators to be submitted to the same requirement and avoid distortion of the internal market: As long as EU territories are not held accountable for the protection of soils, it may be tempting to adapt the level of ambition according to the current economic activities or to welcome new industrial sites. This is especially true with the plans to decouple the EU economic activities from unsustainable reliance on global supply chains. Veolia endorses the EEA conclusion about the lack of a comprehensive and coherent policy framework to protect land and soil.
We believe the EU must give itself a full-fledged Soil-Framework Directive, providing goals for European Soils protection, with horizontal soil quality standards, monitoring and reporting requirements, and a toolbox to reach the goals. Such a directive will be instrumental to the Green Deal, and more precisely the Zero-pollution strategy, the Farm-to-Fork and the Biodiversity strategies. The experience, positive and negative, gained from the implementation of the Water Framework Directive (WFD) should guide the EU in developing a Soil directive, which should indeed step up efforts to protect soil fertility and reduce soil erosion, Increase soil organic matter and restore carbon-rich ecosystems, protect and enhance soil biodiversity.
The physical protection of soils does matter -like hydromorphology under the WFD- to reduce the rate of land take, urban sprawl and sealing to achieve no net land take by 2050. This entails progress in identifying and remediating contaminated sites: the soil strategy must be tightly interfaced with the upcoming strategy for a sustainable built environment.
Enhancing and protecting the organic content of soils is paramount. The EU legislation should ensure that the potential of the circular economy is fully taped into:
- This is why the sludge directive should be revised as a daughter directive of the to-be-written soil-framework directive, to provide specific definitions and thresholds to secure the beneficial recycling of urban sewage sludge into land.
- The quality of soils can be enhanced using available organic matter and especially biowaste, which has to be separately collected by 2023. Economic drivers and incentives should be implemented to enable the production and use of safe fertilizers and soil amendments. This entails more investments in collection as well as economic instruments (such as tax rebate or subsidies) making it viable for local authorities and farmers to use the end product.
- As intended in its Circular Economy Action plan, the Commission should carefully assess the impact of biodegradable plastics as they might pose a threat to both recycling and composting processes.
A specific topic is the identification of contaminated sites, and their remediation needs a proactive approach. For Soil decontamination, where the contamination is such that it cannot be fully remediated, enabling the use of the site for tertiary purposes is possible with adapted soil quality targets (Germany has a proven practice which may inspire the EU). Furthermore, the financial risks pertaining to purchasing contaminated land (liability for pre-existing contamination), could be partially alleviated by setting up structures leasing brownfield lands.
To secure sufficient funding, the EU should facilitate environmental reporting (e.g. “4 PER 1000”, “Low Carbon Label”, “SOC Guidance”) methodologies for environmental accounting and reporting of soil carbon storage and support the development of marketplaces enabling offsets to be sold as carbon credits.
Read full responseResponse to Protecting biodiversity: nature restoration targets
30 Nov 2020
Veolia strongly supports the EU Strategy on biodiversity and shares answers to the Inception impact assessment.
The plan to increase and strengthen the EU network of protected areas needs measures and monitoring that are concrete and readily understood by all actors for swift implementation: we suggest to include broad no-regret measures obligations (ex. zero-pesticides areas in urban and industrial environments, organic farming in rural surroundings, late mowing, …).
The EU Nature Restoration Plan, with binding targets for soil sealing and urban sprawl is promising, using undisputable measures and monitoring. The “EU-wide methodology to map, assess (...)” must be readily understood in the same manner by all actors who are tasked to implement them.
The F2F Strategy conditions the success of the Biodiversity strategy. We strongly support the payment for ecosystem services (GHG sequestration, soil protection etc.) where the environmental benefits can be measured.
The Zero Pollution Action Plan must tackle pesticides, heavy metals and chemicals of emerging concern: they must be eliminated at source to avoid struggling with pollution dispersed in products, packagings, wastes and ecosystems. A number of species are contaminated by heavy metals or Chemicals of emerging concerns, which builds-up in the food-chain: we need more environmental quality standards for surface water, biota and sediments, and mixture, to trigger remedial action and monitoring of flows from economic and urban activities.
The UWWTD is a proven instrument to tackle urban impacts on inland and coastal waters: it should become a mainstream element to improve biodiversity of EU waters and ecosystems, including for example monitoring around the infrastructures and wetlands protection. It also entails higher nutrient removal, and the removal of chemicals of emerging concern.
We support EU hard targets for the restoration of free-flowing rivers, floodplains and wetlands. The EU should also adopt a more prescriptive, pan-European, approach to Ecological flows definition under the WFD. In addition, it is urgent to develop an EU vision on how impacts of the changing climate are to be faced in landscaping the freshwater ecosystems.
Restoring soil ecosystems lacks a full-fledged soil framework directive in line with the strategy for a sustainable built environment to “protect soil fertility, reduce soil erosion and increase soil organic matter”:
- To support soil conservation, the EU should facilitate environmental reporting (e.g. “4 PER 1000”, “Low Carbon Label”, “SOC Guidance”) , reporting of soil carbon storage and support marketplaces enabling offsets to be sold as carbon credits.
- where the contamination of soils cannot be fully remediated, the use of the site for tertiary purposes is possible with adapted soil quality targets (Germany has a proven practice), and the liability for pre-existing contamination could be partially alleviated by setting up structures leasing brownfield lands.
- As a daughter directive of this soil framework directive, the sludge directive must be revised to fully exploit the carbon content of biodegradable waste from urban and industrial sources, and enhance soil fertility and carbon sequestration
The Greening of urban spaces must make the best of urban farming to enhance biodiversity and mitigate climate change, also creating local jobs: An EU standardisation would be beneficial. Likewise, a European label “Aquaponics” should be created.
These measures lead to higher production costs in Europe: This must be accounted for in trade policies, all the way to controls on imported products, so that the EU does not externalise pollution, at the expense of domestic jobs.
Read full response26 Nov 2020
We welcome the initiative of the European Commission to review the Regulation on binding annual greenhouse gas (GHG) reductions by Member States, the so called Effort Sharing Regulation.
Below we provide our thoughts regarding the place the buildings and waste sectors should have respectively in the EU ETS and ESR.
Extension of the EU ETS to the building sector has to be accompanied by a strong high impact policy mix in Member States directly addressing building decarbonisation challenges
Veolia is in favor of extending the scope of the EU ETS to the building sector, provided:
It covers all GHG emissions from fossil fuels used in buildings;
The chosen mechanism is as easy and as quick to implement as possible, with a clear scope;
It takes the form of an specific EU ETS for the building sector, designed to capture emissions upstream (applied to fuels distributors);
Is accompanied by well-designed compensation measures for the most vulnerable consumers not capable of immediately switching to low-carbon heating solutions and hence heavily impacted by potentially higher energy bills.
Also, it is essential that it can only work effectively and efficiently as part of a well-designed broader policy mix. With that in mind we support the second option in the Inception Impact Assessment, namely, keeping current ESR sectoral scope in parallel to extending emissions trading. We believe that given the limited potential of CO2 pricing that will be introduced by a dedicated EU ETS, building related policies should remain under the responsibility of Member States, which is ensured when the building sector remains in the scope of the Effort Sharing Regulation. The ultimate goal of a revised legislative package to serve the purposes of the Green Deal is to obtain maximum coherence and clarity, which will provide future investors with clear targets, measures and trajectories.
Waste sector should remain outside the scope of the EU ETS
For GHG emissions, the whole waste management sector should be addressed in a single coherent policy framework. As far as waste management is concerned, each treatment option should be part of an integrated waste management approach. Waste incineration represents one option amongst others and many parameters are taken into account when local authorities design waste management plans. Scattering the waste management sector across different regulations would lead to inconsistencies and additional administrative burden.
Regarding waste incineration, lowering the carbon content of the input is the most cost-effective way to reduce GHG emissions. Upstream actions focusing on the carbon content of products would be the most cost-effective way to reduce GHG emissions. Besides incineration, it is worth noting that the development of waste-derived fuels (RDF/SRF) would help to lower emissions in other sectors as their emission factors are lower than those of more conventional fuels.
Waste sector’s emissions have been significantly reduced and could be further mitigated under the current Effort Sharing Regulation. To reduce the waste sector’s emissions, only a holistic approach encompassing all treatments would have a significant impact, thereby leading to a sharp decrease in emissions. This would benefit both the sector and the wider economy.
Under the ESR, a variety of regulatory, economic and fiscal instruments have proven to be efficient and reliable at national level. The ESR has been conducive to the development of these policies and should remain the cornerstone as it takes into account the whole waste management sector and offers the necessary leeway for member states to tailor their national policies and incentives.
For more information, please see the attached file
Read full responseResponse to Updating the EU Emissions Trading System
26 Nov 2020
As data shows, the EU ETS has been an effective tool for reducing CO2 emissions in the sectors covered by it. But there is a need to strengthen the system to enable a delivery of necessary emissions reductions and by doing so, to deliver a robust CO2 price.
The need for a reinforced EU ETS to deliver robust CO2 price necessary for energy and climate transition
A 55% target will require an increase from the EU ETS contribution from the current -43% to -62%.This will imply the need for a reform that will eliminate the existing surplus of allowances in the market. The following options should be combined and mutually reinforcing:
There is a need to “rebase” the EU ETS cap to levels better reflecting the actual emission levels. Rebasing the cap would not only help to restore scarcity in EU ETS at the beginning of phase four, but also lead towards a cap reduction path possibly consistent with a climate target of -55%;
The literature review also point out to the need of increasing the Linear Reduction Factor from 2026 on from the current 2.2% (planned for the 4th phase) to 4.2%;
Market Stability Reserve Review is a complex matter, several parameters have to be looked at (withdrawal rate, thresholds, etc.), interactions with a deeper cap reduction path and implications on the carbon-leakage risk have to be investigated. However to help balance supply and demand in the EU ETS, the MSR withdrawal rate could be lifted temporarily from 24% to 36% from 2021 on.
Much needed extension of the EU ETS to the building sector
We have been advocating for the introduction of a homogenous CO2 pricing for the entire heating sector. Hence, we advocate for the extension of the EU ETS to cover all GHG emissions from fossil fuels used in buildings:
The extension of the current EU ETS to the building sector could be counterproductive, take longer than what is urgently required and have negative consequences both in terms of emissions reduction potential for the building sector as well as unproportionally important burden to be carried by sectors already in the existing EU ETS;
In the short term a separate ETS for fuels is clearly more appropriate here than an expansion of the EU ETS as it would provide more targeted reduction incentives in the building sector;
Including the buildings in the EU ETS would require these sectors to be captured upstream.
Any CO2 pricing imposed on the residential sector would also require ambitious compensating mechanisms to prevent rise of energy poverty and support investments in important sectors
Potential impact of an EU ETS for buildings on fuel poverty: any carbon pricing can lead to an increase of energy poverty unless appropriate flanking measures are taken to protect vulnerable groups;
Need for financing to support the modernisation of DHC networks and renovation of buildings. Decarbonising the heating and cooling sector would both require and entail increased efficiency, the integration of renewables and waste heat, as well as flexibility brought by system integration. District Heating can enable the three. The sector will thus need the continuous support of all existing financing tools to achieve its full potential in all Member States.
Waste sector should remain outside the scope of the EU ETS
The waste management sector is a relatively small emitter of GHG in comparison to other industries (less than 3% of total GHG emissions).
We would not recommend extending the ETS scope to waste incineration. While the waste management sector must decrease its CO2 and CH4 emissions, including incineration would not lead to this outcome. It would also imply additional costs without triggering more investment in innovative solutions. Thus, we would favour option 3 proposed by the Commission, i.e. maintaining in the ESR only the sectors that are not covered by the ETS while making sure national objectives are reviewed in line with the overall commitment.
For more details, please see the file attached
Read full responseResponse to Revision of EU legislation on end-of-life vehicles
19 Nov 2020
Veolia welcomes the revision of the ELV Directive as a way to increase the contribution of ELV management to the circular economy in line with the Green Deal and the Circular Economy Action Plan. The ELV Directive has been instrumental in better managing vehicles once they become waste and Veolia calls for an ambitious revision based on the following key principles:
1/ Facilitating dismantling and recycling by focusing on eco-design
Eco-design is the first step to improve the recyclability of various parts, as well as ensuring the efficiency of recycling processes. Thus it is crucial to make dismantling and sorting easy and more thorough before the final shredding step. Once vehicles are shredded, recovering materials becomes much more complex and costly so any prior step allowing effective separation of valuable spare parts, recoverable materials and contaminated fractions should be preferred. The intrinsic recyclability of specific parts should be ensured by working together with waste management companies and potential clients for Secondary Raw Materials so that industrial solutions could be scaled up.
2/ Reaching high-quality recycling by phasing out Substances of Concern and/or decontaminating specific streams
Problematic substances contained in polymers or other materials should be reduced or substituted. Substances of concerns impair the quality of recyclates and should be avoided or only be used when necessary. Alternatively, decontamination could be required to ensure a safe return back into the loop. The fate of ‘legacy substances' should be dealt with as a matter of priority. This could be done by lowering hazardous substances thresholds or gradually phasing them out at the eco-design phase.
3/ Closing the loop by setting up requirements for the mandatory use of recycled materials
Veolia strongly supports the introduction of mandatory minimum recycled contents in a revised ELV Directive. It is key to create secondary raw material markets to reach the ambitious EU recycling targets and further reduce GHG emissions. This could apply to the most common waste and material streams such as glass, plastics and metal. As far as non-hazardous plastic resins are concerned, PE and PP should be a priority. It is crucial to assess hazardous items such as batteries or electronic equipment to ensure that specific parts or substances could be either recycled or recovered.
4/ Promoting best practices by taking into account the specificity of each waste stream
Different types of liquid and solid waste streams are extracted from ELVs and should be treated in line with the waste treatment hierarchy. While recycling remains the most desirable option for most waste streams, others should be either safely recovered or disposed of to avoid any harm to the environment or human health.
Read full responseResponse to Review of Directive 2012/27/EU on energy efficiency
21 Sept 2020
Veolia welcomes the European Commission initiative to revise the Energy Efficiency Directive, as announced in the EU Green Deal Communication. Efficient use of energy is key to achieve the Green Deal objectives. The revision seems necessary as preliminary estimates show that even if the 2020 target might be achieved due to COVID19 effect, there are very little chances the 2030 targets will be achieved. This is confirmed by the assessment of the final NECPs. Also, as the roadmap specifies, the revision of the EED, if leading to additional energy savings, is likely to have positive impacts on economic growth and investments, and increasing the EU competitiveness, reduced fossil fuel imports, changes in the fuel mix and enhanced energy security, as well as distributional and social impacts.
In the revision process, and when elaborating the combined evaluation and inception impact assessment, we would like to advocate for the most ambitious revision scenario, encompassing the revision of provisions concerning renovation of public buildings, public procurement, energy audits, heating and cooling and recovery of waste heat, energy services and skills amongst others; as well as additional provision not mentioned in the list. In addition, non-regulatory measures should also be considered. General considerations are the following:
- The new EED should integrate the Energy Efficiency First principle as defined in Article 18(2) of the Regulation, EU(2018)1999, requiring to prioritise energy efficiency actions along the whole energy chain (from the supply to demand side). As the roadmap states, Energy Efficiency First is a guiding principle of EU energy policy, and is highlighted in the European Green Deal as a key means to decarbonise the energy system by 2050. This principle did not exist in 2012, so it should be clearly affirmed and recognised in Energy Efficiency Directive as well as in all other energy-related policies.
- More focus is needed on primary energy reduction, as primary energy is the real indicator of the energy effectively consumed and gauging its progression enables us to see the actual system efficiency.
- A revised EED should enhance the role of Energy Efficiency Services (EES), which should always be considered along with renovation actions and prioritised, where relevant, due to their main advantages: the cost-effectiveness of measures and projects, which can be carried out more easily than heavier interventions and have shorter payback times, with contractual arrangements possibly offering financing solutions and often requiring low upfront investment. This is particularly important in the current economic context and especially for EE measures in the public sector, as many local and regional authorities’ ability to invest in capital intensive works will be significantly limited; The achievement and maintaining, through proactive energy management, of actual energy efficiency improvements over time, which can also be contractually guaranteed in the case of Energy Performance Contracting (EPC).
- Regarding the heating sector in particular, the revised directive should also provide for more targeted provisions on supply side efficiency, in particular for cogeneration and district heating.
- A better alignment of the provisions of the EPBD, EED and RED is needed to address barriers that hamper the deployment of energy efficiency in this sector and a better waste heat recovery.
- Finally, the introduction of “stability of financial support” to ensure predictability of long-term investments in energy efficiency solutions is also essential, given the contribution energy efficiency is likely to have for the EU economic recovery. Similar provisions as in RED II Article 6 are needed in the revised EED.
The paper attached contains a series of recommendations on specific articles, which are in the scope of the current revision and additional ones which should also be considered for review.
Read full responseResponse to Revision of the Renewable Energy Directive (EU) 2018/2001
21 Sept 2020
Veolia welcomes the European Commission’s initiative to assess the possibility to revise the Renewable Energy Directive (REDII) and would like to make the following recommendations for the impact assessment.
Increasing the general and sectoral targets for renewable energy: In accordance with the results of the impact assessment published on September 17 for 2030 CO2 emission target of 55%, it seems necessary to revise the general RES target from the current 32% to at least 40%.
In order to achieve this objective, sectoral targets would also have to be increased, in particular in the heating and cooling sector. This could take the form of a general binding target to be achieved at the EU level, in line with the potential of 40% identified in the impact assessment of 2030 CO2 target and binding national yearly target.
Strengthening coherence with energy efficiency Directive: Energy efficiency improvements should be prioritised, even in the field of renewables (RES) production and distribution, in line with the Energy Efficiency First principle. This should be fully applied to the generation, distribution and consumption of all types of RES.
Further promoting highly efficient and green heating solutions, such as district heating, cogeneration and waste heat recovery: Delivering sustainable heating and cooling is fundamental to achieve Europe’s climate neutrality ambition. We need to make sure that REDII is adequately transposed, and in the framework of the current revision, that potential new instruments are being added to promote district heating, cogeneration and heat recovery.
Promoting waste derived and low carbon fuels: Waste-derived fuels, which include a renewable fraction help reduce and ultimately avoid the consumption of fuels with a higher carbon footprint. Hence, the potential of waste-derived fuels should be fully tapped into to reach the EU CO2 emissions and renewables targets
Enforcing sustainability criteria for biomass with the view of a thorough evaluation: Sustainable biomass will continue to play an important role in the energy transition and contribute to the decarbonisation of the heating sector, and district heating and cooling in particular. The implementation of the existing sustainability and GHG criteria set out in REDII and related compliance guidelines will ensure that only the most sustainable biomass is efficiently used for district heat production. Those sustainability and GHG emissions requirements will be implemented in Europe, starting from next year, while the implementing guidelines for REDII are not yet finalised. An appropriate fitness-check is meant to evaluate if measures are fit for purpose by assessing their performance with respect to the policy objectives. At present, such an evaluation cannot be carried out as the sustainability requirements for biomass are not yet implemented. Therefore, the revision of articles 29-31 of REDII would be premature.
Financial support is essential, especially in the context of Green Recovery: Higher general and sectoral targets for renewables and waste heat can only be achieved if adequate support schemes are being designed and implemented at the EU, member states and local levels. Support should address the transition towards high efficient heating, emerging applications, cogeneration and waste to energy installations. This support architecture should be clear and predictable. Also, the funding could also be reinforced for projects covered by schemes guaranteeing results in terms of efficiency, RES penetration and CO2 savings, as well as when cogeneration is being used. Finally, the heating sector needs a uniform CO2 price to ensure a level-playing field. This should be achieved through the revision of the Energy Taxation Directive and/or the revision of the EU ETS.
More details in the file attached
Read full responseResponse to Revision of the Urban Wastewater Treatment Directive
3 Sept 2020
Veolia welcomes the Inception Impact Assessment on the revision of the Urban Waste Water Treatment Directive (UWWTD). Two issues do not feature explicitly in these early directions:
- Access to Sanitation: It is fundamental that the Human Right to Water and Sanitation is translated into EU law, recalling that SDG 6 aims to grant access to sanitation for all by 2030. An increasing number of homeless people in urban areas lack access to decent sanitation facilities. The new UWWTD should enshrine this international right into European law, as is being done with the new Drinking Water Directive.
- The reuse of appropriately treated wastewater beyond agricultural irrigation: Year after year, the EU is suffering from severe droughts, highlighting the value of all water sources. We think that the revision of the UWWTD should introduce a provision to assess the potential of treated wastewater/rainwater reuse for local purposes. Whether for environmental enhancement, urban uses or economic life, and not solely crops irrigation (covered in the EU Water Reuse Regulation) - complying with the highest health and environmental standards.
Better stormwater management is a matter of resilience of the grey and green infrastructures, faced with climate change and rapid urbanisation. We believe several matters should be addressed in this framework: favouring the re-infiltration of rainwater, taking into account potential environmental impacts; enhancing wetlands within the perimeter of the service, especially downstream of the discharge points; and finally, controlling for sanitary risks associated with untreated urban runoff discharges. We also believe the EU Biodiversity Strategy must be cross-references as appropriate: as an example, the “clear set of agreed indicators” anticipated under this strategy should be carried over into the UWWTD for those who are applicable to water. Moreover, the “Urban Greening Plans” must be closely tied to the rainwater and wastewater management plans.
We welcome the closer look to small agglomerations and individual systems, with four main ambitions:
1) Ramping up decentralised solutions where the population density is too low;
2) Avoiding to further enhance the urban/rural divide;
3) Mandating Member States to monitor more closely what is done and not done by local authorities and report;
4) Reducing interpretation gaps between all levels of governance within and between Member States. We hence support the development of an EU-wide definition of sensitive zones, which must drive the nutrient removal obligations.
The contaminants of emerging concern (CECs) are far from being fully explored, yet they must be tackled in the revision to protect health and the environment. We believe the EU has a critical role to play in deciding the suitable proxies and targets for the wastewater treatment plants, according to size etc. There is no doubt that prevention and management at source must get absolute priority also with a view to enable municipalities to choose the most relevant use of sewage sludge. However, downstream controls and obligations are equally part of the framework to turnaround widespread practices, as was done several decades ago in solid waste sorting. Both approaches are complementary to tackle CECs in the most cost-effective and efficient way.
Equally important, the UWWTD must be aligned with the EU target of carbon-neutrality. We strongly support the development of the suitable metrics, and believe that the choice of instruments/technologies must be left to subsidiarity.
Veolia finally welcomes transparency ambitions and the Impact Assessment provisions on governance and affordability. To enable meaningful public participation in debates at all levels, a limited but comprehensive list of performance indicators is necessary, also with a view to speed-up the deployment of most promising solutions at limited costs for the EU citizens.
Read full responseResponse to Evaluation of the Sewage Sludge Directive 86/278/EEC
24 Aug 2020
Almost 10 Mt of dry matter from municipal sewage sludge are produced each year in Europe, of which a minimum 40% is recycled in agriculture, showing the importance of this route.
Contrary to many other byproducts, the volume of wastewater sludge directly follows the volume of treated wastewater: with sustained ambitions for wastewater treatment, sludge production will keep growing. The quality of sludge, equally, is tightly determined by the goals for treated wastewater and upstream sewer management. Sludge management requires substantial investments, currently amounting € 1.5 Bn annually for the EU27, with a need to keep pace with the final deployment of the Urban Waste Water Treatment Directive (UWWTD), whilst facing the growing need for renewal of the oldest facilities in Western Europe.
The current Sewage Slude Directive (SSD) is an essential part of wastewater management in the EU. This practice has several merits: it is an established circular economy practice, yet the 40% show there is room to do much more, with an agronomic benefit as a soil-enhancement means, through the provision of organic matter, and usual fertilizers (nitrogen and phosphorus). It is a local loop and a cheaper alternative for the farmer, against other sources, and for the wastewater operator, against other disposal routes.
Nevertheless, many Member States deemed necessary to supplement the SSD with a number of tighter requirements, showing that the current framework needs a rigorous updating in light of more recent findings and practices: this concerns parametric values for both the sludge and the soil-impacts, the processes including hygienization or composting, and a whole array of risk-management and traceability requirements: the opening of the revision of the SSD is therefore warranted to take account of such progress and also address concerns with emerging pollutants (micropollutants, microplastics, ..), and the citizen and supply-chain demand for organic products.
Veolia believes this needs both a bottom-up and a top-down approach.
Bottom-up, the SSD would best be recast as a daughter directive of a full-fledged Soil Framework Directive: the later would set a policy for European soils protection, with horizontal goals and a tool box to reach them. We believe that such a framework directive is missing in the EU environmental protection law, and suggest it should be considered under the Green Deal, and more precisely in the Zero-Pollution Strategy. It would also be coherent with the Farm-to-Fork and the Biodiversity strategies.
Top-down, the SSD should provide for different categories of sludge, the best ones above to-be-provided end-of-waste criteria for municipal sewage sludge. The top category should be suitable for organic farming. The EU target of 25% organic farms will need low carbon source of organics, N, P and K, it would be a circular opportunity to include domestic sources instead of imported resources. Beyond this top-category, the EU institutions have the critical mass to develop categories of sludge, like the categories developed in the recent Water Reuse Regulation. In the current context, the suitable end-of-waste criteria should be specified for the top categories, whilst the lower categories should be framed with enough standards to safeguards against environment or health damages.
At Veolia, we believe this dual approach can deliver an SSD that is fit for the 21st century, also setting a timing for an affordable, gradual adaptation of the current assets, though in line with the transition towards a circular, low-carbon, economy.
Read full responseResponse to Review of the requirements for packaging and feasibility of measures to prevent packaging waste
6 Aug 2020
Veolia is the global leader in optimised resource management. With over 163 000 employees worldwide, the Group designs and provides water, waste and energy management solutions that contribute to the sustainable development of communities and industries. Through its three complementary business activities, Veolia acts and contributes to the transition towards a circular and low carbon economy by developing access to resources, preserving available resources, and replenishing them.
According to the European Commission: “the initiative aims to tackle the limited competitiveness of secondary materials from recycled packaging relative to virgin feedstock in view of its quality and availability and to address the increase in packaging waste generation”. We welcome this new market-based, industrial approach to recycling. To waste management companies like Veolia, only resilient markets decoupled from the prices of virgin materials can ensure high levels of recycling over the medium/long run. This approach is already included in Annex IV of the revised Waste Framework Directive which lists several economic and regulatory incentives.
Please find more details in the attached document:
1# Moving towards high-quality recycling: phasing SVHCs out and working on recyclability across the value chain
2# Plastics: tackling plastic pollution and increasing recycling rates should remain a priority
3# Paper and cardboard: Veolia calls for an ambitious European strategy
Read full responseResponse to EU Methane Strategy
5 Aug 2020
Veolia is the global leader in optimised resource management. With over 163 000 employees worldwide, the Group designs and provides water, waste and energy management solutions that contribute to the sustainable development of communities and industries. Through its three complementary business activities, Veolia acts and contributes to the transition towards a circular and low carbon economy by developing access to resources, preserving available resources, and replenishing them.
Veolia welcomes the new EU methane strategy as a way to fight climate change and improve waste management in the EU.
1# Reducing methane emissions: avoiding poor maintenance, upgrading existing sites and moving waste streams upwards the waste treatment hierarchy
As stated in the roadmap, the main source of methane stemming from the waste management sector are the uncontrolled emissions of landfill gas. Therefore, making sure that landfill sites are compliant with the provisions of the landfill Directive (and national regulations) is a prerequisite for better monitoring and abatement of emissions. Regarding enforcement, ensuring a homogenous implementation will be key to decrease emissions for the whole of the EU. Authorities should also take it as a given that upgrading or refurbishing existing sites will require both private investment and public funding to avoid further GHG leakages.
Every Member state is due to make sure that, by 2035, the amount of municipal waste landfilled is reduced to 10% or less of the total amount of municipal waste generated. Since disposal is at the bottom of the waste treatment hierarchy, investments made in higher steps of the ranking will definitely help to reduce both landfilling of waste and associated methane emissions. Investments are especially required for the collection, composting and anaerobic digestion of biowaste.
More specifically, the separate collection of biowaste is due to be implemented across the EU by 2023, which means that methane emissions are expected to significantly decrease. Indeed, methane emissions are directly related to the amount of organic matter found in residual waste streams sent to landfill sites. Veolia strongly supports the organic or energy recovery of separately collected biowaste.
2# Recovering methane: ensuring the development of (1) alternative treatment options for biowaste and (2) energy recovery options for biogas.
1/ Treatment options for biowaste
Besides efficient collection schemes, a dense network of well designed (and maintained) composting sites is key to increase the organic recovery of biowaste while decreasing overall methane emissions.
2/ Energy recovery options for biogas
Landfill gas capture and recovery allow local communities to tap into the energetic potential of biogas by producing heat or electricity. It goes without saying that promoting the recovery of biogas also contributes to reducing GHG emissions as it is used in place of fossil fuels. Injecting biogas into local gas networks for further use is another valuable option that should be fostered. Anaerobic digestion also represents a promising market in which Veolia is ready to invest.
3/ Economic instruments and regulatory drivers
As with any other emerging markets, these technologies need to be supported by regulatory and economic drivers and incentives such as feed-in tariffs for injection or anaerobic digestion. From a regulatory standpoint, more flexibility might be needed regarding the types or origins of waste streams (agricultural or industrial) to be mixed so that the quality of the end product remains steady, in line with regulatory and sanitary requirements. Although these policy options are often dealt with at national/regional level, the EU can act decisively by issuing guidelines, promoting best practices and shedding light on the need for authorities to set up these instruments.
Read full responseResponse to Implementation modalities of the smart readiness indicator for buildings
16 Jul 2020
Veolia, provider of integration solutions for the management of buildings and energy infrastructures sees the establishment of a voluntary European SRI scheme as a positive development and an efficient tool to evaluate the smart readiness of a building or building unit, that is essential in the context of smart energy sector integration dynamic. We also want to underline that the DHC sector has an important role to play in making buildings smarter and more agile. Specifically, DHC has been a facilitator and integrator of different fuels and carriers which could help a building or a building unit become more energy efficient and responsive to the needs of its occupants and wider energy system. Therefore, DHC should be fully accounted for in the SRI calculation.
As for the implementing act, we have the following remarks:
The purpose of SRI is specified as follows: “it will raise awareness amongst building owners and occupants of the value of building automation and electronic monitoring of technical building systems. It will also give them confidence that the new and improved functions can generate costs and energy savings”. As we indicated in our comment to the Delegated act, the SRI should also raise awareness about the value and ability of various heating solutions to contribute to achieving higher score, including efficient district heating networks;
On article 3 of the Implementing Act regarding the accreditation and qualification of smart readiness indicator experts, we believe that energy service companies and utility operators should also be included among the listed experts as having the capacity to deliver such certificates. Indeed, this would provide consistency with revised EPBD, which in article 14 and 15 provides for the possibility to replace regular inspections of building systems by regular evaluations carried out in the framework of energy performance contracting arrangements or by utility operators;
In addition, even if the Act specifies that SRI can include additional information on inclusiveness and connectivity of the building, on interoperability and cybersecurity of systems, and on data protection, as well as on preparedness to climate change, those aspects are not being covered either by the implementing nor by delegated act.
Read full responseResponse to Establishment of a smart readiness indicator for buildings
16 Jul 2020
Veolia, provider of integration solutions for the management of buildings and energy infrastructures sees the establishment of a voluntary European SRI scheme as a positive development and an efficient tool to evaluate the smart readiness of a building or building unit, that is essential in the context of smart energy sector integration dynamic. The SRI should also be a means in achieving a more sustainable, healthier, and less environment impacting European building stock.
We also want to underline that the DHC sector has an important role to play in making buildings smarter and more agile. Specifically, DHC has been a facilitator and integrator of different fuels and carriers which could help a building or a building unit become more energy efficient and responsive to the needs of its occupants and wider energy system. Therefore, DHC should be fully accounted for in the SRI calculation.
With that in mind, we think that the methodology for SRI calculation could be improved. We have identified below the main points which we believe should be addressed in the current Delegated Act and Annex (please see the file attached).
Read full responseResponse to Chemicals strategy for sustainability
19 Jun 2020
Veolia is the global leader in optimised resource management. With more than 170,000 employees worldwide, the Group designs and provides water, waste and energy management solutions that contribute to the sustainable development of communities and industries.
Veolia strongly supports the intention of the European Commission to establish a Chemicals Strategy as part of the zero pollution ambition. We endorse the early thoughts shared by the Commission whereby the impacts of chemicals are assessed ex-ante in a whole life-cycle approach, to enable only safe chemicals, with specific attention to degradability in and removability from water, soil and air, phase out non-essential chemicals, and frame and follow the use of hazardous ones: it must be more costly to pollute than treat pollution. Companies that place (potentially) very harmful substances on the Union market should track-and-trace volumes and emissions of these substances throughout the entire chain, to readily take action when pollution is identified, not waiting for the current, excessively-long, feedback loop whereby substances start being monitored in the environment only ex-post.
As a wide range of substances of concern has been used until recently, phasing them out should be the absolute priority to increase both the quality and quantity of recyclates. Still, dealing with these ‘legacy substances’ will remain a challenge for the recycling industry. Should further recycling of some waste containing legacy substances be envisaged, decontamination et non-dilution should remain paramount and hazardous waste/substances should be treated as such. To avoid dilution, the strategy should encourage separation of contaminated streams, which should be made much easier by recent improvements in traceability (SCIP database). Finally, upholding the principle of decontamination (already enshrined in the legislation) should be regarded as the most efficient way to move towards quality recycling. Indeed, the objective of decontamination is to make sure that substances of concern contained in waste or products are below regulatory thresholds and/or can be safely extracted and disposed of.
To further elaborate on these prerequisites, Veolia would like to stress the following points (more information in the attached document).
#1: Defining and tracking substances of concern in products and waste
1/ A broad definition of substances of concern is needed and should encompass SVHCs under REACH, CLP substances and POPs. If it is relevant, it might also include specific substances under specific product legislation.
2/ Tracking substances of concern is another crucial issue for waste and wastewater operators, as knowing the substances that are embedded in products and waste allows for more visibility and legal certainty on how to treat/recycle them.
#2: Ensuring a level playing field between primary and recycled materials
1/ The waste management industry is striving to achieve a toxic-free material loop by phasing out toxic substances.
2/ EU-produced and imported articles should be subject to the same rules as waste management operators treat and recycle waste regardless of their origins.
3/ The strategy should actively support eco-design policies and the recyclability of products put on the market.
#3: Harmonising and streamlining End-of-waste criteria and implementation
#4: Keeping waste and product classification separate
1/ Waste classification (hazardous/non-hazardous) should neither be aligned with nor inspired by the classification of substances/mixtures under CLP
2/ The hazard-based approach should remain the cornerstone of waste classification
#5: Setting up a pragmatic yet environmentally sound approach to recycling and treating waste containing substances of concern
#6: Applying thoroughly the control at source principle to avoid contaminating wastewater
Read full responseResponse to Strategy for smart sector integration
8 Jun 2020
Veolia has been developing expertise in fostering local energy loops and working right in the sector integration nexus of sectors such as energy, waste and water management. We achieve this by exploring resources such as refuse derived fuel (RDF) from non recyclable waste, waste heat from industries, data centers or wastewater, and biogas from landfills and sludge processing. In our view an effective energy sector strategy should rely on the following elements:
The concept of smart energy sector should go well beyond the narrow understanding of electricity and gas coupling. A truly integrated energy system can reap benefits from both demand and supply side flexibility. With a varied energy mix, it should adapt to different circumstances, needs and seasonality. This should include the following features: flexibility of interconnected systems, featuring energy storage (electric and thermal), merging together electric grid, heating and cooling and (decarbonised) gas networks; minimisation of losses through the application of the energy efficiency first principle; integration of maximum of low-carbon energy sources. This can only happen if we aggregate local integrated energy systems. Hence, a local, district-based approach to energy planning should be fostered to identify and maximise synergies among different parts of energy systems on a given territory.
The heating and buildings sectors have tremendous potential for energy efficiency and cost-efficiency through system integration. In the heating market district heating and cooling networks enable sector integration by creating linkages between different parts of the system and provide flexibility through the means of technologies, which are both already technically and commercially available. DHC networks connect the local level with EU level electricity and gas infrastructure and integrate multiple renewable and waste heat sources, while coupling points with the electricity and gas systems via heat pumps, Combined Heat and Power (CHP) plants and renewable gases produced from waste streams, such as municipal sewage water, or renewable electricity.
Energy Efficiency Services also play a key role and have a huge cost-effectiveness potential across different sectors, including the building sector, which will be central in the dynamic of the future energy system integration. The optimisation of buildings’ energy consumption, thanks to renovations and effective energy management, can indeed support the further uptake of renewable and recovered energies booths at building and district levels. The same can be said for the optimisation of energy consumption in industrial sites and platforms, where EES can enable energy efficiency gains and enhance circularity.
There is huge and unexploited potential of renewable gases: renewable gases create a link between the waste and energy sectors. The share of RES gases which will be available in the future should be used in the most efficient way, in those sectors which are particularly difficult to decarbonise otherwise. On the heating market, RES gas should be used in priority in CHP plants - and not in individual boilers.
Circularity of our energy systems is an essential factor for a successful and efficient energy sector integration: Waste heat recovery is a prime example of a circular and integrated approach to resources management as recovered heat would otherwise be lost. The challenge today is to upscale the waste recovery project. Similarly there is significant potential for the use of Refuse Derived Fuels as well as recycled wood in a truly integrated and circular system.
In the file attached, we present several illustrations of the above points with concrete projects we have been developing.
Read full responseResponse to Commission Communication – "Renovation wave" initiative for the building sector
8 Jun 2020
Veolia welcomes the roadmap on a Renovation Wave initiative presented by the European Commission and fully supports its ambition of boosting the energy efficiency and the renovation rate of the building stock in Europe. We believe that to reap the benefits of renovation potential and various synergies it can generate, upcoming communication should cover the following aspects:
Building renovation should go hand-in-hand with decarbonisation of the heating and cooling systems
All efforts put in enhancing the existing buildings stock thermal envelope should be done at the same time as modernisation and decarbonisation of the heating and cooling solutions. Buildings are indeed the first consumer of the H&C sector and space heating. In this realm, district heating plays and will continue to play an essential role as one of the most effective and economically viable options to reduce the heating sector’s dependence on fossil fuels and cut down CO2 emissions. DH&C networks are suited to feed in locally available, renewable and low-carbon energy sources. The ability to integrate diverse energy sources means customers are not dependent upon a single source of supply.
District heating networks enable also a form of “energy solidarity” between producers of low-carbon waste heat from data centers or commercial centers and more vulnerable clients often suffering from energy poverty.
Building renovation should take place at the level of a district
The initiative should plan for comprehensive renovations (including efficiency measures on the demand and supply side) taking a district or neighborhood perspective. Such approach has the merit of providing a clearer overview of the needs of each particular district and allows for more efficient energy planning. It can help capture interdependencies between supply and demand and exploit many synergies that can be only identified if a holistic planning to energy takes place.
Building renovation should also include deep staged renovation, with a significant role for Energy Efficiency Services
Energy efficiency services (EES) typically provided by ESCOs, such as energy performance contracts (EPCs) represent a necessary complement to renovations. To be the most effective, such EES have to be based on the following features: explicit and verifiable commitments; financial guarantes for the clients if energy savings are not achieved; technical tools to make sure the energy savings announced have been achieved.
Building renovation should also be an opportunity to improve indoor air quality
The Initiative is an opportunity to reinforce EU requirements regarding air quality when buildings are being renovated. Indeed, not factoring in indoor air quality when renovating can rapidly lead towards degradation of the building stock and serious risks for health of the occupants.
This could be achieved in particular through a proper implementation of the Energy Performance of Buildings Directive. Also, the EPBD could be reinforced with the introduction of IEQ criteria/indicators which shall be reported in a transparent way in the energy performance of buildings certificates.
Building renovation should be facilitated with adequate financing
The Initiative should be funded from the EU Recovery Plan with specific ring-fencing and tailor-made instruments. All funding available for renovation purposes should be conditioned upon the following:
Energy Efficiency First should be the absolute guiding principle;
A particular attention should be paid to cost-effectiveness consideration for each investment conceded. This implies prioritising solutions based on criteria such as the cost per unit of energy saved;
Special bonus should be planned for investments enabling real energy savings over time;
Renovations planned at the level of a district should also benefit from specific and targeted support.
For mode details, please see the file attached.
Read full responseResponse to EU rules on industrial emissions - revision
21 Apr 2020
Veolia is the global leader in optimised resource management. With over 170,000 employees worldwide, the Group designs and provides water, waste and energy management solutions that contribute to the sustainable development of communities and industries. Through its three complementary business activities, Veolia helps cities and industries increase their sustainability performance and reduce their environmental impact. Please note that our comments below were already submitted in September 2019 during the first phase of the consultation.
The Industrial Emissions Directive (IED) aims to reduce emissions coming from large industrial facilities through an integrated approach. Studies have shown that emissions of major pollutants have decreased significantly over the past decade in the EU. Veolia welcomes this public consultation and sees it as an opportunity to share its expertise to feed into the Commission’s work as we believe the existing framework, although very effective, could be further improved.
To be fully successful, environmental protection requires a long-term approach. Veolia considers that the “polluter pays principle” should be implemented more consistently in all EU Member States. Indeed, polluting should cost more than removing the pollution and revenues generated by those who pollute should be dedicated to finance those who depollute. To ensure effective implementation of this principle, a better control at source and an effective monitoring system at local level can help prevent the emission of pollutants and optimise the existing schemes of environmental protection.
While the IED has had a positive impact on the EU competitiveness, its enforcement should be more harmonised across all Member States. This would ensure a level playing field between all industrial operators regardless of their geographic location. Local interpretations can diverge quite significantly, leading sometimes to situations where similar installations based in different Member States might be subject to different obligations. We believe the current implementation of monitoring provisions at Member State level is not efficient enough and could be further improved.
Some industrial installations fall outside of the scope of the IED due to their capacity that are below the thresholds set in Annex I (e.g. thermal input below 50MW for combustion plants), which can result in unfair competition between small and large installations. This is the case for instance in waste treatment as well as in district heating. Moreover, some sectors are excluded from the list in Annex I which means they are not subject to the obligations of the Directive. We believe all industries in Europe should operate on an equal footing by following the same rules.
When replacing the old Integrated Pollution Prevention Control Directive (IPPC), the IED has made BAT Conclusions mandatory, and introducing BAT-AELs strict boundaries from which emission limit values (EVLs) are derived. Veolia strongly supports the binding approach of the IED, which has enabled this instrument to be much more effective in achieving its objectives.
Reusing and recycling industrial waste water would also contribute to lower substantially the pressure on the available water resources. Moreover, promoting the reuse of treated waste water by industrial installations in the scope of the IED would also contribute to the transition towards a circular economy. Industrial water reuse provides an important opportunity for industry to reduce freshwater abstractions, while at the same time minimising the amount of treated waste water discharged into European water bodies.
To conclude, as the IED has been quite effective in reducing industrial pollution, we consider the framework still fit for purpose, even though there is still room for improvement. We think harmonised implementation and better enforcement of the provisions set out in the IED would be an effective priority to attain the objectives.
Read full responseResponse to 2030 Climate Target Plan
15 Apr 2020
Veolia welcomes the EU ambition to become carbon and climate neutral by 2050 and to enshrine it in the form of a Climate Law. In the light of this target, we also support the need for the revision of the 2030 target for the reduction of greenhouse gas emissions to move from the current 40% to minimum 55%,. This is particularly justified and should be reinforced in the context of linking the post COVID19 economic recovery with the climate and energy policies that should be maintained given their ability to generate growth and jobs.
As a services provider implementing energy efficiency and environmental solutions for municipal, industrial and commercial clients, Veolia is of the view that a clear and urgent transformation of the energy system is needed in the next decades. This dramatic transformation will need the following:
Guiding principles: Energy Efficiency First principle should be mainstreamed in all EU climate and energy policies. Its implementation and operationalisation should be elaborated and explained to all relevant stakeholders. In addition, the future climate and energy policies should mainstream smart sector integration and circular economy in order to maximise synergies and linkages between various infrastructures and fuels and parts of the existing systems, and optimize the use of all available resources. Putting those principles together will help us achieve maximum cuts in CO2 emissions needed for 2030. The financing instruments should also reflect and be made conditional upon the respect of those principles.
Going district and local: our energy transition and recovery efforts need to be carried out with careful planning and mapping done at the level of a district. This is the only way to match actual energy resources to the exact amount of demand on a given territory. By devising local recovery and transition plans, we will be able to tap on the potential of such decarbonization solutions as efficient district heating and cooling networks, which can integrate not only available renewable energy sources but also waste heat from industries, data centers and tertiary sector and heat from waste (including refuse derived fuel). This is also the place for deployment of simultaneous and local production of heat and electricity through cogeneration. Those energy producing solutions are not only low in carbon but also ensure the flexibility and stability to the entire local energy system. They will then be delivered to insulated, optimized and smart buildings - renovation of which can be scaled up and better financed if made at a level of a territory.
Finding the right CO2 signal: one of the biggest challenge of the transition and recovery will be financing of all the necessary investments. For that to happen, we will need the adequate CO2 signal, which might require defining an EU carbon price floor for the EU ETS as well as reforming, in depth, the Energy Taxation Directive to set minimum and homogenous taxation rates for fuels used for heating and electricity production based on their energy and CO2 content.
Ensuring a just transition for all: an ambitious 2030 target needs to accompanied by bold financing means to enable the transition as well as a fair burden sharing mechanism, including compensatory measures for Member States whose economies depend on coal and whose GDP/inhabitant is below EU average. The different starting points and commercial availability of key transition technologies in each Member States have to be taken into consideration, and where and when the transition is the most necessary and costly, adequate funding is to be provided through different instruments, including but not restricted to the European Green Deal Investment Plan for 2021-2030, and the Just Transition Fund.
Read full responseResponse to Revision of the Energy Tax Directive
1 Apr 2020
Following the publication of the EU Green Deal in December, the Commission has announced the revision of the Energy Taxation Directive (hereafter “ETD”). The 2003 Energy Taxation Directive is obsolete and needs to be reviewed so that it provides an effective framework to Member States to reach their decarbonisation targets and facilitate a smooth functioning of the internal market. A revised Directive is also prerequisite to make the Green Deal a success and make Europe the first “climate-neutral continent” by 2050. In this context, Veolia welcomes the Commission’s Roadmap for the revision of the ETD. Our comments and recommendations can be summarised as follows:
The EU energy tax regime should be reformed in line with its current climate ambitions (2030 and 2050 targets) , which will require a CO2 and energy content based minimum rates. The proposed revision should enable a consistent treatment of all energy sources to provide a genuine level playing field for energy consumers, as well as steering their choices towards decarbonised fuel options and energy efficiency. This could be achieved by setting minimum taxation rates for fuels used for electricity and heat production based on energy content and CO2 emissions, with an equal taxation for competing products. The minimum level of the taxation, especially the carbon component should be set at a level sufficient to reflect the GHG externalities of fossil primary energies. Such taxation would ensure fairer prices against renewable energies and thus support their development.
There is a need for a reformed energy taxation, which will ensure a level playing field and result in decarbonisation of the hating sector. Heating & Cooling represents today 50% of energy consumption and its decarbonisation is one of the main challenges of the current energy transition. This process requires the creation of a real level playing field across the entire H&C market. A harmonized minimal CO2 price should be introduced for fossil fuels used for heating purposes in installations (below 20 MW capacity) not included in EU ETS with a regular update to account for the evolution of prices for CO2 allowances. Member States should be allowed to set out the price of CO2 at a higher rate in line with their own level of ambition and choice of policy instruments to transform the heating market. This would create a level playing field between installations covered by the EU ETS and the small, individual installations outside of the EU ETS scope, which represent the largest chunk of the heating market and are the most polluting. By the same token, any double taxation should be avoided; that is fuels used for heating in installations covered by EU ETS should be automatically exempted from CO2 tax or the tax should be fully refundable. Last but not least, barriers of fiscal nature to the further use of waste heat/cold from industry and the tertiary sector should be identified during the review process and dismantled by the new directive.
Energy Efficiency First principle should be a guiding principle for a revised European energy tax regime. The new directive should facilitate the realisation of this principle as it will define market conditions for future investments in fuels, and consequently supporting infrastructures. One of the solutions, which is coherent with this principle is the simultaneous production of electricity, heat and cold in cogeneration facilities.
The revised ETD should foresee a mandatory exemption for energy products and electricity used for High-Efficiency CHP (as defined in Directive 2012/27/EU) from the excise tax or the tax should be fully refundable. This is the only way to avoid a clear preference for investment is largely less efficient separate production of electricity.
Read full responseResponse to Farm to Fork Strategy
16 Mar 2020
Veolia is the global leader in optimised resource management. With more than 170,000 employees worldwide, the Group designs and provides water, waste and energy management solutions that contribute to the sustainable development of communities and industries. Through its complementary business activities, Veolia intends to become the benchmark company for ecological transformation by helping cities and industries reduce their environmental footprint, while increasing their economic and sustainability performance.
We imagine innovative solutions to anticipate and satisfy the essential needs of tomorrow maximising our positive impact wherever we act and for all our stakeholders. We have notably developed answers to emerging needs concerning the food chain: converting organic waste into organic fertilisers or animal proteins and developing aquaculture, urban agriculture solutions and intelligent water reuse for agriculture as well as improving the taste of drinking water. The attached note summarises our know-how and policy recommendations relevant to the EU Farm-to-Fork Strategy.
How do we feed almost 10 billion people in 2050? With the population growth and the middle class expansion, it is estimated that by 2050 it will be necessary to increase global food production by 50%. Urbanisation and climate change are increasing the pressure on arable land, whose quality and availability are inexorably deteriorating. Ensuring the best food coverage, while diminishing the pressure on the necessary resources in land, energy, water and intrants, is the challenge. Veolia strongly welcomes the Farm-to-Fork Strategy which will be critical for making our food supply chains more sustainable while bringing economic, social, health and environmental benefits.
Overall, Veolia's recommendations (detailed in the attached document) aim to fully close the loop of the circular economy across Europe by:
(1) Making food packaging more sustainable (ease recycling, standardise packaging, impose minimum recycled content);
(2) Tackling food loss and food waste (convert organic waste into clean energy or fertilisers);
(3) Optimising water and energy use in the agri-food industry (reuse treated waste water for industrial processes, recover industrial effluents through anaerobic digestion);
(4) Enhancing soil protection (facilitate environmental reporting, develop marketplaces enabling offsets to be sold as carbon credits);
(5) Facilitate the development of sustainable food production models such as urban farming and aquaculture;
(6) Supporting research and innovation in those fields (ensure sufficient funding, promote exchange of practices).
Read full responseResponse to Fast-track interservice consultation on the 'SEIP including a JTM and the JTF"
12 Mar 2020
On 11 December 2019, the Commission adopted a Communication on the European Green Deal, setting out its roadmap towards a new growth policy for Europe. In line with the objective of achieving EU climate neutrality by 2050 in an effective and fair manner, the European Green Deal proposed a Just Transition Mechanism, including a Just Transition Fund, to leave no one behind. Veolia welcomes this initiative as there is an acute need for an instrument to help manage the necessary transition, which inevitably will lead to significant structural changes. Below we put forward comments regarding the Proposal for a regulation of the European Parliament and of the Council establishing the Just Transition Fund.
Not just a transition but a just transition inscribed in a territory:
The implementation of the Just Transition Fund should be accompanied by smart redistributive policies, based on tailored schemes following the “polluter pays”. The use of the Just Transition Fund should ideally be designed in such a way so as to help all relevant territorial units and their inhabitants affected by the transition. Decarbonisation will have to take place at level of regions, cities and districts. Territorial units that are the most relevant for an efficient energy planning strategies (to carry out energy transition) should be targeted as funding recipients. This will also enable the concretisation of the sectoral integration by promoting the need to identify and exploit synergies among various infrastructures and energy systems.
Necessary clarification of eligibility criteria for potential projects:
Because of their efficiency and decarbonisation potential, as well as their capacity to prevent the spread of energy poverty, district heating and cooling networks should be explicitly mentioned as eligible infrastructure within the Just Transition Fund. We advocate in particular for: support for DHC networks not only through EUInvest leg but also the other two pillars of the JTM (including Just Transition Fund so as to enable eligible projects to benefit from investment support in the form of grants); Support for both generation capacities (including CHP and large heat pumps and waste heat recovery facilities ) as well as networks (pipes) to limit heat losses and make them more efficient (through the use of digital tools); Support for both for existing (so that they could achieve high efficient status) and new networks; Funding made conditional upon development of local (district) energy plans, fully coherent with the territorial transition plans defined in the regulation proposal.
Given the weight and importance of energy efficiency, Energy Efficiency first principle - one of the five pillars of the Energy Union - should guide all relevant EU energy and climate related policies as well as technical and financial tools to underpin those strategies, including the JTF. The principle informs all energy infrastructure decisions by requiring the consideration of demand options as alternatives for investing in generation, transmission or distribution infrastructures. But it also means the optimization of the supply side, through the use of already available technologies and solutions. Examples include cogeneration and energy performance contracting. Hence, high efficiency CHP facilities based on low carbon fuels should benefit from the support through JTF, especially if their development and modernization is inscribed in the territorial transition plans. In addition, Energy Performance Contracting should also benefit from financing through the JTF, given this specific type of contracts ensure Energy Efficiency First principle is implemented across the entire energy value chain (on the supply and demand side) and the actual energy savings are being evaluated and guaranteed.
For more details on those proposals, please see the note attached.
Read full responseResponse to A new Circular Economy Action Plan
20 Jan 2020
VEOLIA calls for a systemic transition towards water, material and energy efficiency. Further developing existing policies could encompass the following:
Accelerating the transition towards quality recycling (and carbon neutrality)
The inclusion of C&I waste in the existing set of quantitative targets would boost open markets and increase the supply of high-quality recycled materials.
Recycling works as an input-output model, which means that the most environmentally-friendly and cost-efficient way to address quality issues is to make sure that recyclability is taken into account.
Fostering design-for-recycling would require to demonstrate that a technically feasible, environmentally sound and economically viable treatment option exists. We believe that standardisation and bodies providing guidelines for new types of packaging could help. While new useful materials might emerge, their overall impacts on the environment and existing infrastructures should be assessed before placing them on the market.
Substances of concern have been used until recently, phasing them out should be the priority to increase both the quality of recyclates. Still, dealing with these ‘legacy substances’ will remain a challenge for the recycling industry. Decontamination and non-dilution should remain paramount and hazardous waste should be treated as such.
Fostering EU markets for secondary raw materials, and local energy loops
A strong market signal would be to take into account the negative externalities of virgin materials (by using taxation and/or the price of CO2) and/or monetise the positive externalities and reduced environmental footprint of S, such as avoided emissions.
It is crucial to ensure a strong, steady demand for SRM even when fluctuating prices of virgin materials negatively affect the market. We welcome the individual and collective pledges but we deem necessary to be more ambitious and define mandatory recycled contents for products in key sectors. Combined with fee modulation under EPR schemes, Green Public Procurements and fiscal tools, these recycled contents would greatly incentivise the use of SRM and tilt value chains towards better material efficiency.
Finally, there is a need for affordable treatment options for the non-recyclable fraction produced by sorting/recycling plants: high treatment costs lead to higher prices, thereby decreasing the competitiveness of SRM. In accordance with the waste treatment hierarchy, energy recovery should be the preferred option, which is also in line with the overall climate and energy goals of the EU. Refuse-Derived Fuels thus represent an obvious alternative to fossil fuels as their calorific value is high and they avoid emissions linked to extraction and refining of fossil fuels. Waste-to-energy plants should also be considered to treat residues from recycling processes. The current attempt to divert much-needed private and public funding from WtE projects is, therefore, worrisome.
Promoting circular water management
Growing population combined with climate change are rapidly accelerating the disruption of the hydrologic cycle thus creating important issues of freshwater scarcity. Europe must shift towards a circular water management model by reusing and recycling treated wastewater. Reusing treated wastewater for agricultural, industrial or even municipal purposes could help address water scarcity. For this reason, Veolia advises in favor of an ambitious regulatory framework that further encourages water recycling in all sectors where it is relevant. The new Water Reuse Regulation for agricultural irrigation has sent a first positive signal.
Concerning sewage sludge, all recycling and reuse options should be encouraged including recovery into fertiliser, compost and biomass as long as it meets strict health and environment standards. The revision of the Urban Waste Water Treatment Directive could help close the loop on this matter.
Read full responseResponse to Fitness Check on endocrine disruptors
10 Jul 2019
The EU's strategic approach to endocrine disruptors for the coming years should be based on the application of the precautionary principle and aim to:
- minimise the global exposure of people and the environment from endocrine disruptors, paying particular attention to exposures that occurred during the essential phases of the body growth, such as fetal development and puberty;
- accelerate the development of a comprehensive research base for effective and forward-looking decision-making;
- and promote an active dialogue allowing all stakeholders to be heard and work together.
1) Endocrine disruption testing and screening
There is clearly a lack of funding and a lack of methods for assessing the EDC character of a substance. The scientific expertise needs to be further developed and the necessary resources put in place. EDCs can alter the endocrine system in various ways (different mechanisms of action). We should agree at European level on a panel of bioassays that covers the different mechanisms of action of EDCs described by scientists. Moreover, we should encourage the use of in-vivo testing to predict early effects on human health and ecosystems.
2) Paying attention to cocktail effects
Many research programmes and environmental monitoring have shown that aquatic environments are contaminated by several families of micropollutants (including EDCs). Endocrine disruptors induce adverse effects at very low thresholds, most often below the detection threshold of advanced analytical equipment. It is time for regulatory authorities to change paradigms and move beyond the measurement of particular substances. The development of bioassays of EDC activity for monitoring the environment is necessary.
3) Evaluating the effect of the combined exposure of different sources of exposure
4) Specifying a timetable for action
Act quickly, data collection and quality assessment are certainly a necessary step, but the European Commission must consider that EDCs are molecules that most often have chronic toxicity, so a clear action plan is needed to avoid the costs of inaction.
5) Strengthening current legislation
The European Commission has launched an evaluation to assess whether current EU legislation related to chemical safety has achieved its overall objectives. There is increasing evidence of toxic stress in large European basins that is causing the disappearance of susceptible species and this is only partially covered by the chemical status under the WFD and the priority monitoring of pollutants. It is urgent to cover all exposure routes and all matrices: air, water and soil.
6) Implementing the EU Circular Economy Strategy
Acting for a circular economy without EDCs. The prohibition of EDCs in plastics could be a solution as this is a brake on their recycling streams.
7) Updating REACH Regulation
Review the principle of tonnages. In fact, EDCs are molecules that harm human health and ecosystems at very low dose. The EU should impose REACH for chemicals whose quantities placed on the European market exceed a certain tonnage (overall) and not a tonnage per supplier. So far, very few substances are identified as EDCs by REACH.
Read full responseResponse to Methodology for assessing the potential for efficient heating and cooling
10 Jan 2019
Veolia welcomes the European Commission’s initiative of the present review and to strengthen the framework on the promotion of efficiency in heating and cooling under article 14 EED (2012/27/EU). Reviewing the assessment rules in the related annex VIII EED and taking into account technology and policy developments as well as the lessons learnt in the first reporting period can indeed provide the necessary push to seize the vast potential of efficient District Heating and Cooling and Combined Heat and Power solutions, in line with the the EU Strategy on Heating and Cooling and growing consideration of heat and cold in the recently revised renewables directive. However, the reviewed annex should reflect as much and as closely as possible technological and political progress and lessons learnt from the most recent assessment exercise in order to ensure its adequate implementation. Hence, we would like to bring the attention to the following aspects that should be adjusted in the draft of annex VIII.
Separation of heating and cooling: Heating and cooling demands as well as the technologies to cover these demands are of a very different nature. To guarantee that cooling is taken into account in the national assessments we want to suggest to list cooling (technologies) under a separate point to be inserted as point 2 (a bis).
Differentiation of supply options: The current differentiation of options under point 2 (a) is unclear as it is not exclusive and allows for various competing ways of reporting and could also lead to double counting. To remedy this eventuality, we want to suggest a new list that a) reflects the difference between onsite and district energy solutions and b) ensures that all viable options can be reported in a clear and distinguished way.
Consideration of power-to-heat potentials: Using renewable electricity in District Heating and Cooling is an option that can contribute to the decarbonisation of heating and cooling. Accordingly, we suggest to add this highly relevant area with a focus on the utilisation of renewable electricity used in heat pumps or boilers in district energy systems and to add the respective point in point 2 (a). The same is relevant for part III point 7.
Consideration of waste heat: While we are glad to see an explicit reference to waste heat in the recently revised Renewable Energy Directive, it needs to be ensured that the reporting on this source of energy follows the new definition of waste heat included in REDII. Thus we suggest to include a new point 2 (b) vi ‘tertiary sector, according to Art. 2 (9) RED II, other than specified under point 2 (b)(iii);’. The same is the case respectively for part III point 7 (a).
Consideration of ambient heat: Ambient energy can be used through heat pumps but also in other manners, as illustrated in the new definition of ambient heat in the Renewable Energy Directive. The point 7 (e) should be modified accordingly to enable maximisation of ambient heat use, not limited to heat pumps.
High-efficiency cogeneration: High-efficiency cogeneration is one of the essential building blocks of efficient District Heating and Cooling as established in the respective definition of HE DHN in the Energy Efficiency Directive. It is also part of DHC-related articles 23 and 24 in the REDII. For the sake of consistency it is key that the new reporting obligation in point 2 (c) is not just limited to the shares of renewable and waste heat and cold as demanded. The share of CHP should also be included in that point to ensure the maximum potential of efficient DH&C is assessed.
Consideration of refurbishing DHC: The potential of DHC refurbishment across Europe must not be underestimated. We support the notion of DHC improvements in part II point 5 but we advocate for the explicit mentioning of the list considered in the Governance Regulation.
All suggestions are made available as comments directly in the draft annex in a separate document.
Read full responseResponse to Evaluation of the Industrial Emissions Directive
4 Dec 2018
The Directive on industrial emissions is the main legal tool to tackle air pollution and mitigate industrial emissions in the EU. It should be noted that it has also inspired similar legislations outside of the continent. As a company dealing with environmental services, one of our main missions is to reduce the environmental impacts of both our municipal and industrial clients by optimising their waste, water en energy management. The uptake of state-of-the-art technologies is also a strategic priority for us, as we operate plants which fall under the IED.
Please find hereafter the main points we would like to raise regarding the proposed items of the evaluation Roadmap of the IED Directive.
Added-value from the IED is, compared to what is likely to have been achieved by Member States in its absence:
The IED Directive and the former IPPC Directive have been instrumental in harmonising industrial emissions in the European Union, thereby creating a level playing field in Europe, fostering innovation and triggering required investments in specific cases.
The extent to which the IED objectives still correspond to the needs of the EU and whether the IED is able to respond to new or emerging environmental issues:
Cross-media effects (defined as a reduction of a pollutant emission to one environmental medium resulting in increased emissions of other pollutants) should also be taken into consideration as the impacts on water or waste generation, for instance, are also part of other environmental objectives. Fragmented environmental policies can lead to adverse effects and it is crucial to consider the environment as a whole when issuing a permit and/or implementing BATs.
Significant differences between Member States in implementation:
Holding a permit should remain compulsory and making sure that requirements stemming from this permit are properly enforced is also key.
The process of elaborating BREFs and BAT Conclusions:
This process, known as the “Sevilla process”, is at the core of the review of BREF documents and guarantees a dialogue between various stakeholders within Technical Working Groups (Commission officials, Member States, Industries and civil society). Although this process could be improved, it should remain the basis on which BREFs are elaborated/reviewed as it enables the exchange of information and actual data, as well as scientific assessments of the accuracy and the representativeness of data.
The extent to which the IED is internally consistent and coherent:
Veolia would like to point out the fact that we currently have two sets of regimes pertaining to Waste Incineration: the former Waste Incineration Directive in the annexes and the new regime of the Waste Incineration BREF. This might create discrepancies when enforced at local level and by local authorities.
Read full responseResponse to Revision of the Drinking Water Directive (RECAST 2017)
27 Mar 2018
Veolia welcomes this proposal that aims at improving water quality, access to water, and sustainability of its use by improved service efficiency and information to the consumer.
As service provider to public authorities across Europe and beyond, Veolia is ready to contribute to the debate with its expertise and experience.
RECOMMENDATIONS:
The EU, Member States, and local authorities have almost 20 years of experience with the current directive and we acknowledge the progress achieved with its implementation, which took a lot more than the mere transcription work.
The proposals seem quite ambitious, yet they are necessary to meet citizens’ expectations (access, health, information). They are without doubt within reach, provided the legislative process anchors them in a concrete setting.
- Access to water:
The new Article 13 is the major change in the scope of the directive. To drive the EU towards the full coverage, quantitative targets and standards must be developed, as local authorities need legal certainty and guidance to swiftly deploy the suitable means.
The directive could create a framework for reporting on this article, as requested by the Sustainable Development Goals. Developing an EU framework would mutualise efforts, clarify this reporting and avoid the current use of very disparate proxis.
- Parametric values:
We recommend that the thresholds align as closely as possible with those of the World Health Organization. The Annex I deserves precisions and rewording, e.g., for PFAS, the directive should be more precise, as some sub-categories have no health relevance.
The new Annex I repeals the former table C “indicator parameters” (aluminium, ammonium, turbidity, color, coliform, colony count etc.), yet water suppliers are requested in the new Annex IV to communicate such results to customers. We recommend that the proposal keeps Table C to retain the confidence of customers, which is a paramount objective of the recast.
- Derogation:
The proposal repeals the current provision for derogation. If this is confirmed, 10 years should be granted to Member States to comply with new parametric values.
- Sampling frequencies
The sampling frequencies (Annex II) should remain proportional to the population size, as provided in the current drinking water directive.
- Risk-based approach to water safety (Art. 7):
The risk-based approach is state of the art. The Directive should request Member States to designate the authorities in charge of the implementation of respectively part 7.1. a), b) and c), and their scope. For example, the scope of the supply risk assessment needs to be clearly defined : from the point of abstraction to the point of delivery to the domestic distribution network.
- Resources (Art. 8):
The hazard assessment of bodies of water used for the abstraction of water intended for human consumption should also cover the sufficiency of water quantity to cover the needs, especially with regards to climate change impacts. Provision of the new article 8.3-a (additional treatment for some other parameters) are redundant with article 5.2, whereby, a Member State should add new parametric values, as appropriate.
- Domestic Distribution Risk Assessment (Art. 10):
The Article 10 of the current directive is the basis for the development of authorisations for materials in contact with drinking water from source to tap, and is needed by the proposal’s approach to control for Acrylamide, Epichlorohydrin and Vinyl chloride (Annex I part B). We therefore recommend to keep the current article 10, which provides more legal certainty than the proposal.
- Information to the public:
The proposal responds to the lack of awareness of the public about water matters, which everyone deplores. As the current wording would leave local authorities improvising their information, we recommend the inclusion of a common set of indicators at EU level.
Read full responseMeeting with Silvia Bartolini (Cabinet of Vice-President Miguel Arias Cañete)
14 Nov 2017 · Energy Efficiency / Energy Performance of Buildings
Meeting with Stig Joergen Gren (Cabinet of Vice-President Andrus Ansip) and E3PO - European PPP Operating Companies in Infrastructure and Services
19 Jun 2017 · Accessibility and re-use of public and publicly funded data
Meeting with Daniel Calleja Crespo (Director-General Environment)
11 Oct 2016 · Economie circulaire, en particulier la gestion de l'eau et des déchets
Meeting with Dominique Ristori (Director-General Energy)
11 Oct 2016 · Energy issues
Meeting with Antoine Colombani (Cabinet of First Vice-President Frans Timmermans), Bernardus Smulders (Cabinet of First Vice-President Frans Timmermans) and
7 Jul 2016 · Lunch Debat Grandes Entreprises Françaises - Better Regulation.
Meeting with Daniel Calleja Crespo (Director-General Environment)
7 Oct 2015 · Circular Economy
Meeting with Mathieu Briens (Cabinet of Commissioner Christos Stylianides)
16 Jul 2015 · Engagement de la fondation Veolia dans le domaine humanitaire