Fitness check – energy security architecture

Statkraft is Europes largest producer of renewable electricity. In our view it is fundamental that the EU energy security framework recognizes the importance of maintaining the fundamental features of the power market, including the marginal pricing principle, which makes sure that available resources are used in an optimal and efficient way, also when energy security is in question.

Securing locally-produced renewables through enabling renewable energy communities is key to reaching an affordable, clean energy supply. From offshore wind, to large-scale district heating projects, energy communities, which bring together citizens, small and medium enterprises, and local authorities, are already demonstrating that local communities can take an active role in driving the EUs decarbonisation and…

Tree Energy Solutions (TES) welcomes the opportunity to provide feedback on the EUs energy security architecture and specifically the Gas Security of Supply Regulation and the Electricity Risk Preparedness Regulation.

Despite increased awareness on energy dependency issues following the 2022 Russian gas crisis, the EU remains exposed to significant energy and strategic vulnerabilities.First, the EU is almost entirely dependent on imports for its oil and gas consumption 97.7% and 98%, respectively, in 2022. This imbalance places Europe in a position of major geopolitical dependency.

NGV welcomes the opportunity to provide its views to the EC consultation on the EU energy security architecture. Energy networks will be a critical enabler for the clean energy transition. However, the scale and pace of investment needed to meet the UK and the European decarbonisation targets will be unprecedented.

Forum Energii welcomes the initiative of the European Commission to review the energy security architecture. We have repeatedly pointed out that this framework should be updated and modernise. Forum Energii has been working with the partner think tanks in 2024 on a report addressing this issue, set to be published in the coming weeks.

There are not enough investments followed by the non-adequate production of the Net-Zero Industries in the EU. The EU is currently too much dependent on the solar PV production import mainly South-East Asia and China in particular. This overdependency creates energy security risks for the EU electricity sector and the entire transition towards low-carbon economies.

Subject: FEDENE's Contribution to the Fitness Check on the EU Energy Security Architecture In this note, FEDENE presents its contribution to the call for evidence regarding the evaluation of the EU's energy security architecture. We aim to support the Commission's efforts in ensuring a resilient, sustainable, and adaptable energy framework for the Union.

EU should follow the example of most risk-averse EU Member States (eg. Poland), which turned out to be well prepared for extreme risks such as war in Ukraine. Specifically, filling trajectory should be continued and storage obligations should be strengthened (or at least not diluted by the EC).· Many synergies made possible by the gas sector for the electricity sector (also including low-carbon and renewable energy)…

In response to the invitation of the European Commission to participate in the assessment of the adequacy of the EU energy security architecture, we are sending below the comments and opinions of the Reform Institute: Conducting the current assessment of the EU energy security policy (based on the criteria of effectiveness, efficiency, coherence, adequacy and EU added value) only on the basis of the revision of EU…

Given Switzerland's central geographical position in Europe and its crucial role as an electricity hub for the synchronous grid of continental Europe, as well as its key role in trans-European gas and (future) hydrogen flows, EU-Swiss cooperation on energy security is of great importance for ensuring European security of supply.

The European Environmental Bureau (EEB) welcomes the opportunity to provide feedback and call on the European Commission to prioritise people and nature when revising the EU's energy security architecture, based on the following key principles: (1) LNG is just prolonging our fuel dependency neither Russia nor the US should be considered reliable partners.

Bellona welcomes the Commission's decision to undertake an evaluation of the EU's energy security architecture and the opportunity to provide feedback. We believe it is important to emphasise that greater energy security goes hand in hand with the climate challenges that must be addressed to combat climate change.

IOGP Europe is the Brussels-based policy arm of the IOGP and is the center of its advocacy activity. We advance the views and position of oil & gas E&P companies to international and EU regulators, legislative bodies, and other relevant stakeholders. Our members account for 90% of Europes oil & gas production.

As Europe advances toward climate neutrality, addressing energy security challenges - rising energy demand, intermittent renewable generation, supply risks, and growing reliance on electrification - is critical. A demand-reduction-focused approach is essential for creating a resilient, cost-efficient energy system aligned with the EUs Fit for 55 objectives.

Enclosed please find an accompanying document to our response to the questionnaire, outlining the need for Europe to update its security of supply strategy and highlighting the key elements that should be considered. Eurelectric is currently working on a flagship study, titled Redefining Energy Security, set for launch in February 2025.

Solar Heat Europe (SHE) is the trade association representing the solar thermal value chain across Europe. Its members are committed to promoting sustainable energy solutions, harnessing solar energy for heating and cooling, providing reliable and renewable energy to homes and industries.

In response to the call for evidence and the public consultation Fitness check evaluating the EUs energy security architecture initiated by the European Commission, the Ministry of Energy of Ukraine would like to share the following feedback, which is herein attached.

Goals of the EU Architecture for Energy Supply Security Comments: Devices connected to the internet require software updates to remain secure. For the software update, the manufacturer has full access to all functions of the device. This could therefore introduce unwanted additional functions, such as Synchronised Shutdowns, which could be geopolitically exploited by other states.

Filed in German · English published by the European Commission

Recent geopolitical crises and heightened climate risks have underscored the urgent need for a resilient and independent EU energy security framework. While the EU has made notable advances in reducing fossil fuel imports following the Russian invasion of Ukraine, the reliance on other non-EU countries remains a significant vulnerability.

CEWEP, the Confederation of European Waste-to-Energy Plants, is the umbrella organization representing both private and public owners and operators of Waste-to-Energy plants across Europe. Its members are committed to promoting sustainable waste management, recovering energy from non-recyclable waste, providing reliable energy to homes and industries, and contributing to the EU's circular economy and climate goals.

GD4S is a European association gathering gas and electric DSOs engaged in a cost effective and resilient transition, optimizing all renewable energies and energy infrastructures, in order to leave no-one behind. Energy security is a crucial aspect of the energy trilemma and a key accomplishment of the energy system, which must be considered in conjunction with sustainability and affordability.

Local authorities (LAs) account for significant EU energy consumption and lead crisis responses, as seen in the 2022 energy-saving sprint by the European Covenant of Mayors. LAs increase their energy independence by cutting energy use and boosting local renewable production. Thus, local governments must be considered allies for a resilient EU energy system. The following suggestions are along these lines: 1.

The current EU legislation and other framework conditions are overall fit to address energy crises and ensure the continuity of energy supply. The currently established system, including EU requirements and national details, can be referred to as a steady system.

Filed in German · English published by the European Commission

nucleareurope, representing Europe's nuclear energy industry, welcomes the opportunity to contribute to the Fitness Check on the EU Energy Security Architecture. Nuclear energy plays a crucial role in ensuring energy security, reducing dependence on fossil fuels, and supporting Europes decarbonization and electrification goals.

During the energy crisis that emerged in 2021 and deepened in 2022, the Hungarian Government emphasized its belief that the key to addressing these challenges lies on the supply side, not the demand side. In our view, expanding supply sources and routes can increase the availability and volume of natural gas, effectively reducing the risk of energy supply disruptions.

Enagás welcomes the opportunity to contribute to the public consultations. The following main ideas are further elaborated in the attached document: 1. Inclusion of hydrogen in the energy security architecture Enagás considers that the EU energy security framework should cover electricity, gas and hydrogen to support the transition to a sustainable energy system. 2.

The European Association for Energy Storage (EASE) welcomes that in the REPowerEU plan, the European Commission recognises that energy storage plays a key role in ensuring security of supply and supporting renewables integration, reducing the need for polluting gas power plants. EASE welcomes the provisions that aim at boosting energy storage deployment, e.g. through investments and better permitting.

In recent times of energy crisis, and uncertain geopolitical context, EU energy security has become a central issue and a top priority for the new EU term. Strengthening energy security in the EU requires not only to reduce reliance on energy imports but also to ensure that energy needs are met and that a stable supply is guaranteed for all EU citizens and industries.

Our detailed feedback and recommendations can be found in the attached document, which addresses the following priority aspects in relation to energy security in the EU: (1) An integrated EEA approach to energy security; (2) Importance of natural gas and hydrogen infrastructure; (3) Need for grids and flexible capacity investments; (4) Offshore hybrid projects; (5) New dependencies or risks of embedded…

TSO Gas One-Pager for the consultation EU Energy Fitness Security Check The current EU legislation and other framework conditions are overall fit to address energy crises and ensure the continuity of energy supply. The currently established system, including EU requirements and national details, can be referred to as a steady system.

Filed in German · English published by the European Commission

The Coalition for Energy Savings would like to thank the Commission for the opportunity to provide its feedback on this consultation. As a core message, we would like to underline that, to ensure the long-term security and stability of the EU energy system, any energy security architecture must not only encompass preparedness for supply disruptions, risk avoidance or diversification of supply, but must also strongly…

AFELMA, Asociación de Fabricantes España de Lanas Minerales Aislantes, welcomes the opportunity to contribute to the European Commission’s public consultation on the review of the adequacy of the EU’s energy security architecture.

Filed in Spanish · English published by the European Commission

CAN Europe, Europes largest network fighting dangerous climate change and representing more than 40 million citizens, welcomes the European Commissions consultation on the revision of the European energy security framework.

To maximize European energy security and sovereignty, it is important and necessary that we continue to expand Europe's renewable energy supply as quickly as possible. However, framework conditions must be created as a matter of urgency to ensure that the sovereignty for remote control of the European electricity system remains in Europe!

Euroheat & Power is the international network representing the district energy sector. We promote the rapid roll-out of sustainable heating and cooling in Europe and beyond, with the objective of full decarbonisation before 2050. As we work towards this common objective shared with the EU, we appreciate the efforts of the Commission to drive progress in the run-up to carbon neutrality in 2050.

Energy Community Secretariats contribution The gas security of supply package was transposed in the Energy Community in late 2021, a giant leap from the obsolete framework 15 years ago. The Contracting Parties are still in the process of implementing all its elements.

EU's energy security architecture is critical as Europe seeks a sustainable, reliable energy supply. As a climate innovation think tank focused on decarbonizing hard-to-abate sectors and cleantech, we want to stress the need to align energy security with the clean energy transition.

Energy security has risen to the top of the EUs political agenda, yet much remains to be done. The EU cannot continue relying on imported fossil fuels, putting its energy security in the hands of hostile nations.

Enagás GTS, as the Technical Manager of the Gas System (GTS) in Spain, is responsible for ensuring the security of natural gas supply, as established in national legislation, specifically in Law 34/1998 on the Hydrocarbon Sector.

CHC, an EU-level umbrella organisation of 16 NGOs and think tanks, welcomes the opportunity to provide input to the European Commission on the EUs energy security architecture. Our vision is for decarbonised, renewable and affordable heating and cooling (H&C) to be a reality in the EU by 2040, a key component to ensure the EU economy-wide net-zero target is met.

Naftogaz of Ukraine, Ukraine's national energy company, would like to contribute to the public consultation process on energy security architecture in Europe. Naftogaz Group's enterprises play a key role in providing gas security in Ukraine and the wider European region.

Please see the attached position paper and link to the related study on the role of storage infrastructure for both security of supply and the energy transition. https://fetsa.eu/wp-content/uploads/2024/07/FETSA-Energy-Transition-Publication-pack-01-07-24.pdf You can contact me for the full study which is not possible to upload.

UAP Coalition Netherlands (UAPCNL) is a non-profit NGO dedicated to representing professionals from aviation, the armed forces, and law enforcement who have encountered Unidentified Anomalous Phenomena (UAP). UAPCNL commends the European Commission's efforts to enhance the security of EU energy architecture, a matter of critical importance for all EU citizens.

Europes national academies of science, through EASAC, have been working during 2024 on a report for EU policy makers on Security of Sustainable Energy Supplies, to be published in April 2025. Our report will present independent science-based advice on policies and measures for delivering secure supplies of energy throughout the transition from a fossil-fuel based energy system to a sustainable energy system that…

The VÖWG expressly thanks for the opportunity to comment on the planned aptitude test. The announced review in the form of a questionnaire is an important step to ensure the adequacy and timeliness of the existing regulatory frameworks in the area of energy security.

Filed in German · English published by the European Commission

In principle, security of energy supply, especially in the gas sector, works very well as several (short-term) supply shortages have shown in the past. The secret of the success remains close cooperation between market participants. There could be some refinements in some detail areas.

Filed in German · English published by the European Commission

The EU Commission speaks of building structures for energy imports. From decisions and what we talk about in the commission from one dependency to another. The focus on US supplies where the proof of origin is not naïve is rather naïve. I will not talk about price, it can also put US companies that are losing their ability to compete on global markets.

Filed in Slovak · English published by the European Commission

Inverters for solar energy are widespread in Europe. These inverters are key element for the plan of energy resilience for 2035 with 42% electricity capacities increase, splitter mainly between nuclear and renewables sources, which includes solar energy as main contributor. These inverters are implementing interfaces to the web which are not standardised, without any norms, certification laboratories....

The attached U.Di.Con. document sets out an analysis and a series of proposals aimed at strengthening energy security in the European Union (EU) in response to future crises. Building on practical experience, it is illustrated how energy crises have a heavy impact on consumers, who face higher supply costs and inflation.

Filed in Italian · English published by the European Commission

Since February 2022, russias unprovoked and unjustified military full-scale invasion of Ukraine had and continues having a direct and serious impact on the security of energy supply in the European Union (hereinafter - EU) as well as in the wider region. It also brought certain gaps in the EU legal framework to the surface, which require to be eliminated.

Italian digital academy entrepreneurs, with a scientific group of engineers who already develop projects, and use the European line guides, are covered by EU legislation on the reduction of national emissions of certain atmospheric pollutants. A number of key steps need to be followed, including both practical planning and compliance with EU legislation.

Filed in Italian · English published by the European Commission

In the world of Entrepreneurs Digital Academy Italy, there are several key areas where proposals could be concentrated using state-of-the-art digital technology in this case: Diversification of energy supply sources, Encouraging the diversification of energy sources and suppliers, in order to reduce dependence on a single country or supplier (e.g.

Filed in Italian · English published by the European Commission

There should be functional and system requirements. I cannot understand why operating systems are allowed where software can read all the files on the computer. Many IoT devices do not support HTTPS, this is not acceptable. Since higher requirements reduce speed of digitalization,a bonus should be given for the first complying devices and OS. Main Focus is on devises helping in demand control.