Renewable Energy Directive

Carbon Recycling International is the globally recognised leader in CO2-to-methanol technology, which has been operating e-fuel (RFBNO) plants at industrial scale and selling certified e-fuel to obligated parties in the EU since 2012. As practitioners of producing and selling certified RFNBO in several EU member states, we would like to offer several comments, found int the attached document.

The Confederation of Norwegian Enterprise supports the overall EU/EEA climate ambition, and our 29.000 member companies employing 3/4 million, back up efforts to get to the low-carbon society. We hereby give some input on what we believe to be RED regulatory hurdles to get there.

The BDE Federal Association of German Waste Management, Water and Extractive Industries (BDE) is the strongest association of the German waste management, raw materials, recycling and water industries, with around 750 member companies, and represents numerous members who produce valuable renewable fuels or electrical energy from waste and thus actively contribute to climate protection and a functioning circular…

Filed in German · English published by the European Commission

ENTSO-E welcomes the revision of the Renewable Energy Directive recast (“RED III”) to be fit for purpose for the achievement of the 2030 decarbonisation goal. The decarbonisation process deeply relies on one hand on maximizing the integration of renewable energy sources (RES) in the electricity, transport, heating and cooling sectors, and, on the other hand, on developing synergies among the energy carriers in all…

To stay ahead in the global race for the best climate and energy technology solutions, companies need a clear and reliable fit-for-55 implementation plan providing a clear commitment to Europe as an attractive business, investment and innovation location.

DEAR Madams and Sirs of the Commission, I am writing on behalf of Consorzio Monviso AgroEnergia (CMA), an Italian consortium gathering more than 150 biogas producers momently beaning to agricultural and rural contexts in Italy. CMA welcomes the Commission’s proposals on the amendments on the Renewable Energy Directive and targets for the possibility to express its position on the topic.

Filed in Italian · English published by the European Commission

On numeral 31 of “Whereas” and art. 1 (15) replacing the fourth subparagraph of Article 26 of the Directive (UE) 2018/2001: This draft seeks to discourage the use of biofuels produced from food and fodder crops and those classified as high ILUC risk -in other words, from oil palm- even if this means lowering the goal of GHG reduction for transport.

INTERNAL Ref. Ares(2021)7112260 - 18/11/2021 Enel’s Positioning on the Revision on Renewable Energy Directive II General view Enel welcomes the reach of the Commission’s proposals of the “Fit-for-55” package, which is an important steppingstone for the full decarbonization of the European economy and the recent Glasgow Climate Pact.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Swedish Wood Fuel Association welcomes the Commission´s initiative to review the EU renewable energy rules to contribute to a higher climate ambition as part of the European Green Deal. We support the target to increase the share of renewable energy in the energy consumption from 32% to 40% by 2030.

November 2021 UFE's reply to the consultation of the European Commission on the revision of the Renewable Energy Directive In general, UFE, the association representing the French electricity industry, supports the proposal for a revision by the European Commission of the Directive on the promotion of the use of energy from renewable sources.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Statkraft refers to the European Commission’s proposal for a revised Renewable Energy Directive and provides feedback on the following topics. Further elaborations on these topics can be found in the attached document.

Bio Oil Group is a producer of waste based Biodiesel in Netherlands, Germany and Austria. The Biodiesel produced in our plants is 100% Used Cooking Oil based (UCOME). Bio Oil welcomes the opportunity to comment on the European Commission’s proposal on the Renewable Energy Directive revision.

Reaching climate neutrality will not be possible without reshaping the energy system in which the majority of energy will come from renewable energy sources by 2050. Energy infrastructure is key to a reliable, affordable and sustainable, integrated energy system.

The Global Alliance Powerfuels welcomes the much-needed revision of the revised Renewable Energy Directive (REDII) and endorses the European Commission’s goal to establish a regulatory framework that sets adequate incentives for the market integration of renewable energy sources and carriers, including renewable hydrogen and other renewable fuels of non biological origin (RFNBOs).

Europe’s airlines are fully committed to decarbonize air transport and are accelerating their efforts to make Europe the world’s first carbon-neutral continent by 2050 through the reduction of CO2 emissions in absolute terms, and through mitigation.

FarmTech Society (FTS) supports the revision of the Renewable Energy Directive III (REDIII) aligned with the goals of the Green Deal and in response to current energy emergencies. FarmTech Society (FTS) is an international non-profit industry association for the Controlled Environment Agriculture (CEA) sector, which is a practice in intensification of yields while upholding ecological principles.

We welcome the Commissions intention to evaluate state aid not only from the perspective of competition but also considering its impacts on climate and environment. However, we believe that the current draft of the state aid guidelines is in need for improvement, in order to boost the essential green energy transition.

The REDII: strengthening the role of RECs to support increased ambition on renewable energy With its recent proposed revisions to the Renewable Energy Directive (RED II), the European Commission (Commission) has recognized the need to increase ambition on renewable energy production in order to meet 2030 and 2050 climate objectives. To meet these objectives, more action is required in all segments of society.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Business and Science Poland welcomes the possibility to comment on the proposed amendment of the Directive (EU) 2018/2001 on the promotion of the energy from renewable sources (RED II). Our organization represents entities operating in refinery, chemical, energy, fertilizers, metals and mining, postal services, transport and financial sector, employing over 100 thousand employees in Poland, other EU Member States…

Enedis welcomes the review of the Renewable Energy Directive proposed by the European Commission. As the main electricity distribution system operator in France and one of the biggest in Europe, Enedis connects around 95% of France’s RES facilities to its public distribution grid. Reducing CO2 emissions must be the main driver of the “Fit for 55” Package.

Association for District Heating of the Czech Republic (ADH CR) welcomes opportunity to comment on the „Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Directive (EU) 2018/2001 of the European Parliament and of the Council, Regulation (EU) 2018/1999 of the European Parliament and of the Council and Directive 98/70/EC of the European Parliament and of the Council as regards the…

The Malaysian Palm Oil Council (MPOC) looks with interest and cooperative spirit to the European Commission’s feedback period regarding its Proposal for a Directive of the European Parliament and of the Council amending Directive (EU) 2018/2001 of the European Parliament and of the Council, Regulation (EU) 2018/1999 of the European Parliament and of the Council and Directive 98/70/EC of the European Parliament and…

Revisione Direttiva 2018/2001 – “RED II” Elettricità Futura condivide l’orientamento del recast ed in particolare l’innalzamento del target UE fino al 40% di FER nei consumi finali lordi al 2030 (art. 1(2)). Approviamo l’accento posto sull’elettrificazione, auspicando tuttavia l’introduzione di target specifici quali quelli delineati per i trasporti.

Filed in Italian · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

ECODES (Foundation for Ecology and Development) thanked the European Commission for the opportunity to comment on the proposed amendments to the Renewable Energy Directive (REDIII). ECODES is an independent non-profit organisation seeking to accelerate the transition to a green, inclusive and responsible economy, framed by new governance, through innovation and building bridges and alliances.

Filed in Spanish · English published by the European Commission

Italgas welcomes the adoption of the Fit 4 55 package and the Revision to the RED II Directive, both in spirit and in substance. We firmly believe in the EU’s climate targets and are striving to decarbonise our business by further making gas grids a key asset of the energy transition. Nevertheless, we think that in the current proposal there is room for significant improvements.

Ørsted is encouraged by the proposal for the revision of the Renewable Energy Directive 2018/2001, which was put forward by the European Commission on the 14th of July. While there is some room for small improvements, we want to underline that we believe the proposal is very well suited to help cost-effectively decarbonise the European energy system.

You will find in the enclosed file the detailed feedback from Dow. Dow is an American multinational chemical company, among the three largest chemical producers in the world. Dow manufactures plastics, industrial intermediates, coatings and silicones to deliver products and solutions for its customers in various market segments, such as packaging, infrastructure, mobility and consumer care.

However, the German Säge- und Holzindustrie Bundesverband warmly welcomes a revision of the Renewable Energy Directive in order to achieve the climate objectives, however, in the amending Directive, the amending directive explicitly considers that there are some requirements which jeopardise the rational use of wood for energy purposes, in the sense of resource efficiency.

Filed in German · English published by the European Commission

UNIDEN welcome the revision of the Renewable Energy Directive (RED) in order to align the text with the 2030 Fit for 55 package of the European Union. It is essential that the energy intensive industry has easy access to the amount of renewable energy at reasonable cost for its geographical location, in order to promote its competitiveness and to achieve the solutions necessary for the energy transition.

Filed in French · English published by the European Commission

As part of the “Fit for 55” package, the European Commission proposes a review of the Renewable Energy Directive (REDII), raising the ambition of the existing legislation and aligning it with the EU’s increased climate ambition.

Key messages: (1) Renewable and low-carbon Hydrogen will be needed to reach the emission reductions ambitions; (2) Air Liquide welcomes the Commission’s increased ambition on renewable energy through the Renewable Energy Directive.

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.

Edison’s reply to the consultation on the Proposal for a Directive amending Directive (EU) 2018/2001, Regulation (EU) 2018/1999 and Directive 98/70/EC as regards the promotion of energy from renewable sources and repealing Council Directive (EU) 2015/652 Edison welcomes the possibility to share its considerations on the European Commission (EC)’s proposals for a reform of the European legislation on renewable…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The American Chamber of Commerce to the European Union (AmCham EU) members call for coherence and consistency of all Green Deal legislative proposals and communications, including those that have yet to be released.

The Interprofessional Committee on Wood Energy (bringing together the energy forest-based industries of communities, service providers and industrialists) welcomes the EU’s new targets for the share of renewable energy in the EU’s energy mix.

Filed in French · English published by the European Commission

The Renewable Energy Directive II (RED) revision proposal brings the EU one step closer to becoming a global leader in renewable hydrogen development by adding to EU’s ambition on renewable energy in the form of electricity and hydrogen. We welcome the approach of focusing solely on renewable hydrogen in this framework and underline a level playing field between all clean technologies needs to be ensured.

As a key player in the energy transition in the outermost regions (ORs), ALBIOMA wishes to stress the key role of bioenergy in the transition to a low-carbon economy, particularly in the ORs, and to point out the need for a regulatory framework that would guarantee the sustainability of the biomass resource and give industrial operators the visibility and stability needed to carry out their investments.

Filed in French · English published by the European Commission

Comments Revision of RED II Association of the German Biofuel Industry Berlin, 18.11.21 1. VDB as representative of the biofuel producers in Germany The Association of the German Biofuel Industry (Verband der Deutschen Biokraftstoffindustrie e. V. - VDB) represents the interests of 15 biofuel producers in Germany with a production capacity of 2.3 million tons of biodiesel and 900 GWh of biomethane. 2.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Environmental Action Germany (DUH) notes that the RED has over the past 10 years stimulated the use of climate- and environmentally-damaging biofuels in the transport sector and biomass in electricity and heat generation, thus contributing to higher GHG emissions, biodiversity loss and deforestation.

The Association of the Automotive Suppliers’ industry in Europe is pleased to provide feedback on the proposed directive as regards the promotion of energy from renewable sources. CLEPA represents over 3.000 companies supplying state-of-the-art components and innovative technology for safe, smart and sustainable mobility, investing over 30 billion euros yearly in research and development and employing overall nearly…

Ares(2021)7110808 - 18/11/2021 Position Ref. Paper Zürich Biogem Express GibGas OrangeGas SNAM November 2021 Zürich 5 Coalition position on the proposed Renewable Energy Directive III (2021/0218) Zürich Position paper: Renewable Energy Directive III (2021/0218) The Zürich 5 Coalition (hereinafter ‘the Coalition’) is expressly committed to achieving the objectives of the Paris Agreement and supports the EU’s ambition…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Many proposed changes in the Renewable Energy Directive in general are too detailed and risks restricting the sovereignty of Member States in choosing their energy mix. The EU should encourage the use of fossil-free energy, not regulate Member States' energy mix, as regulating the energy mix would risk resulting in considerable challenges to security of supply and reduce the cost-effectiveness of transition.

Biomass is the main source of renewable energy in the EU. Equipped with an appropriate toolbox, European agriculture and forestry have the potential to produce additional volumes of sustainable biomass in the EU by 2030.

Fit for 55 Package and Gas for Climate Making 2030 EU climate targets achievable with a clear role for renewable and low-carbon gases November 2021 Fit for 55 Package and Gas for Climate | Making 2030 EU climate targets achievable with a clear role for renewable and low-carbon gases 2 Table of Contents Key policy recommendations ........................................................................

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The German Hydrogen and Fuel Cells Association is grateful for the opportunity to participate in the feedback process on the revision of EU renewable energy rules and welcomes many aspects of the new version. The Renewable Energy Directive (RED II) provides an opportunity for Member States to effectively establish a European sustainable renewable hydrogen energy sector in a market economy, while at the same time…

Filed in German · English published by the European Commission

Dear Sir/Madam, APQuímica, the Portuguese Petrochemical and Refination Association, presents in the attached document its comments and contributions as part of the “Fit for 55” legislative package, and in particular with regard to the proposed revision of the Renewable Energy Directive (new RED III Directive).

Filed in Portuguese · English published by the European Commission

EurEau welcomes the Proposal for a revised Renewable Energy Directive (RED III) but regrets it doesn’t specifically address the water sector, despite its contribution to the renewable energy targets and climate policies: generation of electricity from hydraulic turbines and from on-site wind mills/solar panels, biogas from sewage sludge, electricity and thermal energy from sewage sludge mono-incineration, heat pumps…

Fit for 55 – DVF Rückmeldung zu den Kommissionsvorschlägen: Anpassung der Erneuerbare-Energien-Richtlinie (RED) 18. November 2021 Grundsätzliche Bewertung des Fit-for-55-Paketes • Das DVF unterstützt mit Nachdruck die Zielsetzung, Europa bis zur Mitte des Jahrhunderts klimaneutral zu machen. Dazu müssen die Emissionen des Verkehrssektors schon in den kommenden zehn Jahren sehr deutlich gesenkt werden.

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

SNAM’S FEEDBACK ON THE FIT FOR 55 PACKAGE Snam welcomes the Fit for 55 proposals, which overall certainly represent a complex and comprehensive initiative stemming from the Climate Law. In this note, we wish to express some high level comments outlining the most relevant positive elements in the proposals, together with the main areas for development, highlighting where relevant specific aspects across the…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Stellungnahme Entwurf zur Novelle der EU-Erneuerbare-Energien-Richtlinie Der Verein Deutscher Zementwerke e.V. (VDZ) begrüßt die Gelegenheit, zum Entwurf der EU-Kommission für die Erneuerbare-Energien-Richtlinie (RED III) Stellung zu nehmen. Bei folgenden Punkten besteht aus unserer Sicht konkreter Änderungsbedarf am Richtlinienentwurf: 1.

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Please finalise the position from EDF (Electricite de France) on the proposal to amend REDII. In short: For EDF welcome: • the increased RES target of 40 % at EU level by 2030, in line with the new 2030 climate objective (Article 3); • the new provisions on e-mobility: Bidirectional loading stations and data sharing on batteries to develop flexibility and storage solutions for the growing share of RES (Article 20a)…

Filed in French · English published by the European Commission

The European Heating Industry, EHI, welcomes the Commission’s proposal to review the Renewable Energy Directive (RED) along with the new ambition proposed for the renewable energy target. We also welcome the new provisions on heating and buildings, although we had previously called for a higher renewable heating and cooling target, of 2.3%.

Renewable Liquid Gas, also known as bio-propane (RED II, Annex III), Renewable LPG,or bioLPG, is a renewable liquified gaseous fuel that is already available today on the European market in growing quantities. Renewable LPG is chemically and physically identical to conventional LPG, allowing industry and consumers to seamlessly transition to a renewable solution.

18 November 2021 Dear Commission Representative, RE: Commenting period for EU RED II revised We welcome the opportunity to comment on the revised European Union Renewable Energy Directive (EU RED II revised) and applaud the EU’s leadership role and ambitious climate targets embodied in the Fit for 55 policy package.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Clean transport will be key in ensuring the European Union reduces its emissions and achieves its carbon-neutral ambitions by 2050. However, it is paramount that greening transport does not cause unintended and offsetting increases of emissions and ILUC in other sectors.

IFIEC believes the revision of RED II could help industry decarbonise provided access to abundant, competitive secure and low carbon energy and hydrogen (H2) is assured. Alongside, the revision should further contribute to create the necessary legal certainty for investment in low-carbon and breakthrough technological solutions according to the principle of technology neutrality.

Bioenergy Association of Finland underlines a need to agree a balanced FF55 package that supports the -55 % emissions reduction rather than a wide set of other goals. It is counter-productive and very disappointing that the Commission decided to open REDIII biomass sustainability criteria in its proposal. The proposal does not support creating negative emissions in the EU.

FEAD welcomes the European Commission’s proposal for reviewing the 2018 Renewable Energy Directive (REDIII) and adjusting its rules to the latest EU climate ambitions for 2030. Therein, FEAD supports the unchanged definition of ‘waste heat’, considering that the activities of hazardous and non-hazardous waste installations are producing waste heat, when recovered by efficient district heating and cooling systems.

Comments to the “DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Directive (EU) 2018/2001 of the European Parliament and of the Council, Regulation (EU) 2018/1999 of the European Parliament and of the Council and Directive 98/70/EC of the European Parliament and of the Council as regards the promotion of energy from renewable sources, and repealing Council Directive (EU) 2015/652” Comments to…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

ICLEI Europe welcomes the consultation to ensure that at least 55% (and not 50%) GHG emissions will be reduced by 2030 compared with 1990, as this is closer in line with the effort of the 1.5°C goal of the Paris Agreement.

The Swedish Association of Local Authorities and Regions (SALAR) supports the increase of renewable energy to reach EU climate targets for 2030 and carbon neutrality by 2050. Regulation should be restrictive about detailed requirements and subtargets, in order to respect varying national and regional conditions.

This is an expert opinion of AIB based on its experience in managing GO systems but not necessarily reflecting the opinion of all members, who may not have the mandate to decide on this topic. GOs can serve as a basis for harmonised European certification and labelling of energy. For efficiency and effectiveness the AIB feels that the concept of GOs can be strengthened in the following ways: 1.

EWABA Position Paper on the proposed revision of the Renewable Energy Directive November 2021 EWABA represents the interests of the EU waste-based and advanced biodiesel industry. In 2020 our 35+ members produced 1.737.000t of biodiesel using waste-based feedstocks in Part B of Annex IX of Directive 2018/2001 (the Renewable Energy Directive or REDII), namely used cooking oil (UCO) and animal fats, and different…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Finnish Energy welcomes the opportunity to comment on the Fit for 55 climate package. We strongly support the EU’s climate targets for 2030 and 2050, and we are also committed to Finland’s carbon neutrality target for 2035. The energy and climate policy initiatives published by the Commission in July set the Europe to the right path towards climate neutrality. Please find our comments here attached.

The European Ventilation Industry Association (EVIA) is delighted to provide feedback to the European Commission's proposal for a revised Renewable Energy Directive (RED). EVIA would like to highlight that waste heat and cold recovery, better called energy recovery, in ventilation systems has enormous potential to contribute significantly to reaching the EU’s climate goals by significantly reducing the energy demand…

18 novembre 2021 Révision de la Directive relative à la promotion de l’utilisation de l’énergie produite à partir de sources renouvelables (2018/2001) Contribution à la consultation publique De manière générale, le Syndicat des énergies renouvelables, qui représente l’ensemble des onze filières de production d’énergie renouvelable actives en France, soutient la démarche de la Commission européenne visant à renforcer…

Filed in French · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Romanian Oil and Gas Employers’ Federation’s (FPPG) opinion about the revision of the Renewable Energy Directive FPPG welcomes the “Fit for 55” legislative package put forward by the European Commission as a necessary step in the decarbonization effort that would allow us to reach an EU-wide greenhouse gas emissions reduction of 55% in 2030.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

ACCIONA’S VIEW ON THE COMMISSION’S PROPOSAL FOR A REVISION OF THE RENEWABLE ENERGY DIRECTIVE Acciona welcomes the opportunity to contribute to the consultation on the revision of the Renewable Energy Directive and we hereby offer a few very brief comments and suggestions on the proposal, which we believe would improve the text, the most relevant ones trying to adapt the provisions for biomass to fit to the…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

FEDIOL, representing the EU vegetable oil and protein meal industry, welcomes the possibility to provide feedback on the review of Directive (EU) 2018/2001 on the promotion of energy from renewable sources. With the occasion, we would like to reiterate the sector’s priorities for an ambitious policy framework for renewables in transport, in line with the EU Green Deal’s objectives.

EuropeOn is the voice of electrical contractors, the 1.8 million professionals implementing the energy transition by installing and maintaining electric technologies such as solar PV systems or EV chargers and advising consumers on the best available clean energy technologies.

Gas Infrastructure Europe (GIE), representing almost 70 European companies operating storage facilities, transmission pipelines and LNG terminals, welcomes the European Commission’s initiative to review the recast of the Renewable Energy Directive. In the context of this draft revision and to facilitate the deployment of renewable energy, please find GIE's feedback and considerations attached.

COGEN Europe supports the review of the Renewable Energy Directive (RED) in the context of Fit for 55 and its alignment with the EU’s energy efficiency, climate and competitiveness priorities. The cogeneration sector is committed to the creation of a resilient, decentralised and carbon neutral European energy system by 2050 with cogeneration as its backbone.

Equinor feedback on the revision of the Renewable Energy Directive. Equinor welcomes the Commission’s revision of the Renewable Energy Directive, which will be an important centerpiece of the revised 2030 climate and energy framework. Equinor aims to be a leader in the energy transition by shaping the energy industry of tomorrow and in line with the Paris agreement become a net-zero company by 2050.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Separate Legal Framework for Energy Certification The EU has committed to stronger action on climate change and reaching a carbon-neutral economy. This means greenhouse gas emission will not only have to be reduced in the energy sector but far beyond that. Against this background, resource efficiency and aspects of a circular economy become ever more important.

The MVaK represents 21 members which pretreat suitable vegetable waste and residues, mainly used cooking oil and waste fatty acids, process them into waste-based biodiesel or trade feedstocks and finished products. The MVaK welcomes the opportunity to comment on the European Commission’s proposal on the Renewable Energy Directive revision.

RTE would like to draw attention of the European Commission to two points that directly affects Transmission System Operators (TSOs) for electricity: • Participation of all generation sources of electricity in network balancing services: In the coming years, the share of renewable energies in the European electricity mix will increase significantly.

With “Fit for 55,” the European Commission has presented a comprehensive package aimed at reshaping the European Union’s climate policy. The German automotive industry supports the goal of making road traffic climate-neutral by 2050 at the latest and welcomes the revision of the Renewable Energy Directive (RED) – especially the introduction of GHG-mitigation quota.

The neighbouring regions of North Rhine-Westphalia (Germany) and Flanders (Belgium) are home to powerful clusters of the chemical industry. The chemical sector of both NRW and Flanders supports the ambition to establish a global climate neutral economy and finds low carbon hydrogen will play an import role.

NGVA Europe welcomes the revision of the Renewable Energy Directive, which should align with the increased GHG emission reduction targets of the EU. For this reason, NGVA Europe supports the proposed increased targets for the transport sector combined with the deletion of multipliers for advanced biofuels and renewable electricity.

EPHA welcomes the opportunity to provide feedback on the proposed revision of the EU renewable energy rules (Directive 2018/2001/EU). The use of renewable energy must be supported and significantly scaled up at an accelerated pace if the EU is to achieve its climate and health ambitions. The transport and buildings sectors are two massive contributors to both air pollution and greenhouse gas emissions in the EU.

Transport is responsible for about one quarter of global greenhouse gas emissions worldwide. To reach our climate targets set out under the Paris Climate Accord, there is no single solution and urgent and complementary measures are needed. UNICA, the Brazilian sugarcane association, welcomes the revision of the Renewables Directive and appreciates the opportunity to contribute.

The EC recently published its “fit for 55” package, including a review of the renewable energy directive (RED). Essenscia supports the climate transition and considers the reduction of greenhouse gases while remaining competitive in a global context key.

FinCo Fuel Group welcomes the proposal for an amended Renewable Energy Directive, which in combination with the other proposals provide a sound mix of regulatory measures on the path to climate neutrality by 2050. The inclusion of dedicated targets for the shipping and aviation sector is received with enthusiasm.

GoodFuels welcomes the proposal for an amended Renewable Energy Directive, which in combination with the other proposals provide a sound mix of regulatory measures on the path to climate neutrality by 2050. The inclusion of dedicated targets for the shipping and aviation sector is received with enthusiasm.

Fluxys welcomes the opportunity provided by the Commission through this feedback period for stakeholders to provide views on the Commission’s adaption regarding Renewable Energy Directive (RED) back in the summer of 2021 with the aim of feeding into the legislative debate at the European Parliament and Council.

The European Biogas Association (EBA) welcomes the proposal of the European Commission to raise the ambition for renewable energy by 2030. This paper outlines the concerns of the EBA’s members with regards to the proposal. Europe is world leader in biogas technology for production, upgrading and uses.

DTEK would like to thank the European Commission for this opportunity to provide feedback under the revision of the Renewable Energy Directive. Updating RED II is directly relevant to the company due to Ukraine’s obligation under both the EU Ukraine Association Agreement and the Energy Community Treaty to implement the EU acquis in the electricity sector.

Stockholm Exergi believes that it is far too early to start an adjustment of the sustainability criteria in REDII. Any adjustment must be based on learnings from the ongoing implementation of the current REDII. Bioenergy is the leading energy source in Sweden.

November 2021 US Industrial Pellet Association (USIPA) position on RED III Sustainable biomass is currently the largest renewable energy source in Europe and has proven to be a fast and reliable way to decarbonise the economy.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

SolarPower Europe welcomes the European Commission's proposed amendments of the Renewable Energy Directive. Attached you may find our full feedback to the proposal. Considering the market growth of solar, the EU can go further even faster in its renewable energy ambition. According to SolarPower Europe modelling, the 40% target is insufficient to reach the required 55% GHG emissions reduction target by 2030.

Cepi represents the European pulp and paper industry and gathers, through its 18 member countries, some 895 pulp, paper and board mills across Europe directly, employing more than 180,000 people. Our sector is investing at a rate of more than €5 billion per annum, increasing our production volumes while simultaneously reducing our carbon footprint.

The German Forestry Council (DFWR) supports the objective of the Green Deal’s climate neutrality and the necessary substantial increase in the share of renewable energy sources. In this context, the use of wood from residues and co-products for energy purposes is essential.

Filed in German · English published by the European Commission

See PDF attached for the EBB submission to this consultation. Please note that the document submitted is a high-level submission to this consultation, but does not constitute a complete EBB position paper addressing all the multiple elements in that proposal (still under preparation).

CO2 Value Europe is the European association dedicated to Carbon Capture and Utilisation (‘CCU’) and represents over 70 members along the CCU value chain, primarily industrial actors from different sectors. CCU is a broad term that covers all established and innovative industrial processes that aim at capturing CO2 – either from industrial point sources or directly from the air – and at transforming the captured CO2…

Enagás welcomes EC’s ambition to increase the overall target for renewable energy to 40%, as well as introducing/adjusting several sector-specific sub-targets. The new Directive (REDIII) represents an opportunity to develop renewable and low carbon gases in order to achieve carbon neutrality on a cost-efficient way.

Comments Regarding a ‘Proposal for a Directive of the European Parliament and of the Council amending Directive (EU) 201/2001 of the European Parliament and of the Council, Regulation (EU) 2018/1999 of the European Parliament and of the Council and Directive 98/70/EC of the European Parliament and of the Council as regards the promotion of energy from renewable sources, and repealing Council Directive (EU) 2015/652…

— For the IFR, reducing greenhouse gas emissions should be the first and main objective of climate policy. Increasing production and use of renewable energy is one of the ways to contribute to this. The VBO therefore calls for the renewable energy target to be formulated as an indicative target. — Annex II of the proposal sets out a formula for calculating the renewable energy target per Member State.

Filed in Dutch · English published by the European Commission

Extract from submission: Europe needs to dramatically increase power system capability and flexibility in the coming decades to accommodate renewables. This must be provided for by increased interconnection and innovative grid infrastructure, including in the offshore space where no grids exist today. Furthermore, Europe’s existing transmission grid and the grid under development must also be utilised better, e.g.

The German Energy Agency (dena) welcomes the revision of the Renewable Energy Directive (RES Directive — 2001/2018) as part of the Fit for 55 package to adapt key European climate and energy legislation as part of the Green Deal. The targets set out in the Directive for RES shares for electricity, heat and transport by 2030 are key to achieving climate neutrality across the EU in 2050.

Filed in German · English published by the European Commission

Attached the response of Falck Renewable to the consultation on Directive (COM 2021/557) amending Directive (EU) 2018/2001 of the European Parliament and of the Council, Regulation (EU) 2018/1999 of the European Parliament and of the Council and Directive 98/70/EC of the European Parliament and of the Council as regards the promotion of energy from renewable sources, and repealing Council Directive (EU) 2015/652.

EPEE, representing the Refrigeration, Air-Conditioning and Heat Pump industry in Europe, is delighted to provide feedback to the European Commission's proposal to revise the Renewable Energy Directive (RED). The heating and cooling sector offers a large cost-effective potential to reduce emissions through the integration of renewable energy.

The European Oleochemicals & Allied Products Group (APAG) welcomes the revision of the Renewable Energy Directive (RED II). To ensure that the European Commission’s proposal on the revision of RED II is coherent with circular economy principles, the cascading use principle, and the waste hierarchy, we ask for a level playing field between the different uses of biomass such as for biofuels and bio-based chemicals.

The steel industry aims to achieve climate neutrality in line with the agreed climate objectives. When transforming into green steel, it can already save significant amounts of CO2 by 2030, with the right framework conditions. The replacement of coal and, in the long term, natural gas with green electricity and hydrogen plays a crucial role in this process.

Filed in German · English published by the European Commission

Consultation response: Renewable Energy Directive E.ON welcomes the revision of the Renewable Energy Directive (REDIII) as a key policy lever to accelerate the deployment of renewables and their mainstreaming in end-use sectors. We support the European Commission's proposal to increase the common target for the share of renewables in gross final energy consumption from 32% to 40% by 2030.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Position paper On Amending Directive (EU) 2018/2001 on the promotion of the use of energy from renewable sources and, as a consequence, Regulation (EU) 2018/1999 on the Governance of the Energy Union and Climate Action and Directive 98/70/EC relating to the quality of petrol and diesel fuels AND Delegated regulation on GHG accounting of renewable electricity for the production of Renewable Fuels of Non-Biological…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

November 2021 Lantmännen’s position on the European Commission’s proposal on the review of Directive 2018/2001/EU (Renewable Energy Directive II) Lantmännen welcomes the opportunity to provide constructive feedback to the European Commission’s proposal on the review of Directive 2018/2001/EU on the promotion of the use of energy from renewable sources (hereafter RED II).

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

General comments The proposed targets appear to be very ambitious from the perspective of the Renewable Fuels Platform (PEK), especially in view of the short maturity until 2030 and the length of negotiations and deadlines for implementation.

Filed in German · English published by the European Commission

Helen Ltd. is the second biggest energy company in Finland and has the fifth largest district heating network in the world. Helen Ltd. is reaching the carbon-neutrality latest by 2030 based on renewable energy sources especially societal and industrial waste heat and cold. In Helen Ltd.’s view, the EU should be reached Paris Agreement’s goals as soon as possible and limit global warming by 1,5 degrees.

The German National Committee for Monument Protection (DNK) – a network of actors and stakeholders in monument preservation and archaeology in Germany – comments on the above-mentioned proposal (long version in german and english see attached file): The DNK welcomes both this proposal and the proposal for the recast and amendment of the Energy Efficiency Directive (EED), which is also available for feedback, as…

Liquid Wind welcomes the European Commission’s proposed revision of the Renewable Energy Directive as a part of the Fit-for-55 legislative package. Liquid Wind is a Swedish Power-to-Fuel Development Company committed to reducing carbon emissions.

MOL Group has a strong ambition to improve its operations and gradually transition to a low-carbon, sustainable business model, hence also welcomes the aim of the “Fit for 55” package to target a reduction of at least 55% in greenhouse gas emissions by 2030. The green transition can only take place if the required industrial and economic changes do not impose disproportionate burden on society.

Teréga welcomes the "Fit for 55" package presented by the European Commission (EC), and wishes to propose several recommendations and areas for improvement to make the Fit for 55 package even more effective. The attached document shortly highlights Teréga’s main attention points in order to make sure that the net-zero objective set by the EC is reached as swiftly as possible and at the lowest-possible cost for the…

The Renewable Energy Directive II (REDII) revision shall put in place incentives for scaling-up renewable energy production, particularly renewable H2. Switching to renewable energy is one of the EU stated long-term goals. This goal is often expressed synonymously with becoming climate neutral, though carbon neutrality is a broader term.

The European Feed Manufacturers’ Association (FEFAC) welcomes the possibility to comment on the revision of the EU renewable energy directive (Directive 2018/2001/EU on the promotion of the use of energy from renewable sources) aiming to support the objectives of European Green Deal and Fit for 55 packages to reduce Greenhouse gas emissions (GHG) and as such help the EU on the way to climate neutrality by 2050.

INTERNAL Ref. Ares(2021)7105187 - 18/11/2021 Enel’s Positioning on the Revision on Renewable Energy Directive II General view Enel welcomes the reach of the Commission’s proposals of the “Fit-for-55” package, which is an important steppingstone for the full decarbonization of the European economy and the recent Glasgow Climate Pact.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The IDA is the global voice of the Dimethyl Ether (DME) industry, promoting its use as a clean alternative fuel worldwide. The IDA has a global membership of more than 50 companies, institutions and individuals involved in the research, development, production, distribution and use of DME.

The Austrian Chamber of Agriculture welcomes the opportunity to submit the following initial assessment regarding the European Commission proposal to amend the “Renewable Energy Directive (REDIII)” – part of the “Fit for 55” package: The REDIII draft proposed by the EC sets the target of doubling the share of renewable energy in the gross final energy demand of the EU27 from 20% in 2020 to 40% in 2030.

Enclosed please find the position of the Polish Coalition of Biofuels and Protein Feed regarding the proposals of the European Commission within the “Fit for 55” package including the review of the RED2 directive in the scope of the EU’ transport sector.

Ref: C21-EPU-45-03 ______________________________________________________________ CEER Feedback to the European Commission on the Review of the Directive 2018/2001/EU on the Promotion of the Use of Energy from Renewable Sources 18 November 2021 1 Introduction This is a response to the European Commission’s request for feedback1 on a proposal for the revision of Directive 2018/2001/EU on the promotion of the use of…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Lappeenrannan Energia Oy commends the opportunity to comment on the European Commission’s proposal for an amendment to the Renewable Energy Directive (EU) 2018/1999 (“RED II”). The Lappeenrannnan Energia group is a Finnish energy and water group active, inter alia, in the production and distribution of heat and electricity.

Filed in Finnish · English published by the European Commission

At BASF we are committed to become climate neutral by 2050 in all our operations globally. Emission reduction in the chemical industry requires the electrification of heat and power use and processes. As a result, the RED is of high relevance for us. 1.

GENERAL COMMENTS • Increasing the share of renewable energy in the EU's gross final energy consumption may result in administrative, economic as well as technology burdens for energy sector. Therefore, it is of key importance to ensure technology-neutral approach that will enable taking an advantage of more affordable solutions such as low carbon technologies e.g. low-carbon hydrogen and biomethane/biogas.

On 16 July, the European Commission opened a public consultation on its review of the Renewable Energy Directive (RED). TransnetBW welcomes the opportunity to provide below its views on several of the proposals. In summary our comments relate to the following aspects: With regards to new Art 20a(1), the provision of estimated renewable energy sources (RES) generation data is already widespread among European TSOs.

The transition of the European steel industry towards climate neutrality will build on the deployment of new technologies and will be dependent on the reliable availability of low carbon energy (mainly electricity and hydrogen) at economically viable and affordable prices.

AGFW-Position Paper Renewable Energy Directive Frankfurt, 18th November 2021 __________________________________________________________________________ AGFW is the German energy efficiency association for heating, cooling and cogeneration. We represent more than 550 utility companies (national and regional), energy service providers as well as industrial companies of the sector across Germany and Europe.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Your ref Our ref Date 16/3574- 17 November 2021 Norwegian comments on the proposal for a revision of the Renewable Energy Directive 2018/2001 of 14 July 2021 1. Introduction Thank you for giving us the opportunity to share some viewpoints on the proposal of the revision of Renewable Energy Directive 2018/2001 which was put forward by the European Commission on the 14th of July.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Novembre 2021 Contribution de la Région Bretagne aux Consultations européennes sur le paquet « Fit for 55 » La Région Bretagne souhaite pleinement prendre sa part à la réalisation des objectifs européens pour une atteinte de la neutralité carbone à l’horizon 2050.

Filed in French · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Biomass is the main source of renewable energy in the EU. Equipped with an appropriate toolbox, European agriculture and forestry have the potential to produce additional volumes of sustainable biomass in the EU by 2030. Copa and Cogeca want the role of certified sustainable agricultural and forest biomass to be strengthened in all the bioenergy sectors.

FNADE welcomes the European Commission’s proposal for reviewing the 2018 Renewable Energy Directive (REDII) and adjusting its rules to the latest EU climate ambitions for 2030. FNADE also approves the increase of the renewable energy target to 40%. This proposal and the whole “Fit for 55 package” will help to achieve the EU's greenhouse gas reduction and climate neutrality targets.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Reganosa, as Transmission System Operator, is committed to play an active role in the energy transition process framed within the European Green Deal, the National Energy and Climate Plan 2021-2030 (NECP) and the EU Energy System Integration and Hydrogen strategies.

EFIEES is the voice of energy service companies (ESCOs) and their national associations in 12 EU Member States. Our members represent over 130.000 professionals engaged in the design and implementation of energy-efficiency solutions in public and private buildings as well as industrial facilities. In some countries, they also ensure the efficient operation of DHC networks.

Ensuring carbon neutrality and fostering the energy transition is a key societal challenge. Property owners, be they owner-occupiers or individual/professional landlords, are not only key stakeholders in the housing and real estate sectors, they also are consumers, as well as potentially producers of renewable energies helping households and businesses to reduce their energy costs and their environmental footprint.

The review of the Renewable Energy Directive (RED) is a unique opportunity to accelerate the use of renewable alternative fuels needed for the long-term decarbonisation of transport - renewable electricity, renewable hydrogen and e-fuels - while strengthening the sustainability safeguards for advanced biofuels and phasing-out of crop based biofuels.

Electrochaea GmbH (Electrochaea) appreciates the opportunity to submit the following comments to the European Commission consultation on the Renewable Energy Directive review (RED III). Our comments address questions in the proposal for a directive – COM (2021) 557, Article 1 (19) on Article 29a and Article 1 (11) on Article 22a. Please see attached document with our comments.

Position Paper Revision of the Renewable Energy Directive (2018/2001) Publication date: November 2021 EUROFER Key Messages • • • • • • • Page |1 The achievement of targets on the integration of renewable and low carbon energy in the European industrial sector requires inevitably the deployment of a considerable amount of renewable and low carbon electricity and hydrogen at large scale, making them available at…

Filed in Czech · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

1. SELF-USE OF BIOMASS FROM BIOMASS PROCESSING IN RURAL AREAS SHOULD BE EXCLUDED FROM ART. 29 The revised sustainability criteria under the new draft Art. 29 are overly restrictive and would add dis-proportionate obligations for sugar manufacturers to certify the full amount of raw material beets and the biomass fuel derived from production residues.

CEE Bankwatch Network supports amending the RED II to further align it with the European Green Deal, and raising the ambition of the RED II targets. However, such an increase in ambition must be accompanied by a tightening of the Directive’s sustainability provisions – for all technologies, not only biomass – if it is to truly contribute to the Green Deal.

CEPM wishes to transmit its comments on various texts proposed in the “fit for 55” package. In general, CEPM regrets that the contribution of crop based biofuels, including corn bioethanol, is not better supported. CEPM requests that the role of these biofuels be improved, and that it is reflected systematically in the various texts. Please find attached our comments.

Position from 18. November 2021 on the Revision of the European renewable energy directive (RED II) DVGW Deutscher Verein des Gas- und Wasserfaches e.V. Contact [name removed]-Platz 4 D- 10115 Berlin Tel.: [phone removed] M.: [phone removed] E-Mail: [email removed] General remarks on the revision of the EU renewable energy directive The DVGW welcomes the opportunity to provide input to the revision of the directive…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Please find enclosed the submission document drawn up by the Andalusian Energy Agency. Technical and Energy Planning Directorate C/[name removed], 6. Isle de la Cartuja, 41092 Seville, [email removed] Tfno: 954 78 63 35, Fax: [phone removed] https://www.agenciaandaluzadelaenergia.es/es

Filed in Spanish · English published by the European Commission

ECI supports the EU’s climate ambitions for 2030 and 2050 and welcomes the proposed revision of the Renewable Energy Directive (RED II) as a step in the right direction to accelerate the deployment of renewables in buildings, heating and cooling, transport and industry.

AFLRA acknowledges the need to increase renewable energy (RE) as a necessary component to reach EU climate targets for 2030 and carbon neutrality 2050. AFLRA supports ambitious climate and energy policy and action in line with 2050 climate neutrality for the EU, involving local and regional authorities (LRAs) as forerunners, as long as it is accompanied by appropriate frameworks, measures and financial resources.

The Association for Emissions Control by Catalyst (AECC) welcomes the opportunity to comment on the European Commission’s proposal for amending the EU renewable energy rules public consultation. Sustainable renewable fuels can contribute substantially to the reduction of CO2 emissions from road transport. This needs to be fully recognised in the Renewable Energy Directive (RED).

Dear Commission, We would like to fully support the comments and justification expressed by Eurofer in its position document (attached). As such we fully support the following key messages: • The achievement of targets on the integration of renewable and low carbon energy in the European industrial sector requires inevitably the deployment of a considerable amount of renewable and low carbon electricity and hydrogen…

Remissvar Jernkontorets reg.no:3521 Stockholm, November 18, 2021 European Commission Contribution on the proposal for revised RED Jernkontoret represents steel industry in Sweden with high ambition to be in the frontline of the transition towards decreasing climate related emissions.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

18.11.2021 Hydrogen Denmark’s response to the consultation on the review of the Renewable Energy Directive (REDIII) Hydrogen Denmark (Brintbranchen) would first and foremost like to thank the European Commission for the opportunity to provide feedback on this topic.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Please find attached ESWET’s full response to the consultation. ESWET represents companies that have built and supplied over 95% of the Waste-to-Energy plants in operation in Europe. We welcome the European Commission’s proposal for the revision of the Renewable Energy Directive (RED), as it accurately addresses the urgency of up-taking every renewable energy source available, including the electricity, steam…

We welcome the support of renewable energies throughout the EU, and beyond. However, any such support needs to be well integrated into the legal framework of the EU based on transparent, holistic and reliable planning taking international competitiveness fully into account and aiming at utmost planning certainty.

The revision of the Renewable Energy Directive is a significant step forward in the accomplishment of the decarbonisation of the European economy. The objective of the Directive would be reinforced with a clear definition of low carbon gases.

COFALEC is the Confederation of European yeast producers. Beyond the traditional applications of yeast in fermented food and drinks (bread, wine, beer), the European Yeast producers are committed to provide a wide range of solutions to achieve a more sustainable and low-carbon food chain.

APREN’S RESPONSE TO THE REVIEW OF DIRECTIVE 2018/2001/EU ON THE PROMOTION OF THE USE OF ENERGY FROM RENEWABLE SOURCES The Portuguese Renewable Energy Association (APREN) is a non-profit association with the mission of coordination, representation and defence of the common interests of our Members.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Generally, we support all measures aimed at reducing climate change and promoting alternative energy sources. Meeting the EU's 2030 target of at least 40% renewable energy in the EU's gross final energy consumption is a step in the right direction. However, there are several stipulations that we would like to see amended, we will address in detail in the following. 1.

The Danish Forest Association supports the high ambition for the climate in the fit for 55 package set to combat the climate change, including the suggestion to increase the share of renewable energy in the energy mix.

CEWEP Ireland welcomes the European Commission’s proposal for a revised Renewable Energy Directive (RED III) with a view to bringing the objectives of the Directive in line with the EU’s revised climate ambition.

Fertilizers Europe welcomes the possibility to share its views on the revision of the European Commission revision of the Renewable Energy Directive. The European fertilizer industry supports the European Green Deal ambition of climate neutrality by 2050. Already today the main European fertilizer products have a climate footprint that is typically half of the global average.

A sharp increase of renewable energy capacities is indispensable for the Paris Agreement’s objective to limit temperature rise to 1.5°C. As action in the next ten years will be decisive in reaching the 1.5°C objective, the EU should strive for at least 65% greenhouse gas emission reductions by 2030.

The attached paper is APPLiA’s proposed contribution to the feedback mechanism launched by the European Commission on the “Fit for 55” Renewable Energy Directive proposal. It provides a first set of remarks on the provisions of the legal text under consultation. APPLiA is also proposing amendments and/or comments to specific articles of the Commission.

DIGITALEUROPE welcomes the European Commission’s “Fit for 55” legislative package, published on 14 July 2021. Digital solutions play a key role in achieving the climate goals and allowing grids to absorb more power from renewable energy sources whilst also helping to balance supply and demand.

AEAS welcomes the Proposal for a revised Renewable Energy Directive (RED III) but regrets it doesn’t specifically address the water sector, despite its contribution to the renewable energy targets and climate policies: generation of electricity from hydraulic turbines and from on-site wind mills/solar panels, biogas from sewage sludge, electricity and thermal energy from sewage sludge mono-incineration, heat pumps…

The European Union’s commitment to meeting the Paris climate targets and achieving climate neutrality by 2050 will have to lead to major policy adjustments in the next years. In line with the revision of other key framework legislation in the so-called Fit for 55 Package, the revision of the Renewable Energy Directive (RED III) is of key importance for our common ambition.

North European Oil Trade (NEOT) contributes to this consultation from the perspective of an independent fuel procurement company in the Baltic Sea region. We supply annually roughly 7 billion liters of fuel products to transport, heating, aviation, and marine sectors in Finland, Sweden, and Norway. Our supply represents approximately 40% of the total fuel consumption in Finland, 30% in Sweden, and 35% in Norway.

The Confederation of European Forest Owners (CEPF) takes note of the Commission´s initiative to review the EU renewable energy rules to contribute to a higher climate ambition as part of the European Green Deal.

Lappeenrannan kaupunki kiittää mahdollisuudesta lausua Euroopan komission uusiutuvan energian direktiiviä (EU) 2018/1999 (”RED II”) koskevasta muutosehdotuksesta. Lappeenrannan kaupunki on EU:n Green Leaf voittajakaupunki 2021. Kaupungissa on vahva energia- ja ympäristöalan yrityskeskittymä, jossa valmistellaan teollista synteettisen metanolin pilottilaitosta (RFNBO).

Filed in Finnish · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Position Paper Revision of the Renewable Energy Directive (2018/2001) Publication date: November 2021 EUROFER Key Messages • • • • • • • Page |1 The achievement of targets on the integration of renewable and low carbon energy in the European industrial sector requires inevitably the deployment of a considerable amount of renewable and low carbon electricity and hydrogen at large scale, making them available at…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Alfaport Voka is the platform by and for companies and professional associations in the port of Antwerp, Belgium. Alfaport Voka is aiming for an accessible, facilitative, cost-competitive and sustainable port of Antwerp with a view to embedding sustainable employment and added value at the port.

RED 2 revision Input consultation OCI SUMMARY - Regulation should be should be technology neutral, safeguard a level playing field and maximize flexibility in circular feedstock of choice and fuel of choice - The 50% RFNBO mandate for industry impacts certain countries disproportional and is too high imposing high costs on industry.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

PLINOVODI d.o.o. as a TSO of gas infrastructure would like to highlight importance to extend the cooperation within electricity system operators and gas system operators to widen the scope of cooperation to grid investment planning and markets to better utilize the potential of district heating and cooling for providing flexibility services and to enable efficient storage of renewable energy surpluses and…

Aerospace and Defence Industries Associations of Europe (ASD) thanks the European Commission for this opportunity to comment on the proposal. ASD is committed to the ultimate objective to reach a net-zero emissions aviation ecosystem in Europe by 2050, and to strongly contribute to the EU’s 2030 ambition.

EFG Ref. Ares(2021)7093760 - 18/11/2021 European Fermentation Group POSITION PAPER November 2021 European Fermentation Group’s views on the review of the Renewable Energy Directive The European Fermentation Group welcomes the ongoing revision of the Renewable Energy Directive (RED II).

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Dear Commission, Please find Energy Norway's feedback on the proposal attached. Energy Norway is an association that represents the whole electricity chain in Norway. In other words, our members include companies producing, transporting and trading electricity. Our members produce 130-140 TWh annually, which is around 95 percent of all power production in Norway.

Grexel welcomes the opportunity to respond to the consultation on the review of the Directive on the promotion of the use of energy from renewable sources. As the leading energy certificate registry provider in Europe, Grexel helps customers to design new certifications schemes and cope with changing requirements set by international legislation and standards.

The European Automobile Manufacturers Association (ACEA) welcomes the proposal to revise the Renewable Energy Use Directive (RED) and the Fuel Quality Directive (FQD). RED is one of the key cornerstones of an effective policy framework which supports and enables the transition to carbon-neutrality. ACEA’s position paper on RED-FQD is attached.

The EU bioenergy sustainability policy must strengthen European forest industry's position in global competition. To deliver on climate objectives requires massive investments which require a stable and facilitating regulatory framework.

AGDW supports the objective of increasing the share of renewable energy in energy consumption from 32 % to 40 % by 2030. Energy from sustainable forest management residues is an indispensable element of a sustainable energy mix. However, we have serious concerns about the amended sustainability criteria for forest biomass in the draft revised RED II Directive submitted on 14.7.2021.

Filed in German · English published by the European Commission

The Renewable Energy Directive (RED II(I)) is a crucial part of the FF55 puzzle, and we support adjusting it to fit the decarbonization ambitions. First, we find it positive that that the RE-target is increased, however we would advise setting a target of 45% RE in 2030. This is in line with the swift buildout needed and supported by the Commission’s own impact assessment.

With the European Green Deal, the European Commission presented an ambitious growth and transformation strategy in December 2019, which is intended to bring about climate neutrality for Europe by 2050. In response to this landmark decision, the European Parliament and the European Council have committed to realigning the European climate targets for 2030.

Thank you for the opportunity to give feedback to this recast. We take the following position on the European Commission's proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on the promotion of energy from renewable sources of 14 July 2021 (EU Renewable Energy Directive -RED -): The proposal to recast and amend the Directive of the European Parliament and of the Council on Energy Efficiency (EED)…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Introduction: In the notion of the “twin transition”, the European institutions have endorsed a strategic focus on the need for a close synergy between the green transition and the digital transition – a partnership which is needed for the EU to deliver on its medium and long-term climate targets in due time.

CEMR acknowledges the need to increase renewable energy to reach EU climate targets for 2030 and carbon neutrality by 2050. We support ambitious climate and energy policy and action in line with 2050 climate neutrality for the EU, involving local and regional authorities (LRAs) as forerunners, as long as accompanied by appropriate frameworks, measures and financial resources.

The BDEW supports the objectives set at European and national level to achieve climate neutrality. These can only be achieved if available decarbonisation options are widely exploited. An essential prerequisite for a successful energy transition is an ambitious and accelerated expansion of renewable energy on land and at sea.

Filed in German · English published by the European Commission

18.11.2021 Euroopan komissio - Uusiutuvaa energiaa koskevat EU:n säännöt ± uudelleentarkastelu´$QQDSDODXWHWWD´ Euroopan komission uusiutuvan energian direktiivi (EU) 2018/1999 (´RED II´) Lappeenrannan-Lahden teknillinen yliopisto, LUT kiittää mahdollisuudesta lausua Euroopan komission uusiutuvan energian GLUHNWLLYLl (8   ´RED II´ koskevasta muutosehdotuksesta.

Filed in Finnish · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Etelä-Karjalan liitto kiittää mahdollisuudesta lausua Euroopan komission uusiutuvan energian direktiiviä (EU) 2018/1999 (”RED II”) koskevasta muutosehdotuksesta. Etelä-Karjalan liitto on aluekehitysviranomainen ja alueen edunvalvoja. Etelä-Karjalan liiton tehtäviin kuuluu muun muassa älykkään erikoistumisen strategian laadinta ja strategian toimeenpano omalla alueellaan kaakkoisessa Suomessa.

Filed in Finnish · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The RED builds on the European Green Deal, in which the Commission set out “a new growth strategy that aims to transform the EU into a fair and prosperous society, with a modern, resource-efficient and competitive economy where there are no net emissions of greenhouse gases in 2050 and where economic growth is decoupled from resource use.

TIF feedback to REDII: REDII should be amended so as to include hydrogen and RFNBO-fuels produced from low carbon sources. Also nuclear power contributes to reducing GHG emissions and therefore it must be regarded as low carbon energy. The EU-level target should remain indicative. Member States should have the obligation to include their targets in the National Energy and Climate Plans (NECP).

The revision of the Renewable Energy Directive creates the opportunity to make it the primary regulatory instrument to drive the effective and efficient decarbonisation of transport fuels and the development and deployment of renewable fuels, including from biological, non-biological origin, captured or recycled origin.

The Association of Owners of Municipal, Private and Church Forests (SVOL) welcomes the Commission’s initiative to review EU rules on renewable energy to contribute to higher climate ambition as part of the European Green Deal. SVOL supports the objective of increasing the share of renewable energy in energy consumption from 32 % to 40 % by 2030.

Filed in Czech · English published by the European Commission

BP PLC Transparency number: 3394026642-58 Ref. Ares(2021)7080063 - 17/11/2021 Renewable Energy Directive (RED III) We welcome the proposed target to increase the overall share of renewables to at least 40%, underpinned by sectoral targets. Renewable energy in transport bp believes electrification, supported by green electricity, is the best option for lowering emissions from passenger cars and light duty vehicles.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

As noted in previous consultation inputs by European State Forest Association (EUSTAFOR), we believe that the current criteria in the REDII are robust enough and effective, requiring that the biomass is sourced sustainably and negative impacts on biodiversity are minimized. Their revision risks bringing even more uncertainty to the market and unjustified administrative burden for operators and Members States.

FSC supports the EU Commission goal of ensuring that the EU Renewable Energy Directive (RED) contributes to the achievement of the highest climate and biodiversity protection ambition. For this, FSC would like to share the following three recommendations: 1. Reinforcing the REDII sustainability criteria for bioenergy in light with the EU Green Deal climate ambition. 2.

With the European Green Deal, the European Commission has set the goal of reducing net greenhouse gas emissions to zero by 2050. Moreover, to put the European Union on the path to climate neutrality, it also aims to reduce greenhouse gas emissions by at least 55 percent by 2030 compared to 1990 levels.

Contributos ou observações da APICER aos desafios colocados à sustentabilidade da competitividade, dos sectores que representamos, pelo Pacote Fit for 55 e em especial às Diretiva CELE/ETS, Diretiva Eficiência Energética e Diretiva das Energias Renováveis Agosto 2021 Rua Coronel Veiga Simão, Edifício C 3020-307 Coimbra Portugal T. [phone removed] F.

Filed in Portuguese · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

International Council on Clean Transportation consultation response on Amendment to the Renewable Energy Directive to implement the ambition of the new 2030 climate target November 17, 2021 This consultation response is submitted by the International Council on Clean Transportation (ICCT).

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The European Infrared Heating Alliance (EIHA), representing the infrared heating manufacturers in Europe, welcomes the opportunity to share its feedback on the proposed revision of the Renewable Energy Directive (RED). Achieving the 55 % emissions reduction targets by 2030 and climate neutrality by 2050 require ambitious policies to bring change in the EU energy system.

IAR, the French bioeconomy hub, welcomed the European Union’s desire to increase the share of renewable energy in the European energy mix. However, IAR considers that the share of bioenergy in the proposed European energy system is not ambitious enough, even though these forms of energy account for a significant proportion of the renewable energy consumption of several Member States of the European Union.

Filed in French · English published by the European Commission

RAG Austria welcomes the inclusion of hydrogen in the EU's climate strategy. Nevertheless, we see a need for improvements in the RED III draft in the following areas: • Technology openness: Ambitious targets can only be achieved in the short term if proven, efficient and economical technologies are allowed on an equal footing; • Imports: Europe will be dependent on secure supplies of green energy from third…

Fit-for-55 – Renewable Energy Directive November 2021 Eurogas welcomes the higher ambition of the European Commission in its proposed of revision of the Renewable Energy Directive. Nevertheless, this ambition is not enough, nor properly translated for gaseous fuels. There is no dedicated driver that would focus on the decarbonisation of gaseous energy.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

LanzaTech commends the European Commission for its proposal to amend the Renewable Energy Directive (RED). The Renewable Energy Directive is a vital legislative tool to turn the EU's Green Deal ambitions into a reality. We welcome the opportunity to respond to the EU Commission's proposal and working alongside the co-legislators in the future.

FEDENE is a French professional association representing 500 energy and environmental service companies. From public and private district heating and cooling (DHC) operators to energy service companies (Escos), FEDENE’s members employ 60.000 professionals developing sustainable services.

Filed in French · English published by the European Commission

We support increasing the target for renewable energy from 32 to 40%, but believe that it could be raised further, to 50% in 2030 if the target for the transport sector is raised, which is possible if the attitude towards biofuels from agricultural crops is changed and restrictions on these biofuels are removed. The target for the transport sector of 13% greenhouse gas reduction is too low.

GRUPPO TERNA/P20210093719-17/11/2021 - Allegato Utente 1 (A01) Ref. Ares(2021)7077447 - 17/11/2021 TERNA RESPONSE TO THE EC CALL FOR CONTRIBUTION TO THE FIT FOR 55 PACKAGE Proposal for a revision of the Renewable Energy Sources Directive “RED III” Terna welcomes the opportunity to provide its preliminary views to the European Commission public consultation on the RED III proposal as part of the wider “Fit for 55”…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Turboden S.p.A. welcomes the initiative of the European Commission on the Renewable Energy Directive Recast. We strongly support the policy recommendations aiming at the promotion of renewable sources and the efficient use of them. By the next decade, the EU must halve its greenhouse gas emissions and slash its fossil fuel dependency.

REPSOL supports the Green Deal’s ambition for climate neutrality in 2050 and will work with the EU institutions, member states, and stakeholders, to help create the essential enabling policy framework. We appreciate that the revision of the Renewable Energy Directive (RED) provides the opportunity to step up the contribution of sustainable and renewable liquid fuels in transport.

IBERDROLA welcomes the revision of the Renewable Energy Directive (RED) IBERDROLA supports the following aspects of the proposal: • Increase of the RES target to 40%, in line with the highest ambition for 2030. • Introduction of an explicit supportive framework for renewable electricity Power Purchase Agreements, especially for dealing with credit risk.

FEDIAF, the European Pet Food Association, acknowledges and supports the role of renewable energy in achieving the climate ambitions of the EU. Our members have made several commitments in this area already. We believe the revision of the Renewable Energy Directive and its Annex IX provides a good opportunity to address these challenges.

Cooling is present in many aspects of our lives, playing an essential part in support of a variety of societal needs, ranging from food conservation and healthcare to residential and office comfort, and data center operations. In this context, it is no wonder that refrigeration and air conditioning applications have a significant share of the global energy consumption.

Neste welcomes the overall increase in transport decarbonisation ambition through the Fit for 55 package and the specific target for transport in the renewable energy directive. However, Neste regrets that the European Commission proposes changing the GHG calculation rule for biofuels which are currently accepted under REDII so shortly after national transposition.

Region Kalmar County welcomes the fit for 55 package, as our county has a target to be completely fossil fuel free by 2030. Our regional development strategy builds on the following principles: our work should contribute to less fossil CO2 emissions, more efficient use of energy and a growing business sector contributing to a sustainable development. The public sector should be a frontrunner for this development.

Einride strongly believes that nearly half of heavy freight transport can be electrified immediately. Technically speaking, it is already feasible. But to get there, we need to challenge the status quo and in some ways start from scratch. Electrification of the transport sector will require a whole new ecosystem when it comes to logistics.

WKÖ supports the European Green Deal and stands by the climate neutrality goal by 2050. Now a concrete set of measures for a sustainable, ecological change in the EU, in line with a new growth strategy, is necessary. WKÖ will contribute to a legislative package that meets the requirements of effective climate protection and at the same time is practicable and compatible with economic prosperity.

Danish Shipping welcomes the proposal which in combination with the proposals on inclusion of shipping in the Emissions Trading System and FuelEU Maritime provide a sound mix of regulatory measures on the path to climate neutrality by 2050.

Response to COM(2021) 557 final MM Kotkamills welcomes the opportunity to respond to Commission’s proposal on the revision of the directive COM(2021) 557 (later RED III). The revision is part of the European Green Deal and Fit for 55 package. Fit for 55 aims to decrease emissions in different sectors while increasing carbon sinks.

Yara strongly supports the roll out of green & blue hydrogen economy. Our know-how and products will deliver low-carbon solutions to decarbonize agriculture, shipping and the wider economy. However, this transition requires a coherent and well-timed package of regulations, enabling energy infrastructure, funding and demand creation of low carbon end-products to develop in parallel.

17.11.2021 VC EU Fit For 55 – Paket Renewable Energy Directive RED III Energy Efficiency Directive EED III POSITIONSPAPIER Der Fachverband Steine-Keramik als gesetzliche Interessenvertretung der österreichischen Baustoffindustrie vertritt 313 Mitgliedsfirmen mit einem Gesamtjahresumsatz von € 3,23 Milliarden und knapp 14.000 Beschäftigten.

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Association for Gas Heat is grateful for the possibility of providing feedback on the Commission’s proposal for a revised directive on the promotion of energy from renewable sources. Please find below our comments.

Filed in German · English published by the European Commission

The VKU is grateful for the possibility to present the proposal to amend the Directive. to comment on the promotion of the use of energy from renewable sources. VKU positions in the near future (see detailed opinion attached): — The use of renewable and otherwise sustainable and greenhouse gas neutral electricity produced for the production of heat and gas, Fuels and industrial manufacturing processes (“sector…

Filed in German · English published by the European Commission

17-11-2021 Aedes - Association of Dutch Housing Corporations Feedback on the revision of the Renewable Energy Directive Introduction Aedes welcomes the opportunity to share its feedback on the proposed revision of the Renewable Energy Directive (RED). It is crucial that the revised RED bring about the intended systemic change and contributes to the much-needed green transition.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

FuelsEurope response to the public consultation on the Renewable Energy Directive proposal. FuelsEurope supports the Green Deal’s ambition for climate neutrality in 2050 and will work with the EU institutions, member states, and stakeholders, to help create the essential enabling policy framework.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Gas Networks Ireland (GNI) welcomes the publication of the European Commissions (EC) legislative proposal for the revision of the Renewable Energy Directive (RED II). The increased overall ambition shown with the Directive, alongside the overarching Fit for 55 Package, provides a strong legislative basis for achieving the 2030 targets and the long-term goal of net zero by 2050.

The CEA welcomes the strengthening of the targets for the deployment of renewable energy in Europe, although it regrets that these targets do not target all low-carbon energy sources. A point of care, however: Although necessary, the development of renewable energy is not sufficient in itself to reduce the consumption of fossil fuels, in particular if energy consumption increases or renewables replace other…

Filed in French · English published by the European Commission

European Commission DG ENER Unit C1 Brussels, 16 November 2021 EPF feedback on the review of the EU renewable energy rules The European Panel Federation (EPF) warmly welcomes the possibility to provide feedback on the review of the EU renewable energy rules as part of the ‘Fit for 55’ package.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

In line with the waste hierarchy and the cascading use of biomass principle, feedstocks available in limited volumes, providing high socio-economic and environmental benefits and having higher value uses other than energy recovery shall be allocated in priority to those industrial uses. DRT proposes 2 options to ensure those feedstocks (incl. tall oil) are used to meet the EU Green Deal ambition: 1.

Připomínky Hospodářské komory ČR k návrhu SMĚRNICE EP A RADY, kterou se mění směrnice Evropského parlamentu a Rady (EU) 2018/2001, nařízení Evropského parlamentu a Rady (EU) 2018/1999 a směrnice Evropského parlamentu a Rady 98/70/ES, pokud jde o podporu energie z obnovitelných zdrojů, a zrušuje směrnice Rady (EU) 2015/652 Obecné připomínky: V rámci revize Komise nově navrhla zvýšení unijního cíle pro podíl energie z…

Filed in Czech · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Oesterreichs Energie welcomes the increase in the target share of renewables in final energy consumption in 2030 from 32% to 40%. Integration of the energy system is central to achievement of the EU’s climate protection targets.

The European Data Centre Association (EUDCA) represents the European data centre operator (DC) community. The EUDCA is happy to submit feedback on the review of EU renewable energy rules and wants to draw attention to the following key points: • EUDCA welcomes the review of the Renewable Energy Directive (RED) in light of a higher EU climate ambition under the European Green Deal; • EUDCA supports the binding target…

Plant of Portoscuso (SU) Proposal of Renewable Energy Directive amending 2018/2001 EU Directive, EU Regulation 2018/1999 and EU Directive n.98/70 – COM (2021) 557 final of 14.7.2021 Revision: 02 Date: November 2021 File name: EA_Feedback on Renewable Energy Directive Plant of Portoscuso (SU) Proposal of Renewable Energy Directive amending 2018/2001 EU Directive, EU Regulation 2018/1999 and EU Directive n.98/70 – COM…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

MTK is in favour of a separate minimum share for advanced biofuels and biogas produced from raw materials in Part A of Annex IX. MTK is also in favour of abolishing double counting. Finland has already abandoned double counting in the past, and the blending obligation rates applied in Finland are significantly higher than those imposed by the EU.

EARSC Contribution EU Renewable Energy Rules - Review The European Association of Remote Sensing Companies (EARSC) is a trade association based in Brussels, Belgium that represents the European Downstream services sector creating added-value services and products based on Earth Observation satellite data. EARSC has more than 130 members across 25 European countries.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The following aspects should be taken into account. Adaptation of the RES expansion target for 2030 from 32 % to at least 40 % As a matter of principle, we would point out that the requirement for GHG reductions in other regulations makes targets obsolete, as the impact on climate protection is governed solely by GHG reduction.

Filed in German · English published by the European Commission

We welcome the Commission’s intention to adapt REDII to meet the increased climate change objectives and to further develop REDII as a regulatory basis for a wider use of renewable energy in various forms in the transport and heat sectors.

Filed in German · English published by the European Commission

Eurelectric supports the increased 2030 EU RES target of at least 40%. The key role of renewable electricity is recognised through different amendments, for example, MSs setting up RES-E frameworks, the issuance of GOs for every MWh of renewable energy produced upon request from producer independently of benefitting or not from a support scheme, the enhanced requirement for promoting PPAs, better coordination in…

Business travel is fundamental to the world economy and brings many benefits in terms of international connections and wealth creation. However, climate change is a global threat and responsible governments, industries and corporations must continue to work together to reduce carbon emissions and operate in a more sustainable manner.

Renewables and RFNBOs need to become competitive The amending Directive focuses on increasing the renewable energy target to at least 40 % by 2030. For the industrial sector, an indicative annual increase in the share of renewables and a binding target of at least 50 % RFNBO share of hydrogen use by 2030 is set.

Filed in German · English published by the European Commission

Fit-for-55 Package Initial reaction September 2021 We provide herein our initial reaction to the Fit-For-55 Package about some priority issues for the Italian Business sector, provided that sector’s specific positions are still under definition.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The development of RES is the key instrument for decarbonising the EU economy. The revision of the Directive 2018/2001 is thus needed to adapt it to the increased emission reduction target. To this extent, the provisions related to the revision of existing targets; the inclusion of new sub-targets (e.g.

The Federation of European Private Port Companies and Terminals FEPORT Position Paper on the EU Commission proposal for a revised Renewable Energy Directive (RED III) Introduction FEPORT is the European association which represents the interests of 1225 private companies and terminals performing cargo handling and logistics related activities in the seaports of the EU.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

With the revision of the Renewable Energy Directive, he Commission is setting policy measures to increase efforts in renewable energy. However, it does not necessarily encourage clean electrification, in particular of buildings, industry and H&C. This leads to vague/absent provisions on their flexible integration with the electricity system, notably in art. 15a (buildings), 22a (industry) and 23 (H&C).

The Northern Sparsely Populated Areas network, NSPA, represents the interests of the four northernmost regions of Sweden (Norrbotten, Västerbotten, Jämtland Härjedalen and Västernorrland), the seven eastern and northernmost of Finland (Central Ostrobothnia, Kainuu, Lapland, North Karelia, Northern Ostrobothnia, Pohjois-Savo and South Savo), as well as the two northernmost regions of Norway (Nordland, Troms &…

The increased use of renewable energy in existing buildings and the proposed leading role of the public buildings in the demanding process of energy efficiency improvement is undoubtedly important and the introduction of the new Article 15a is a proper regulation for this purpose.

Filed in German · English published by the European Commission

JAPAN AUTOMOBILE MANUFACTURERS ASSOCIATION, I NC. JIDOSHA KAIKAN 1- 30 , S H I B A D A I M O N 1 - C H O M E , M I N AT O - K U T E L : +81 ( 3 ) 5 40 5 - 61 26 TO K Y O , 10 5 - 001 2 J A PA N FA X : +81 (3 ) 5 40 5 - 61 36 2 November, 2021 JAMA’s feedback response to the European Commission on the ‘Fit for 55’ legislative proposal package under the European Green Deal The Japan Automobile Manufacturers Association…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Swedish Forest Industries’ position on REDIII in the “Fit for 55”-proposal Please find the full feedback in the attached position paper. Summary Support a higher renewable share in the EU energy mix, but allow for rules on forest biomass to be properly evaluated before new ones are discussed The Swedish Forest Industries support the Green Deal and the important goal of a climate neutral society by 2050.

The National Union of Wine Distilleries (UNDV-France) represents the adherent wine distilleries located in the various French wine-growing basins. UNDV is a circular economy sector with excellence and is ready to contribute to the objectives of Fit for 55, but the elimination of double counting prevents this sector from contributing to the decarbonisation of the economy.

Filed in French · English published by the European Commission

The Swedish Gas Association – Energigas Sverige, the industry organisation in Sweden – is thankful for the invitation to contribute comments on the Commission’s revision of the Renewable Energy Directive (hereafter called RED III), 14 July 2021. The Swedish Gas Association has only had a short time to examine the proposal, and thus has only been able to analyse it a limited amount of detail.

Aughinish Alumina Ltd Feedback on Energy Efficiency Directive legislation proposal within the Fit for 55 Package Executive summary Aughinish Alumina (AAL) is own by Rusal and AAL is the largest alumina refinery in Europe. Based on Ireland’s West Coast, it is also the one of the largest energy consumer in the country. AAL operates in the 5% lowest carbon intensity within the alumina industry globally.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

• MVV Energie AG welcomes the revision of the Renewable Energy Directive (RED). We strongly support the aims of European Green Deal and the Fit for 55 package to reduce greenhouse gas emissions and become the world's first climate-neutral continent by 2050. • We also welcome the proposed increase of the renewable share of the EU final energy consumption from 32 % to at least 40 % by 2030.

It is essential that we protect the environment. To this end, it is also important that we gradually reduce all harmful emissions. Crucially, however, the overall balance is positive, not just local emissions (Thea Well to Wheel). If an incinerator vehicle is fuelled with synthetic fuel, using existing sustainability systems, for example. If 80 % of CO2eq is saved, this saving should be attributed to the vehicle.

Filed in German · English published by the European Commission

LOTOS Group position on the revision of Directive (EU) 2018/2001 on the promotion of the use of energy from renewable sources (RED) 1. Obliged entities The draft revision of the RED directive provides that Member States are to oblige fuel suppliers to achieve a minimum emission reduction target of 13%.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

GD4S welcomes the ongoing revision of the Renewable Energy Directive (REDII). The publication of the Energy System Integration and Hydrogen strategies has underlined the importance of renewable gases in achieving carbon neutrality in a cost-efficient way. The revision of REDII is the legislative opportunity to stimulate their development.

PGE Polska Grupa Energetyczna S.A. (hereinafter: “PGE S.A.”) welcomes the revision of the Directive on the promotion of the use of energy from renewable sources as a prerequisite to further streamlining green energy in the pursuit to achieve climate neutrality by 2050.

Ares(2021)6879093 - 09/11/2021 Position Ref. Paper Zürich Biogem Express GibGas OrangeGas SNAM November 2021 Zürich 5 Coalition position on the proposed Renewable Energy Directive III (2021/0218) Zürich Position paper: Renewable Energy Directive III (2021/0218) The Zürich 5 Coalition (hereinafter ‘the Coalition’) is expressly committed to achieving the objectives of the Paris Agreement and supports the EU’s ambition…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Iogen Corporation supports “Fit for 55”, the transformational changes that are required to achieve the EU’s 2030 decarbonisation goals and climate-neutrality by 2050. Indeed, we as a company are fully dedicated to using our world-leading advanced biofuels technologies to develop deep carbon-negative fuels based on green biohydrogen, a process we have successfully commercialised.