Renewable Energy Directive

November 05, 2021 Response to the public consultation on the proposal for revision of the Renewable Energy Directive (RED) Sonae is a multinational corporation managing a wide portfolio of businesses in retail, financial services, technology, wood-based panels, shopping centres and telecommunications, creating value acrocss several geographic areas.

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

We believe that setting the proposed 13% greenhouse gas intensity reduction target as well as the increased sub-target for advanced biofuels to 0.5% in 2025 and 2.2 % in 2030, and the introduction of the sub-target 2.6% for energy from renewable fuels of non-biological origin (RFNBO) should be a minimum and preferably be exceeded.

District heating and cooling The PKEE members have made and continue to make numerous investments to replace existing coal-fired heating sources with highly efficient cogeneration ones based on natural gas because the use of renewables in large-scale district heating systems is limited.

Finnish Forest Industry Federation Industry (FFIF) hope that the FF55 package including RED will provide regulatory stability which promotes the industry’s investments in climate friendly products and production as well as in sustainable forestry.

Finnish Forest Industry Federation Industry (FFIF) hope that the FF55 package including RED will provide regulatory stability which promotes the industry’s investments in climate friendly products and production as well as in sustainable forestry.

SEA-LNG Feedback on the Proposed Amendments to the Renewable Energy Directive (RED III) SEA-LNG Founded in 2016, with numerous high-profile members including shipping companies, ports, LNG suppliers, bunkering companies, infrastructure providers and OEMs (Original Equipment Manufacturers), classification societies, banks and brokers, SEA-LNG is a multi-sector industry coalition whose members work together to…

With energy efficiency and nuclear energy, renewables are crucial for achieving the transition to a carbon-neutral economy in the EU. For this reason, their development should be an important goal of the Fit for 55 package, and EdEn welcomes the proposal published by the Commission in July to revise the RED.

The Norwegian Oil and Gas Association (NOROG) organises companies which produce oil and gas on the Norwegian continental shelf, supply the operations there, or work at sea with renewable energy or mineral production. We support the goals of the Paris Agreement and the EU’s ambition to reach climate neutrality by 2050.

Please find attached the Composite Panel Association's (CPA) submission on the proposal to amend the Renewable Energy Directive (RED) 2018/2001, specifically in regard to the promotion of energy from biomass sources.

EURACOAL is pleased to submit its attached response paper on the proposed amendments to the Renewable Energy Directive. In summary, we wish to make four points in response to the European Commission's proposal: • EURACOAL welcomes the support for electricity generated from biomass at coal power stations.

France Hydrogène welcomes the new proposals on hydrogen included in the recast of the Renewable Energy Directive (RED III). In line with the EU Hydrogen Strategy, the proposals for end-uses targets for renewable hydrogen in the transport and the industry will stimulate the supply and demand of clean hydrogen and encourage the development of a competitive European hydrogen industry.

The eFuel Alliance is a stakeholder initiative committed to promoting the political and social acceptance of eFuels and to securing their regulatory approval and represents more than 150 companies along the value chain of eFuel production. The use of all relevant emission reduction solutions is key for achieving the European Union’s target of climate-neutrality by 2050.

Östergötland is a prosperous region, with a thriving forestry industry and agricultural sector. These sectors provide favourable conditions for the development of co-production of high value bioenergy products with the potential to create environmental benefits in the region, where to promote economic growth in a circular value chain.

Filed in Swedish · English published by the European Commission

POSITION PAPER OCTOBER 2021 Cefic views on the Commission proposal amending the Renewable Energies Directive (RED III) Cefic welcomes the Commission ambition to increase the use of renewable energies by 2030. Europe urgently needs to upscale renewable energies and prepare import routes, to lower the CO2 content of energy produced and help facilitate the transition towards a climate-neutral energy system.

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

Background In order for Sweden to reach its ambitious targets in the transport sector, with a 70 % reduction in the climate impact by 2030, a significant increase in the share of sustainable biofuels is required. For this to happen, an effective and long-term regulatory framework within the EU must be in place allowing Sweden to create the right conditions for biofuels.

Filed in Swedish · English published by the European Commission

Buildings: CGA considers the nature and the level of the newly proposed binding target for Member States as regards the share of RES in heating and cooling by 1.1 pp/per year as unachievable in the given conditions of the Czech Republic. We are afraid that unrealistic targets would fail reaching even lower, still realistic targets.

E.DSO welcomes the revision of the EU’s approach to renewable energy (RE) and the FF55 package as a tool to equip the EU’s economy for climate neutrality. The proposal entails important consequences for DSOs which will have a central role in an integrated energy system with the customer at its centre.

Comments from Malaysian Palm Oil Board Palm oil is an essential economic sector for Malaysia as it provides a high value commodity for world trade and jobs for Malaysians. The biodiesel sector in Malaysia is one business that thrives with biodiesel trade as well as the local Malaysian biodiesel mandates. Malaysia has had success in implementation of B10 blending for the whole country since 2019.

The Commission’s proposal is too restrictive as it essentially identifies direct electrification and district heating and cooling as the only solutions to decarbonise the energy sector. Such an approach however is very narrow, as it fails to acknowledge the potential of low carbon and renewable liquid fuels for heating in off-grid areas (https://www.eurofuel.eu/images/Heating_with_liquid_fuels.pdf).

Amending Directive (EU) 2018/2001 on the promotion of the use of energy from renewable sources: Submission from SBP Introduction SBP is a multi-stakeholder, voluntary certification scheme designed for solid woody biomass used in large-scale energy production.

In order for the transformation envisaged by the European Green Deal to succeed and the set renewable energy targets to be achieved, appropriate low-CO2 alternatives to energy supply are necessary. That is why more electricity from renewable sources, climate-friendly gases and fuels as well as renewable heat in adequate quantities are required.

ENTSOG (European Network of Transmission System Operators for Gas) welcomes the European Commission’s legislative proposal COM (2021) 557 on the revision of the Renewable Energy Directive and would like to support the future legislative process with the following comments and proposed changes (please see attached). We hope our contribution will help policymakers better assess available policy options.

UPRIGAZ supports the “Fit for 55” and the proposed methodology of setting new, more ambitious targets for 2030: Increase the share of ENR in the mix, increase energy efficiency, new standards on alternative or renewable fuels. UPRIGAZ welcomed the introduction of carbon price signals that would guide operators. As regards ENR, UPRIGAZ emphasises the opportunities offered by renewable gases (biomethane, hydrogen).

Filed in French · English published by the European Commission

On 14 July, the European Commission took an important step towards reducing greenhouse gas emissions in Europe. The “Fit for 55” package aims to introduce the necessary policy and legislation for Europe to reduce its greenhouse gas emissions by at least 55 % by 2030.

Filed in Spanish · English published by the European Commission

PVthin welcomes this opportunity to provide feedback on the European Commission’s proposal to review the Renewable Energy Directive (RED III). PVthin supports the direction set by the Fit for 55 Package and encourages EU Member States and the European Parliament to work further to increase the uptake of solar PV. The RED III review proposes a number of changes that will have a significant impact on our sector.

The CDR welcomes the fact that, as a result of the Green Deal and the EU Climate Law, the European Commission is aiming for a more ambitious expansion of renewable energy sources. In the view of the CDR, bioenergy can make a decisive contribution to achieving the EU’s climate objectives, especially in areas where other climate technologies reach their limits.

Filed in German · English published by the European Commission

In order to achieve more ambitious GHG emissions reduction target – 55 % by 2030 compared to 1990 levels, the European Commission proposing the increase of the share of RES in final energy use from present set 32 % to 40 % by 2030. At the EU level this means doubling the share of RES in only one decade, since the current share of RES in final energy use is only 20 %.

Filed in Slovenian · English published by the European Commission

We would like to thank you for the opportunity to comment on the Commission’s current proposal on RED III. So far, technology freedom has been an important factor in successfully contributing to the energy transition and achieving the Paris climate goal. It was integrated into any EC climate and energy strategy and was intended to promote and support alternative renewable fuels.

Filed in German · English published by the European Commission

ElaadNL is the knowledge and innovation centre in the field of Smart Charging and the charging infrastructure in the Netherlands and is an initiative of the Dutch grid operators. ElaadNL welcomes the revision of the REDII and the fact that smart charging capabilities become mandatory under the directive for non-publicly accessible recharging infrastructure.

The Fit for 55 package sets important new goals for emissions reduction in transport. Giving a prominent role to renewable liquid fuels would create a solid foundation for reaching them. The EU should fully maximise the tools it has on hand for decarbonisation and de-fossilisation, starting with the RED.

The International Association of Oil & Gas Producers’ (IOGP) supports the goals of the Paris Agreement and the EU’s ambition to reach climate neutrality by 2050. We recognise that there are many challenges on the road to meet this objective as the energy transition will require significant investments, new technologies, effective policies and behavioural changes.

THE DANISH CHAMBER OF COMMERCE Børsen 1217 København K www.danskerhverv.dk [email removed] T. [phone removed] Ref. Ares(2021)5892791 - 28/09/2021 The European Commission DG ENER Unit C1 24 September 2021 The Danish Chamber of Commerce’s consultation response regarding the Renevable Energy Directive (RED) The Danish Chamber of Commerce thanks the EU Commission for the opportunity to respond to the revision of the EU…

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

The Spanish Cement Manufacturers Grouping OFICEMEN appreciates the opportunity to provide its considerations to the Commission’s public consultation on the review of Directive (EU) 2018/2001 on the promotion of the use of energy from renewable sources (RED II) and Regulation (EU) 2018/1999 on the Governance of the Energy Union and Climate Action.

Filed in Spanish · English published by the European Commission

APPA Biomass welcomes the higher targets for renewable energy in the Renewable Energy Directive but has several reservations regarding certain provisions. GOVERNANCE. We object to the revision of sustainability criteria in REDII before they have even been fully transposed into national law.

PUBLIC REPLY Reply to the Proposed Renewable Energy Directive III The Lithuanian Biomass Energy Association LITBIOMA unites over 40 companies, working in the field of biomass resources exploration and enhancement, biofuel production and supply, biofuel technologies (biofuel boilers and boiler houses production and construction), heat energy production.

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

Parking Energy’s views on the proposal on the revised RED II Parking Energy welcomes the European Commission’s proposal on the revised Renewable Energy Directive (RED II). Parking Energy supports the European Green Deal and the resulting target of reducing greenhouse gas emissions from transport by 90 % by 2050 compared with 1990, as part of a larger effort to become a climate-neutral economy.

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

EPEX SPOT welcomes the opportunity to provide input to the present consultation on the review of the Directive on the promotion of the use of energy from renewable sources. We support the revision of this directive, including the increased renewable energy targets, which are essential to meet the objectives of the Green Deal.

EEX welcomes the opportunity to take part in the consultation on the review of the Directive on the promotion of the use of energy from renewable sources. We support the review of the directive, including the reconsideration regarding the renewable energy targets, marking an essential step into the right direction to meet the objectives set under the Green Deal and transform the EU into a carbon neutral economy by…

Overall: - The access to ample and cheap renewable electricity is a precondition for decarbonization, in particular for industry which will have to achieve large-scale CO2-reductions via process electrification. The accelerated deployment of renewable energy, in particular wind and solar, is welcoming and should be supported with ambitious targets of at least 40% by 2030.

Key points: Following the European Commission’s proposal for an updated Renewable Energy Directive (RED-3) the European Parliament and European Council should: 1. Retain the requirement to issue GOs for all renewable energy generation, whether it benefits from a support scheme or not; 2.

RED II revision brings opportunities to consolidate a Europe-wide approach to developing standards and harmonising national arrangements for the issuance, use and cancellation of Guarantees of Origin (GoOs) in the gas sector as well as the power sector. The AIB has already developed a standardised system: the European Energy Certificate System - "EECS".

August 2021 SEKAB position on THE PROPOSAL FOR A RENEWABLE ENERGY DIRECTIVE Introduction SEKAB supports the EU’s commitment to carbon neutrality by 2050 and increased levels of ambition for 2030 greenhouse gas (GHG) reduction targets proposed in the European Green Deal and legislated for in the Climate Law.

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

The Energy & Nature Conservation Action Group (AKEN) welcomes the intention to revise RED II, which in our view is urgently needed. We have identified two fundamental problems of RED II which need to be addressed. On the one hand, the a priori limitation of future energy supply options by RED II to certain pre-defined, restrictive methods of energy supply, leading to a lack of but necessary technology openness.

Filed in German · English published by the European Commission

As an agricultural organisation, we want to draw attention to the possibilities and bottlenecks for the production of renewable energy in the countryside. In Flanders (and probably also in the rest of Europe), the agricultural sector also produces a lot of solar energy.

ZWE welcomes the EC proposal for the Renewable Energy Directive (RED) reform. In order to ensure that the RED only supports energy from biogenic wastes, it should only allow energy from separately collected biowaste or biogenic waste that is segregated from fossil waste in case of mixed waste.

The Swedish Wind Energy Association (SWEA) welcomes the initiative to intensify the efforts to reach the climate targets and appreciates the opportunity to provide feedback. Swedish wind power may contribute considerably to affordable electrification and timely climate transition in the Baltic region, provided that a few barriers are removed.

The Confederation of Norwegian Enterprise (NHO) welcomes the opportunity to comment and to provide inputs to the EU renewable energy rules review. NHO supports the EU ambition of net-zero greenhouse gas emissions (climate neutrality) by 2050 to reach the objectives of the Paris Agreement.

CEPM, Confédération Européenne de la Production de Maïs, supports the contribution of agriculture and corn to the decarbonisation of energy, in particular in fuels for transport and for natural gas. European maize makes it possible to produce sustainable bioethanol and biomethane which help to reduce EU energy dependence, and concomitantly, with the protein-rich DDGS from the production of bioethanol, to reduce the…

Central Europe Energy Partners (CEEP), an organisation representing the interests of the energy companies from Central Europe, welcomes the possibility to provide feedback to the Commission’s Inception Impact Assessment on the revision of the RED II.

Within the next few years, the ground-breaking technologies that are being developed by European companies will make new geothermal resources available in most EU Member States. As a result, deep geothermal energy installations could provide clean and affordable energy alternative to fossil and nuclear power plants around Europe.

We write on behalf of Bio Oil Group and operate along the value chain from waste collection to its processing into waste-based biodiesel. Below are our recommendations. 1. Upward revision of the 14% transport obligation (Article 25 (1)) The upcoming revision of the RED II will review the general 32% target of use of renewable energy in 2030, as stated in the European Green Deal and further confirmed in a recent…

We strong belive in renewable energies and we are looking forward to the new challenging objective trajectory given by Europe. We are biodiesel producer of 1st and 2nd generation, with 4 biodiesel plants in Europe (Spain and Italy) To guarantee the availability of biodiesel to reach the ambitious target necessary to stop the climate change in a sustainable way, it is important to include all raw materials available…

WWF welcomes the fact that the Commission has recognised that REDII is not consistent with the achievement of the EU’s 2030 GHG target or with the goals of the Paris Agreement and needs to be reformed. The points within the legislation that need urgently to be amended are as follows: - The 2030 RES target needs to be increased to at least 50% in order to be consistent with the goals of the Paris Agreement; - The…

The European Automobile Manufacturers' Association (ACEA) welcomes the opportunity to provide feedback on the inception impact assessment towards a revision of Directive (EU) 2018/2001 on the promotion of energy from renewable sources (RED). Please find attached our contribution.

Consultation on RED II Inception Impact Assessment Summary Feedback from Wild Europe Wild Europe welcomes the concept of increased ambition by the EU and its member states to address climate change through net reduction in GHG emissions towards 55% by 2030. But this must lead to clear and uniformly positive impact in practice.

The German Biogas Association welcomes the EU's ambition to revise the Renewable Energy Directive's goals. The German Biogas Association thinks it very necessary to align the different legislative acts and thus votes for option 5. Binding targets are needed in order to accelerate the greenhouse gas emissions reduction and to ensure that renewable energy is deployed across all sectors throughout Europe.

The EU renewable energy rules (Directive 2018/2001/EU) puts the active customers at the centre. The Directive is suggesting to introduce market-based systems to make the markets fit for increasing shares of renewable energy.

As one of the first homegrown battery manufacturers in Europe, Northvolt’s mission is to produce the world’s greenest batteries. Hence, Northvolt have always been strong advocates of carbon footprint declarations for battery cells and products.

To reach the Paris Agreement objective of limiting global warming to 1.5°C, EU Member States need to phase out fossil fuels and transition to a 100% renewables-based energy system by 2040. The current 2030 EU RES target of 27% is not in line with this effort.

ClientEarth acknowledges the European Commission's initiative to revise the Renewable Energy Directive (REDII) in line with a new climate ambition. However, ClientEarth does not agree with the 55% emissions reduction target recently proposed by the European Commission and calls for a more ambitious 2030 emissions reduction target of at least 65%, without including offsetting by carbon sinks in the land use sector.

Dear Sir or Madam, the register of guarantees of origin at the Federal Environment Agency is the national issuing body for Guarantees of Origin for electricity in Germany. In addition to the enforcement and further development of the GOs for electricity, it coordinates their international transfer and take care of the verification of national electricity disclosure.

Filed in German · English published by the European Commission

Comments from The Swedish Wood-Fuel Association We strongly recommend not to open a revision of the RED II. It was adopted not long ago after thorough negotiations. The directive has not yet been implemented in the members states. It will cause uncertainty for the markets actors if the directive should be revised at this stage. Article 29-31 should not be changed.

On behalf of our six million members and supporters and 51 affiliate organizations across the United States, the National Wildlife Federation appreciates the opportunity to provide feedback on "EU renewable energy rules." As the largest advocacy-focused conservation organization in the United States, the National Wildlife Federation has a long history working on biomass.

Habitat for Humanity Hungary (HfHH) would like to highlight key issues that can ensure a just energy transition from the point of view of energy poor households in Hungary and Central and Eastern Europe. Deployment of renewable energy (RE) and reduction of greenhouse gas (GHG) emission must ● be rigorously inclusive to maximize its potential of tackling energy poverty (and its extreme forms such as lack of access to…

EDF welcomes the opportunity to comment on the Roadmap related to the review of the EU’s renewable energy rules. As the European leader of carbon free electricity with a close to 90 % decarbonized generation mix, EDF strongly supports the target of net zero emissions by 2050 and an increased GHG emission reduction target by ‘at least 55%’ in 2030.

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

In line with the European Green Deal, and the urgent need for a stronger action against climate change, we strongly support the EU’s climate neutrality goal for 2050 and the recent Commission’s proposal to increase the EU 2030 greenhouse gas emission reduction target at least 55% from 1990 level.

ENGIE welcomes the opportunity to participate to this consultation allowing to stimulate reflections on how a revised Renewable Energy Directive (RED) can effectively contribute to a more integrated energy system which should enable the achievement of greenhouse gas (GHG) reduction targets and carbon-neutrality by 2050 at lowest cost for society, while ensuring security of supply.

With the publication of the European Green Deal in December 2019, the European Commission announced the revision of the Renewable Energy Directive 2009/28/EC and the Recast Directive 2018/2001/EU by June 2021. The attached position paper constitutes Air France-KLM’s initial views towards the announced revision.

Response to Roadmap Feedback: EU renewable energy rules – review About Hydrogen Europe Hydrogen Europe is the European association representing the interest of the hydrogen and fuel cell industry and its stakeholders. We promote hydrogen as the enabler of a zero-emission society.

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

Danfoss welcomes the inception impact assessment presented by the European Commission on the Renewable Energy Directive (RED). The European Union has settled to increase its climate ambition for 2030 and to become climate neutral by 2050. This requires a significant increase of the share of renewables in our energy mix, especially in the industry, buildings and transport sectors.

We write on behalf of ABA (Advanced Bioenergy Association) from Portugal. We welcome the early revision of the REDII as an excellent opportunity to further improve certain elements of the existing regulatory framework to ensure that the EU achieves carbon neutrality by 2050. We set out here below key improvements of REDII provisions supported by the waste-based biodiesel industry: 1.

The German aviation industry as one of the hard-to-decarbonise-sectors is committed to the EU climate goal of greenhouse gas neutrality by 2050. The German Aviation Association very much welcomes the initiative to revise the RED II earlier. In order to be able to fly carbon-neutral, fossil fuels must be replaced by Sustainable Aviation Fuels (SAF).

Review of EU renewable energy rules – Roadmap consultation Os contributos da ZERO – Associação Sistema Terrestre Sustentável No contexto do Acordo Verde da UE ((European Green Deal), é com satisfação que a ZERO – Associação Sistema Terrestre Sustentável vê o compromisso da Comissão de aumentar a ambição na mitigação das alterações climáticas, bem como os seus planos de revisão da meta de redução dos gases de efeito…

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)

AGCS Gas Clearing and Settlement AG welcomes the EC’s initiatives for Europe becoming the first climate-neutral continent. We appreciate the opportunity to contribute to the Inception Impact Assessment. AGCS is the Austrian gas balance group coordinator and has been operating the Biomethane Registry Austria since 2012, according to the Austrian Renewable Electricity Act (ÖSG, Ökostromgesetz).

Herebelow we are pleased to submit the main comments from ERG Group, a primary independent power producer from renewables in Europe – wind, solar and hydro. - ERG strongly supports the target of 55% GHG emission reduction by 2030, as recently proposed by the Commission to the Parliament and other institutions involved in the process.

The Forest Stewardship Council (FSC) is the pioneer of forest certification with 25 years of experience in sustainable forest management and is widely regarded as the world’s most trusted forest certification system. FSC uses its expertise to promote the responsible management of the world’s forests, bringing together experts from the environmental, economic and social spheres.

Directive 2009/28/EC recognised in its typical and default values the biomethane from municipal biowaste as sustainable, since was reaching the greenhouse gas saving targets of 60%. Directive (EU) 2018/2001 in its Annex VI has a different approach, and provides typical and default values of GHG savings for biomethane produced from bio-waste differentiating by “open” and “close” digestate and by the presence or not…

The Ørsted vision is to create a world that runs entirely on green energy. Ørsted develops, constructs and operates offshore wind farms, associated infrastructure and innovative waste-to-energy solutions as well as providing smart energy products to our customers. We are also entering the market for renewable hydrogen production.

SHV Energy is a Dutch family-owned company and world’s leading LPG distributor, which also provides small-scale LNG, sustainable biomass and bioLPG for domestic heating, industrial heating, cooking and transportation.

The German Federation of Industries welcomes the intention of revising the RED II directive in response to the upcoming challenges and the need of system transformation to meet the set climate targets. The implementation of the defined climate policies requires increased investment, operating and production expenditures.

THIS IS A SUMMARY OF EHPA'S MAIN REQUESTS. THE DETAILED POSITION HAS BEEN ATTACHED TO THIS SUMMARY. On the 8th of July, the European Commission published its EU Energy System Integration Strategy as part of the European Green Deal to reach climate neutrality by 2050.

Recommendations on the REDII Inception Impact Assessment Enerkem welcomes the opportunity to comment on the Inception Impact Assessment on the REDII. It is indeed crucial to adjust the energy and climate targets upwards given the objective to have a net zero-emission society by 2050.

GENERAL COMMENTS: • Natural gas is a bridge from coal to renewables and hydrogen. Especially in MS like Poland whose economy is to a large extent based on coal, role of gas is crucial in the process of energy transformation toward clean sources of energy. • It is of key importance to ensure that any possible increase of RES target is set only after a thorough impact assessment and in a technology neutral manner.

Review of EU renewable energy rules – Roadmap consultation Feedback from Eni S.p.A. We welcome the upcoming review of the EU policy and regulatory framework for renewables as we see a strong potential in supporting a fast yet economically efficient renewables deployment pursued at Union level.

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

LRF welcome the European Green Deal and the European Commission’s ambitions aiming to make Europe the first climate-neutral continent by 2050. The increase of the general European objective to promote renewable energy sources is important to bring about the transition to a green economy.

We write on behalf of Hardlevel from Portugal. We welcome the early revision of the REDII as an excellent opportunity to further improve certain elements of the existing regulatory framework to ensure that the EU achieves carbon neutrality by 2050. We set out here below key improvements of REDII provisions supported by the waste-based biodiesel industry: 1.

The start of an overall review process of the energy and climate legislation, including the 2018 Renewable Energy Directive (“REDII”), aimed at ensuring that the EU renewable energy policy effectively continues to contribute to the cost-effective deployment of renewable energy sources is welcome.

COGEN Europe welcomes the opportunity to comment on the European Commission consultation on the revision of the Renewable Energy Directive (RED). Accelerating the cost-effective uptake of renewable energy (RES) in all sectors of the economy, across electricity, heat and gas systems, will be critical to reach climate neutrality by 2050.

SOL appreciates the EC initiative to revise the rules for renewable energy in order to contribute to achieving the objectives of the Green Agreement for Europe and the objectives of the Climate Action Act 2030. However, we would like to draw attention to some points relating to the assessment of potential impacts in the use of renewable energy from forests.

Filed in Czech · English published by the European Commission

UNICA, the Brazilian sugarcane association, welcomes the opportunity to contribute to the review of EU renewable energy rules. In order to meet the EU’s ambition of reaching climate neutrality by 2050, enormous effort and support will be required both immediately and in the long term. Please find our full input in annex.

We warmly welcome the promotion of renewable energies. We recognise that a huge effort and investment is needed to replace fossil energy with renewables; The availability of renewable energy is also limited. When using renewable energy, priority should therefore be given to applications with a high specific CO2 reduction potential.

Filed in German · English published by the European Commission

USIPA supports the initiative to increase the EU’s climate and energy targets for 2030, and to increase the share of renewable energy in final energy consumption. This will better prepare the EU for the transition towards climate neutrality by 2050. Consequently, some existing EU legislation may need to be reviewed and updated to ensure that it reflects this increased level of ambition.

The EU’s 2030 climate target makes it urgent to adapt the Renewable Energy Directive (RED) with regard to the transport sector. This applies to the previous 2030 target of 40 % greenhouse gas reduction and, a fortiori, to a possible higher target of 55 %.

Filed in German · English published by the European Commission

- bp supports the EU’s 2050 climate neutrality aspirations. - To ensure renewable fuel options are developed for each of the transport modes specific discrete targets for land, marine and air transport should be set. - We support option 5. - RED2 should send a clear signal to the energy sector and financial institutions for investment into low carbon technologies for the transport sector.

To be on a pathway consistent with achieving climate-neutrality by 2050, SolarPower Europe supports the European Union to review upwards its 2030 greenhouse gas emissions target to at least 55% and to increase the ambition of its 2030 renewable energy target accordingly by June 2021, before the upwards review initially established by the RED II for 2023.

Competitiveness is a driver for sustainability VIK welcomes the consultation of the roadmap on the revision of RED II. Industry is ready to support the transition of a carbon neutral energy supply system with innovative processes and products. However, such innovations are largely not yet competitive and partly not even on an operational readiness level.

Business and Science Poland welcomes the possibility to comment on the early revision of the Directive 2018/2001 on the promotion of the use of energy from renewable sources. We recognize the need to ensure compliance of several initiatives under the EDG scope with the ongoing ambitious climate policy, which is relevant for elements of the RED II rules.

Confcommercio – Imprese per l’Italia comments to the EU renewable energy rules – review Inception impact assessment - Ares(2020)4087053 L’obiettivo promosso dalla Commissione europea di creare le condizioni affinchè l'energia rinnovabile contribuisca in misura sufficiente al raggiungimento della maggiore ambizione climatica dell'UE è senz’altro condivisibile.

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)

As Europe’s largest renewable electricity producer, Statkraft is committed to contributing to the EU becoming the world’s first climate-neutral region by 2050. We support the Commission’s proposal to increase the EU’s current 2030 climate target from 40 % to 55 % emissions reductions. Preferred option Of the presented options in the Inception Impact Assessment, Statkraft prefers option 4.

[Please refer to attachment for WindEurope complete feedback] WindEurope, representing the entire European wind power value chain with more than 400 members, welcomes the European Commission’s proposal to increase the 2030 climate ambition level and the possibility of providing feedback on the revision of the Renewable Energy Directive through this first consultation.

ICLEI Europe welcomes the REDII Inception impact assessment. As the leading global network of 1,750 cities, towns and regions committed to building a sustainable future, representing more than 25 percent of the global urban population, and on behalf of our European members and the millions of citizens they represent, ICLEI Europe supports an increase of the 2030 climate target to at least 55% GHG emissions…

We welcome the Commission’s initiative to streamline the objectives of RED II with recent initiatives to increase the 2030 target, promote hydrogen and sector integration. This review should encompass: 1) An increase of the RED II targets and sub-targets. The nominal sub-target of 14% for renewable energies in the transport sector should be increased to at least 23% in 2030.

The Federation of Swedish Family Forest Owners (LRF Forest) welcomes the EC initiative to possibly review the EU renewable energy rules in order to contribute to higher climate ambition as part of the European Green Deal and in support to the objectives of the EU Climate Law and 2030 Climate Target Plan.

Hereby, Airlines for Europe (A4E) takes the opportunity to submit feedback on the EU renewable energy rules – review (Roadmap). Alongside radical fleet renewal, improved air traffic management and technological advances such as hydrogen and electric propulsion, the use of sustainable aviation fuels (SAFs) is generally considered as one of the most effective means to reduce CO2 emissions from aviation in the next…

Veolia welcomes the European Commission’s initiative to assess the possibility to revise the Renewable Energy Directive (REDII) and would like to make the following recommendations for the impact assessment. Increasing the general and sectoral targets for renewable energy: In accordance with the results of the impact assessment published on September 17 for 2030 CO2 emission target of 55%, it seems necessary to…

The recently released European Commission’s Hydrogen and Energy System Integration strategies have confirmed the essential role of renewable and low-carbon gases in reaching a climate-neutral Europe by 2050. To speed up the transition towards these gases, an appropriate regulatory framework is needed.

21 September 2020 EUROALLIAGES’ submission to European Commission’s public consultation on the Inception Impact Assessment of the Revision of Directive (EU) 2018/2001 on the promotion of the use of energy from renewable sources EUROALLIAGES1 is the voice of ferro-alloys and silicon industry in Europe.

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

DIN, the German Institute for Standardization, is the independent platform for standardization in Germany and worldwide. DIN Standards Committee “Principles of Environmental Protection” (NAGUS) is responsible for interdisciplinary generic standardization in the field of environmental protection at national, European and international level.

We welcome the opportunity to contribute to the roadmap consultation on the review of the EU renewable energy rules. E.ON supports the new, clear path for the EU 2030 climate targets and the reduction in greenhouse gas emission of at least 55%.

The RE-Source Platform welcomes the initiative of the European Commission to review the Renewable Energy Directive (RED II) and allow for a faster transition to a green, smart and resilient European energy system.

Contributo Unione Petrolifera su Consultazione revisione Direttiva RED II L’Unione Europea sta programmando target sempre più ambiziosi per la quota di energia rinnovabile nei trasporti. Pertanto la linea generale che a nostro avviso andrebbe perseguita per guidare la revisione della RED II in prospettiva 2030 dovrà essere quella di non escludere alcuna materia prima che rispetti i criteri di sostenibilità, da…

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)

Lantmännen welcomes the opportunity to review the Renewable Energy Directive and raise overall RES targets as an opportunity to further promote the use of biofuels as the only readily-available, cost-effective, sustainable alternative to traditional fuels.

Liquid Gas Europe is a European association composed of national Liquefied Petroleum Gas (LPG) associations, the main European LPG suppliers, distributors and equipment manufacturers. With the support of its working groups of industry experts, Liquid Gas Europe is actively involved in concrete initiatives and programmes to ensure the sustainable, safe and efficient development of LPG and bioLPG in Europe.

The European Solar Thermal Electricity Association, ESTELA, welcomes the initiative of the European Commission to review the RED II, considering recent developments in the health and environment sectors. Considering the recent State of the European Union speech by President Von der Leyen, reviewing RED II seems more than ever appropriate to deliver on the climate and energy objectives.

The Federation of Private Forest Owners welcomes the EC initiative to help to raise ambition as part of the European Green Deal and in support to the objectives of the EU Climate Law and 2030 Climate Target Plan. We do want to note some remarks and concerning the content of the options needed in the inception impact assessment and their possible impacts on the use of st-based energy energy.

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Revision of Directive (EU) 2018/2001 on the promotion of the use of energy from renewable sources: Submission from Sustainable Biomass Program Introduction SBP is a multi-stakeholder, voluntary certification scheme designed for solid woody biomass used in large-scale energy production.

Please find attached Bellona Europa's full response and recommendations to the Roadmap Consultation "EU renewable energy rules - review" as well as our recommendations for the REDII delegated acts for your reference. We are happy to contribute further to the process and offer our expertise on the topic should this be of interest to you continued work. Here is a short summary of Bellona Europa's recommendations: 1.

FRIENDS OF THE EARTH EUROPE FEEDBACK TO THE INCEPTION IMPACT ASSESMENT Friends of the Earth Europe is the largest grassroots environmental network in Europe, uniting more than 30 national organisations with thousands of local groups. Since 2013 we have been campaigning to speed up the development of people’s ownership of renewable energy. Renewable Energy Target.

Feedback on Inception impact assessment – of the possible review of the Renewable Energy Directive (REDII) 21 September 2020 Case no.: Danish Shipping supports the European Union’s ambition to be the first climate neutral continent in the world by 2050 and welcomes the initiative to review REDII.

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

Please see document attached. About EHI, the Association of the European Heating Industry EHI represents 90% of the European market for heat and hot water generation, heating controls and heat emitters, 75% of the hydronic heat pump market, 80% of the biomass central heating market (pellets, wood) and 70% of the solar thermal market.

I write on behalf of Greenergy Fuels from the United Kingdom. We welcome the early revision of the REDII as an excellent opportunity to further improve certain elements of the existing regulatory framework to ensure that the EU achieves carbon neutrality by 2050. Our main points are covered in the below and go into more detail in our attachment. 1. Upward revision of the 14% transport obligation (Article 25(1)) 2.

To: European Commission 1049 Bruxelles/Brussel Belgium Maroussi, Xth September 2020 Mytilineos is one of the largest industrial companies in Greece, with activities in numerous sectors (including Metallurgy, Electricity generation and supply, Gas trading, and EPC works).

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

The GEN-I Group welcomes the European Commission's initiative, via the European Green Deal, to increase the EU's climate ambition for 2030 and thereby accelerate also the deployment of renewable energy, in particular as it affects the potential for active consumer empowerment through renewables self-consumption.

Energy Norway is a non-profit industry organization representing about 270 companies involved in the production, distribution and trading of electricity in Norway. Energy Norway's members vision are an all renewable, all-electric decarbonized society. We believe early action with the use of market design and instruments, is key to achieving this decarbonization at the fastest rate and lowest cost.

September 21, 2020 Directorate-General for Energy European Commission Re: Airlines for America® Feedback on the European Commission’s Inception Impact Assessment on Revision of the Renewable Energy Directive II (Directive (EU) 2018/2001) Dear Sir/Madam: Airlines for America® (A4A), the principal trade and service organization of the U.S.

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

To ensure we reach net zero emissions by 2040, EU Member States need to phase out fossil fuels and commit to a strong reduction in energy consumption and a transition of our energy system to one that is 100% based on sustainable renewable energy sources (RES) by 2040. The current 2030 EU RES target is not in line with the Paris Agreement objective to limit temperature rise to 1.5°C.

Eurocities calls for the EU 2030 emission reduction target to be revised upwards to at least 55% for 2030, and to be binding at member state level to ensure full commitment. We also call for the European Commission to strengthen direct collaboration with and support for leading cities that can show Europe the way to climate neutrality by aiming for an even higher reduction target of 65% by 2030.

Feedback on Revision of Directive (EU) 2018/2001 on the promotion of the use of energy from renewable sources September 21, 2020 Please accept this feedback from the Partnership for Policy Integrity (PFPI), a US based NGO working with allies across Europe for the protection and restoration of natural forests.1 The present initiative seeks input on how the increased greenhouse gas (GHG) reduction ambition for 2030…

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

GASNATURALLY FEEDBACK TO EU RENEWABLE ENERGY RULES REVIEW 21 September 2020 GasNaturally welcomes the Commission’s Roadmap for the revision of the Renewable Energy Directive (RED II). In light of the European Green Deal (EGD) and the 2030 Climate Target Plan recently published by the European Commission, GasNaturally members reiterate the importance to recognise that gas plays an important role in achieving EU…

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

Solar Heat Europe (SHE) strongly supports the EU Commission initiative for the possible revision of the RES Directive (EU2018/2001) The goal of achieving carbon-neutrality by 2050 will require a prompt action on the mid-term climate and energy goals. We are managing a tight carbon budget and need to decarbonise as fast as possible, leaving for the final years (2030-2050) those areas harder to decarbonise.

Community Power Coalition feedback to REDII Inception impact assessment. TARGET. The Community Power Coalition welcomes the initiative to increase the Renewables target from the current target of at least 32%. To avoid catastrophic climate impacts we need to urgently switch to a 100% renewable energy system. Citizen and community ownership should be at the heart of this.

CEWEP Ireland response to the European Commission’s Inception impact assessment on the revision of the Renewable Energy Directive (2018/2001) (RED II) CEWEP Ireland welcomes the current revision of the REDII and in particular the measures to promote District Heating and Cooling (DHC), energy efficiency and the use of heat from industrial sources.

Targets Cuts in greenhouse gas emissions over the next 10 years are definitive for the success – or failure – of climate action. The Commissions plan to update the 2030 target is not enough. Without taking equity and the historic responsibility into account, the EU must commit to at least 65% cut in emissions by 2030 and net-zero by 2040.

The Austrian Federal Economic Chamber (Wirtschaftskammer Österreich/WKÖ) supports the goal of European climate policy to achieve greenhouse gas neutrality by 2050. The economy can make a significant contribution, but it needs a fair, plannable, and competitive legal framework in order to continue to implement investments in Europe.

Renewable Energy Directive: Facilitating a progressive and open integration of renewables in heating and cooling The EU Green Deal foresees a potential early revision of the Renewable Energy Directive (REDII). Eurofuel sees this as an opportunity to reap the full benefits of all types of renewable liquid and gaseous fuels across sectors.

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

The Dutch authorities welcome the European Green Deal and its impact assessed plan to increase the 2030 greenhouse gas reduction target from 40% to at least 55% compared with 1990 levels. This is a target the Dutch authorities have argued for the past few years. They also acknowledge the key role of renewable energy in achieving this reduction target.

We write on behalf of Kobkiat Global Co. Ltd from Thailand. We welcome the early revision of the REDII as an excellent opportunity to further improve certain elements of the existing regulatory framework to ensure that the EU achieves carbon neutrality by 2050. We set out here below key improvements of REDII provisions supported by the waste-based biodiesel industry: 1.

The Forum for Electricity and Gas (FEEiG) Forum brings together 8 Polish industry organisations focusing on energy-intensive business in Poland. The main objective of FOGASA is to create favourable conditions for the development of production activities in Poland through improved energy efficiency and the development of industrial energy.

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Feedback – Renewable Energy Directive FNADE, the french association for waste management and environmental services welcomes the European initiative for the Revision of Directive (EU) 2018/2001 on the promotion of the use of energy from renewable sources.

Biofuelwatch welcomes the European Commission’s commitment to the Green Oath’ and its No Harm principle, and the acknowledgment that this must be considered in relation to biodiversity and air quality as well as climate impacts. We believe that this Principle requires substantial reforms to REDII, due to the large volume of evidence of the harm caused by forest biomass and land-based biofuels (including bioliquids).

Bankwatch supports a combination of non-regulatory measures, amending the RED II to accommodate for the new measures foreseen in the European Green Deal (EGD), and raising the ambition of the RED II targets and subtargets (option 5). However, such an increase in ambition should not be done without tightening the Directive’s sustainability provisions.

E-fuels generated from CO2 and renewable energy are essential to defossilize transport sector and a wide range of European industries and thereby achieving the climate goals. As liquid and gaseous energy carriers, these CO2 based fuels provide an immediate solution reducing or even reaching net zero CO2 emissions in a variety of fields, incl. road transport/shipping/aviation.

FEDIOL, the association representing the EU vegetable oil and proteinmeal industry, welcomes the possibility to comment on the Roadmap for the upcoming review of the EU renewable energy rules (Directive 2018/2001/EU on the promotion of the use of energy from renewable sources).

UFE welcomes the EC initiative to bring greater consistency between energy and climate policies. Considering the 2018 revision of RED, UFE believes that, alongside a review of the overall 2030 target, the EC should also ensure the complete and correct transposition of REDII by MS. To achieve climate neutrality, the EU must put in place an effective system in which reducing CO2 emissions is the priority.

Directive 2009/28/EC recognised in its typical and default values the biomethane from municipal biowaste as sustainable, since was reaching the greenhouse gas saving targets of 60%. Directive (EU) 2018/2001 in its Annex VI has a different approach, and provides typical and default values of GHG savings for biomethane produced from bio-waste differentiating by “open” and “close” digestate and by the presence or not…

As key stakeholders in the housing and real estate sectors, we value the possibility of having our members’ propositions and concerns reflected in the upcoming revision of the Renewable Energy Directive. The key to a successful transition towards a greener and more sustainable energy is to remove existing disincentives as well as to ensure flexibility and legal stability in the deployment of renewable energy…

With regard to the Commission’s IIA, CEMBUREAU has the following comments: • Regardless of the level of ambition for 2030, it is absolutely essential that a thorough impact assessment is conducted by the European Commission to determine the different policy options to reach these targets and their consequences.

To reduce CO2 emissions in transport in the next decade, we need to leverage the solutions that are available today. This is especially true in view of an EGD increase of climate ambition. The pressure to deliver requires solutions that could be implemented at a low investments cost. The use of biomethane in transport meets all these conditions.

GD4S welcomes the expected revision of the Renewable Energy Directive (REDII) as part of the Energy System Integration Strategy and the possibility to comment on the Inception Impact Assessment (IIA). With the publication of the ESI and Hydrogen strategies the Commission has underlined the important role renewable gases will play to reach carbon neutrality in a cost-efficient way.

The Groupe Avril fully supports the EU’s Green Deal and its ambition to become the first climate-neutral economy by 2050 and believes the revision of the RED is a key part of reducing CO2 emissions. 1.Increase of the renewable energy target in transport As biodiesel made from European feedstocks reduce CO2 emissions, the EU should promote sustainable solutions in the transport sector, and make sure that all…

Bioenergy Europe welcomes the European Commission initiative evaluating the possible revision of the Renewable Energy Directive ((EU) 2018/2001). The achievement of the carbon-neutrality objective by 2050 will require a prompt adjustment of the mid-term climate and energy objectives measures.

Cefic supports Europe’s ambition to become climate neutral by 2050 requiring breakthrough technologies and enabling frameworks for the very large investments required. The Green Deal recognises that Energy Intensive Industries, such as chemicals, are indispensable for Europe’s transition, as solution providers to multiple value chains, including renewable energy technologies and low carbon emission energy.

ecoMotion GmbH, Germany, Submission to the European Commission consultation on the “EU renewable energy rules – review” (Consultation period: 3 August 2020 - 21 September 2020) ecoMotion welcomes the announced early revision of the Renewable Energy Directive (REDII) as this process will bring an excellent opportunity to further fine-tune and improve certain elements of the existing regulatory framework in order to…

Edison welcomes the opportunity to share some preliminary views on the revision of the Directive (EU) 2018/2001 on the promotion of the use of energy from renewable sources (REDII), to assess the contribution made by this initiative to the achievement of the European climate objectives.

Please read the attached file for Danish Energy's full feedback. Danish Energy highly welcomes the European Commission’s initiative to review and revise the REDII in order to promote renewable energy production and utilization in the EU.

GRTgaz welcomes the opportunity to provide its feedback on the European Commission’s (EC) inception impact Assessment to review the Renewable Energy Directive (RED). GRTgaz fully supports the EC’s view that achieving the European Green Deal (EGD) objectives will require fundamental changes in many areas including the energy sector.

Natuur & Milieu is a leading NGO in the Netherlands in terms of clean transport and renewable energy. We focus on decarbonisation and a sustainable future for mobility and energy. Natuur & Milieu welcomes the Commission’s intention to revise the Renewable Energy Directive and, in particular, its transport aspects.

The Austrian Biomass Association supports Option 3 – Adapting the RED II targets to the 2030 targets. The reduction of administrative burdens and related potential costs, in particular for producers of raw materials, must be the primary objective. It is expected and assumed that the relevant interest groups in particular will be involved in the discussions. It is also necessary to build on existing systems.

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ecoMotion Biodiesel SA ( Spain ) Submission to the European Commission consultation on the “EU renewable energy rules – review” (Consultation period: 3 August 2020 - 21 September 2020) ecoMotion Biodiesel SA welcomes the announced early revision of the Renewable Energy Directive (REDII) as this process will bring an excellent opportunity to further fine-tune and improve certain elements of the existing regulatory…

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 the light of a higher EU climate ambition under the European Green Deal; • EUDCA also believes that…

www.pwc.de Ref. Ares(2021)661871 - 27/01/2021 Opportunities and risks for Germany’s heating industry in a competitive global environment Efficiency and renewable energy for the heating transition Opportunities and risks for Germany’s heating industry in a competitive global environment Published by PricewaterhouseCoopers GmbH Wirtschaftsprüfungsgesellschaft By Dr.

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

With more than 11 million tonnes of biodiesel produced per year, the EU is the world leader in the production and use of biodiesel for transport. Sustainable biodiesel (both crop and waste-based) is delivering today significant GHG emissions savings and constitutes an essential tool for the decarbonization of the European road transport sector, not only in passenger cars but specially in light and heavy-duty…

Environmental Defense Fund's (EDF) comments include both the strategic need to introduce a methane performance standard and a set of changes to the existing REDII sustainability framework. Considering the EGD’s strategic priorities of decarbonising gas and directing investments to sustainable activities, it is strategically important to ensure alignment of both the RED II and its sustainability framework with the…

As the lead enabler for energy certifcation in Europe (707 TWH of renewable energy certified in 2019) the Association of Issuing Bodies applauds further strengthening and harmonisation of the energy certification system(s). In any case the validity /expiry rule for guarantees of origin (GOs) in article 19.3 of the Directive 2018/2001/EU needs to be cleaned up and harmonised over all member states.

Bioenergy accounts for almost 60% of the current EU renewable energy consumption and according to the European Commission Long Term strategic vision , and other scientific literature, its contribution to the EU energy mix can grow in the next decades through an improved mobilisation of sustainable feedstocks.

EFIEES represents energy service companies (ESCOs) and their national associations in 12 Member States. They represent over 130.000 professionals engaged in the design and implementation of energy-efficiency solutions in buildings and industry. In some countries, they also operate district heating & cooling networks.

The review of the renewable energy directive aims to align it with new climate objectives. Renewable energy sources play a key role to reach carbon neutrality target by 2050. Their deployment should be reinforced to achieve a climate target up to 55% of GHG reduction in 2030.

EUTurbines, the European Engine Power Plants Association, together with EUGINE, the European Association of Gas and Steam Turbines Manufacturers, welcome this opportunity to provide feedback. Gas power plants, be they generating electricity-only or both heat-cold & power (i.e. cogeneration plants), are fuel agnostic as long as some gas quality parameters are met.

We welcome recognition in the Climate Target Plan Communication of the need to increase efforts to mitigate climate change, increase renewable energy consumption and enhance the EU’s terrestrial carbon sinks by 2030, while protecting forests and safeguard the environment.

EREF welcomes the COM proposal to reduce GHG emissions by at least 55% by 2030. This is the minimum necessary. COM should consider that the EP ENVI asked for at least 60% and that there are numerous calls for at least 65% GHG emission reductions; at least 45% renewable energy; and at least 40% energy savings.

Daka ecoMotion Submission to the European Commission consultation on the “EU renewable energy rules – review” (Consultation period: 3 August 2020 - 21 September 2020) Daka ecoMotion, welcomes the announced early revision of the Renewable Energy Directive (REDII) as this process will bring an excellent opportunity to further fine-tune and improve certain elements of the existing regulatory framework in order to…

The Dutch Platform on Sustainable Biofuels (hereafter: the Platform) welcomes the opportunity to reflect on the Inception Impact Assessment on the REDII. It is indeed crucial given the objective to have by 2050 a net zero-emission society to adjust the energy and climate targets upwards.

IIA Roadmap - Renewable Energy Directive FEDENE’s contribution 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 dedicated to the implementation and development of sustainable services. 1.

The European Oleochemicals & Allied Products Group (APAG), a sector group from Cefic, welcomes the forthcoming revision of the Renewable Energy Directive by the European Commission. APAG is a long-established sector of the European bioeconomy.

Roadmap on Revision of Directive (EU) 2018/2001 on the promotion of the use of energy from renewable sources 21/09/2020 Repsol as a global multi-energy provider, shares the world’s ambition to reach climate neutrality in the framework of the Paris Agreement as well as the EU’s 2050 carbon neutrality objective.

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

DI comment to Roadmap: EU renewable energy rules – review The Confederation of Danish Industry (DI) appreciates this opportunity to comment on this inception impact assessment related to the revision of the Renewable Energy Directive (REDII). DI supports the overall objective, i.e. to ensure that renewable energy sources contribute to the achievement of EU’s climate ambition.

We welcome the fact that the Commission is carrying out a comprehensive review of Directive 2018/2001. This is a good opportunity to fine-tune the existing rules. The current target of increasing the share of renewable energy from transport by 2030 to 14 % and to 32 % of gross energy consumption should be assessed with a view to increasing it, as announced by the Commission in the publication of its European Green…

Filed in German · English published by the European Commission

You will find attached a DIHK impulse paper on the amendment to the Renewable Energy Directive. In the light of the EU’s increased ambition to combat climate change enshrined in the Green Deal, it is in principle correct to adapt the Renewable Energy Directive. However, the DIHK is in favour of focusing on efficient measures to make it easier for companies to produce and use renewable energy directly on the ground.

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Enel welcomes the Commission’s Inception Impact Assessment (IIA) initiative to revise the Renewable Energy Directive, in order to support the renewed and higher EU climate ambition and implement the transition towards a more integrated energy system.

Eurogas welcomes the European Commission’s inception impact assessment on the Revision of Directive (EU) 2018/2001 on the promotion of the use of energy from renewable sources. All options will be needed to reach sustainability objectives in a way that ensures the scale needed to decarbonise EU’s economy.

STEAG GmbH, as a European and international energy company, considers it correct and important to carry out an early impact assessment on the impact of this increase on Directive (EU) 2018/2001 on the promotion of the use of energy from renewable sources (REDII) as one of the most important elements of the European Green Deal as part of the planned increase in the EU’s greenhouse gas reduction targets for 2030 as…

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The German Renewable Energy Federation (BEE) welcomes the COM proposal to reduce GHG emissions by at least 55 percent by 2030. In order to be able to achieve an ambitious greenhouse gas reduction target of at least 55 percent by 2030 compared to 1990, an equally ambitious increase in the targets for the share of renewable energies in gross final energy consumption and energy efficiency are necessary.

Elettricità Futura’s Reply to the Public consultation on Inception Impact Assessment Revision of Directive (EU) 2018/2001 21st September 2020 General considerations Elettricità Futura welcomes an overall review of the European energy and climate legislation: improving the effectiveness of the policy framework is a crucial step to better pursue ambitious decarbonization targets, in line with the European Green Deal…

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

The Hydrocarbon Resins, Rosin Resins & Pine Chemicals Producers Association (HARRPA), a sector group of Cefic, welcomes the decision of the European Commission to launch a review of the Directive (EU) 2018/2001 on the promotion of the use of energy from renewable sources (RED II). HARRPA represents the European based producers of resins.

Please, find attached FEAD’s full feedback to the EC Roadmap on the Revision of REDII. FEAD, the European Federation for Waste Management and Environmental Services, representing the private waste and resource management industry across Europe welcomes the European Commission’s initiative to review the 2018 Renewable Energy Directive (REDII).

SNAM welcomes the opportunity to provide feedback to the EC initiative on the review of the EU renewable energy rules (RED II). The revision should proceed consistently with the Energy Sector Integration and H2 Strategies, where the essential role of renewable and low-carbon gases for achieving quicker and more efficiently the net zero emission target by 2050 is clearly defined.

Suez subscribes to the new EU climate ambition of reducing GHG emissions by at least 55% by 2030. Suez’s corporate growth strategy – SUEZ 2030 – is fully aligned with this major milestone of the trajectory of EU’s climate neutrality by 2050. Additionally, Suez is committed to contribute positively and bring value to the objectives of the Green Deal.

The European Fermentation Group (EFG), a sector group of Cefic, welcomes the forthcoming review of the Renewable Energy Directive by the European Commission. EFG is the voice of the European fermentation industry vis-à-vis EU institutions, national governments, and civil society.

The European Biogas Association is fully committed to reaching carbon-neutral Europe and welcomes the inception impact assessment of the European Commission aiming to target sectors such as transport, heat and gas where the process of de-fossilisation has been slow so far.

The ART Fuels Forum, welcomes the initiative of the Commission to review and consider updating RED II to ensure the achievement of 2030 climate goals. If the EU wants to achieve the net zero emission target by 2050, there is no doubt that the pace of deployment of renewable energies should be increased. A clear and harmonized policy framework is needed.

Inception impact assessment about the revision of Directive (EU) 2018/2001 on the promotion of the use of energy from renewable sources. Air Liquide’s Feedback Air Liquide is acting globally in gases, technologies and services for Industry and Health. The Group takes active measures for the climate in its operations, with its customers and ecosystems by offering low-carbon solutions.

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

GRUPPO TERNA/P20200059414-21/09/2020 - Allegato Utente 1 (A01) Ref. Ares(2020)4934128 - 21/09/2020 Terna response to EC consultation on the RED II Roadmap Terna welcomes the opportunity to provide a response to the European Commission public consultation on the RED II Roadmap.

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

Polish Electricity Association position on the Inception Impact Assessment of the revision of Directive (EU) 2018/2001 on the promotion of the use of energy from renewable sources Members of the Polish Electricity Association (PKEE) are actively involved in reduction of greenhouse gas emissions and further development of renewables.

GAZ-SYSTEM welcomes the opportunity to take part in the public consultation on Renewable Energy Directive 2018/2001 (RED II) and comment on the scope of future EU renewable energy policies. GAZ-SYSTEM is of the opinion that the EU climate objectives should be implemented by promoting both renewables and low-carbon/decarbonised energy sources.

CEWEP welcomes the European Commission’s Inception impact assessment on the revision of the Renewable Energy Directive (2018/2001) – REDII and in particular the measures to promote District Heating and Cooling (DHC), energy efficiency and the use of heat from industrial sources.

Following the impact assessment in preparation for the revision of Directive (EU) 2018/2001, the Belgian Confederation of Belgian Enterprises (FEB) would like to highlight the following issues: — The European Commission has indicated that achieving the current 32 % target for renewable energy would lead to a GHG reduction of 45 % or 5 % higher than the 40 % target.

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The SGAB Editors welcome the initiative of the European Commission to review the current Renewable Energy Directive 2018/2001 and align it with an increased climate ambition to 2030 as well as with the objectives set out in the Paris Agreement. The revision creates an opportunity to build on SGAB’s 2017-recommendations and significantly increase the Renewable Fuels targets in EU transport.

EUGINE & EUTurbines, the European Engine Power Plants Association & the European Association of Gas and Steam Turbines Manufacturers, welcome this opportunity to provide feedback. Gas power plants, be they generating electricity-only or both heat-cold & power (i.e. cogeneration plants), are fuel agnostic as long as some gas quality parameters are met.

Comments Revision of Directive (EU) 2018/2001 on the promotion of the use of energy from renewable resources Association of the German Biofuel Industry Verband der Deutschen Biokraftstoffindustrie e.V. 1. VDB as representative of the biofuel producers in Germany The Association of the German Biofuel Industry (Verband der Deutschen Biokraftstoffindustrie e. V.

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

As announced in this initiative summary, under the European Green Deal the Commission has committed to stronger action on climate change and will assess how the EU’s greenhouse gas emissions could be responsibly reduced by at least 50-55% by 2030.

Feedback to the EU renewable energy rules – review Introduction The EC has announced that the proposed increase of Europe’s greenhouse gas emissions reduction target from 40 to 55% by 2030 may require a revision of the Renewable Energy Directive (RED II). Transport is mentioned as one of the key sectors where more renewables could be deployed and a more ambitious target for renewable transport could be required.

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

ECOS welcomes the initiative of the European Commission to review the current Renewable Energy Directive 2018/2001 and align it with an increased climate ambition to 2030 as well as with the objectives set out in the Paris Agreement. The Renewable Energy Directive is a key policy tool to drive the European Union towards a zero-emission and fossil-free energy system.

Essenscia supports the climate ambition and considers the reduction of greenhouse gases the main objective. Therefore it is important other targets, like the RED target, are supportive of this objective and should be made indicative. To reach climate neutrality over time, industry will require access to large amounts of low carbon energy at competitive prices.

The Federation of Norwegian Industries recommends an assessment of the Commission's 2030 Climate Target Plan and relate the 2030 ambition for renewable energy to the climate ambitions. The impact on energy-intensive industries should be given attention. It should consider how ambitions and policies will secure abundant renewable energy for large consumers at low costs.

VERBUND welcomes the Commission’s intention to revise the Renewable Energy Directive. In the Commission’s consultation on a potential revision of the 2030 climate target, VERBUND already spoke out in favour of an ambitious upward revision to at least 55% CO2-savings until 2030. In order to meet this target ambition the 2030 energy targets would need to be adapted accordingly.

We welcome the European Commission’s initiative to review the Renewable Energy Directive (EE Directive – 2001/2018) in the context of the Green Deal. The targets set in the Directive for renewable energy shares for electricity, heat and transport by 2030 are crucial for achieving climate neutrality in 2050. Climate policy is central to an industrial site such as Germany.

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In order to meet the Paris climate targets, a technology-open approach is needed. In this sense, RED II tries to describe in a very detailed way objectives and measures to achieve climate targets and CO2 reduction. However, market considerations are not sufficiently taken into account, which unilaterally promotes technologies and in turn suppresses others.

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Reshape binding EU targets - Increase of the minimum EU targets for renewable energy as well as the sub-target for advanced biofuels - A binding renewable gas target of 11% in final gas consumption within the EU by 2030 combined with the targets on installed capacity: 40 GW of green hydrogen (as included in the EU’s Hydrogen Strategy) and 46 GW of biomethane (in line with the realistic potential of 370-375 TWh by…

This submission is on behalf of Drax Group. Drax Group became Europe’s largest decarbonisation project by upgrading its existing facility from using coal to sustainable woody biomass and is now also piloting Europe’s first bioenergy with carbon capture and storage project (BECCS), which, if successful, will make the renewable electricity produced by the power station carbon negative.

Increasing the CO2 reduction target for 2030 at European level to 55 % will also increase the level of ambition for the transport sector. This brings the use of renewable synthetic fuels to the fore, in particular for air, waterborne and heavy goods vehicles.

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We, Paicu & Sons Consulting, are a Romanian consultancy company with more than 20 year of experience in the South Eastern Europe energy market, with a special expertise in the energy commodities trading. We would be honored to contribute with hands-on insights on this issue. We ordered our proposals into a taxonomy of soft and hard actions. You can find our full feedback attached and a summary below.

In the context of the European Union’s climate ambitions it is vital to ensure that policy measures actually lead to positive outcomes for the climate and money spent on such measures is used in the most efficient way. Raising the EU’s renewable energy targets will only result in climate benefits if the types of energy supported lead to significant GHG reductions.

WSC Reply to the Inception Impact Assessment on the Revision of Directive (EU) 2018/2001 on the Promotion of the Use of Energy from Renewable Sources 21st September 2020 The World Shipping Council The World Shipping Council (WSC or the Council) is a non-profit trade association that represents the liner shipping industry, primarily operators of containerships, vehicle carriers, and roll-on/roll-off vessels.

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

Warszawa, 21 września 2020 r. Stanowisko Polskiej Koalicji Biopaliw i Pasz Białkowych w ramach wstępnej oceny skutków przez Komisję Europejską rewizji dyrektywy RED2 (Renewable Energy Directive) Polska Koalicja Biopaliw i Pasz Białkowych (PKBiPB) pragnie wyrazić niniejszym swoją opinię w ramach zainicjowanych wstępną oceną skutków przez Komisję Europejską (KE) konsultacji publicznych na temat rewizji Dyrektywy…

Filed in Polish · English published by the European Commission

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

DRT is a French medium-size enterprise at the forefront of the biobased chemicals industry. By dedicating 5% of its workforce to R&I, DRT has developed a unique know-how in the treatment and distillation of Crude Tall Oil (CTO).

FEP – the European Federation of the Parquet industry – is welcoming the EC Inception Impact Assessment on the “Revision of EU Directive 2018/2001 on the promotion of the use of energy from renewable sources”. This initiative is of utmost importance to reach the recently set target of minus 55% GreenHouse Gases emissions, compared to 1990, by 2030 and other objectives enshrined in the EU Green Deal, while supporting…

The main focus should be at energy system and CO2 emission level. For instance, in Finland the share of CO2-neutral energy production (electricity, district heating and district cooling) is rather high and therefore in buildings, as elsewhere, CO2-neutral energy is already commonly used.

UPEI and its members, representing nearly 2,000 European importers and wholesale/retail distributors of energy for the transport and heating sectors, look forward to constructively working with the EU institutions to make Europe’s renewable energy policy a success. UPEI calls upon the European Commission to give careful consideration to the following issues in the process leading to the review of REDII: 1.

SEA Europe welcomes the ambition of the European Commission’s “European Green Deal” (EUGD) which is in line with that of the European “Waterborne” Technology Platform (https://www.waterborne.eu/), which aims at providing solutions by 2030, applicable for all main ship types and services, in order to achieve zero-emission waterborne transport by 2050.

Health Care Without Harm (HCWH) Europe welcomes the opportunity to feed into this Inception Impact Assessment proposal. We believe that the EU should commit to more ambitious climate and energy targets to limit temperature increases to 1.5°C and safeguard the environment, safety, and prosperity of people in Europe and worldwide.

INCEPTION IMPACT ASSESSMENT Inception Impact Assessments aim to inform citizens and stakeholders about the Commission's plans in order to allow them to provide feedback on the intended initiative and to participate effectively in future consultation activities.

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

The European Technology and Innovation Platform Bioenergy (ETIP Bioenergy) fosters the position that the biofuel sector has the potential to establish the energy transition in order to achieve the climate targets for the upcoming decade as targeted by the European Green Deal and in line with the EU’s commitment to global climate action under the Paris Agreement.

North European Oil Trade (NEOT) welcomes the Commission’s initiative to review and assess how far the current EU renewable energy rules can contribute to a higher EU climate ambition set out in Green Deal. NEOT contributes to this consultation from the perspective of a Finnish fuel distributor.

E-Control welcomes the opportunity to contribute to the review of the RED II. We provide comments concerning renewable and decarbonized gases including hydrogen, which are not yet consistently covered throughout this Directive. Support schemes for renewable energy: Article 4 and 5 mainly address renewable electricity.

Over recent years, the energy needed to produce hot water has become an ever-larger share of total household energy use at home due to the dramatic fall in energy required for domestic space heating. Every day, more than 22,000,000 m3 of hot water are consumed by European homes alone. It is the main source of energy consumption for new housing, and yet 80 percent of this heat ends up in sewers and is wasted.

BDBe Berlin, 15.09.2020 Ref. 4.584 Review Impact Assessment (EU) 2018/2001 Red II European Green Deal The share of sustainable biofuels from crop biomass in transport in 2019 was around 5 % in Germany. Currently, sustainable biofuels such as bioethanol, biogas and biodiesel account for almost 90 % of all renewable energy in transport in Germany.

Filed in German · English published by the European Commission

Position paper Aedes on roadmaps of the EED and RED In August the European Commission launched roadmaps for the revision of the Energy Efficiency Directive (EED) and the Directive of the use of energy from renewable source (RED). Through this position paper Aedes, the Dutch association representing social housing providers, gives feedback on both roadmaps.

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

Electricity has been decarbonising fast: 59% of the electricity mix was decarbonised in 2019, and this is expected to grow up to 81% in 2030 . While further decarbonisation of the current power mix is expected in the coming years, deployment of direct electrification should be pursued faster, further and stronger.

Feedback to Roadmap on Renewable Energy Rules – Review Confederation of Finnish Industries EK represents the entire private sector and has 24 member associations and 16,000 member companies. We speak for employers of all sizes, from public limited companies to SMEs.

GAPKI Draft Response – EU Renewable Energy Directive (RED II) – review (Feedback) Palm oil and palm oil products are Indonesia’s largest export. Palm oil is ASEAN’s largest agricultural export. Indonesian Palm Oil Association considers that the EU RED II revision must operate on the following principles, without which it will once again be a discriminatory measure against Indonesia: 1.

ChargeUp Europe is an alliance acting as the voice of the electric vehicle (EV) charging infrastructure industry. It has been formed to accelerate the switch to zero emission mobility and ensure that people can have a seamless driver experience with access to high quality, readily available charging infrastructure across Europe.

Option 4: The future RED also needs a stronger focus on renewable gases in the form of biomethane, green hydrogen or synthetic gas. They connect the sectors, integrate and store renewable energy through power-to-gas and distribution across all sectors (space heat, mobility, electricity). In the space heating market in particular, green gases offer a rapid and comparatively favourable substitute for fossil gas.

Filed in German · English published by the European Commission

To maximize the impact and effectiveness of the emission mitigation measures, EU should move towards more technology neutral approach that looks Negative Emission Technologies and Processes (NETP) as complementing efforts to emission mitigation. Therefore, St1 calls for exploring the possibilities to open the boundaries and seek flexibilities between the different sectors.

The European Autoclaved Aerated Concrete Association (EAACA) was founded in 1988 and has members from 18 countries, operating more than 100 production sites and producing around 16 million cubic meter of autoclaved aerated concrete (AAC) annually.

Neste (www.neste.com) supports the European Green Deal and its aim to increase the EU 2030 climate target to 55%. Neste itself targets carbon-neutral production by 2035. However, the right regulatory framework conditions must be put in place in order to fully deploy the GHG emission reduction potentials from different sectors.

EFFPA is the European Former Foodstuff Processors Association. Former foodstuff processors convert food losses at food factory level into animal feed for food-producing animals. EFFPA supports the overall ambitions to stimulate a clean energy transition. This is also necessary for former foodstuff processors to further reduce GHG emissions linked to their energy and transport use in and around their factories.

T&E is the leading clean transport organisation in Europe. Supported by more than 60 organisations, T&E focuses advocacy efforts on clean vehicles, decarbonisation of shipping and aviation and clean energy for the transport sector. In the context of the EU Green Deal, we welcome the Commission’s intention to revise the Renewable Energy Directive and, in particular, its transport aspects.

In order to achieve the European Union’s strengthened climate objectives, the RED II Directive needs to be adapted to better exploit and exploit the potential of the biomass mitigation option. Changes are therefore needed to achieve further emission savings through the use of sustainable, renewable raw materials. Art.

Filed in German · English published by the European Commission

To ensure we reach net zero emissions well before 2050, EU Member States need to phase out fossil fuels and commit to a strong reduction in energy consumption and a transition of our energy system to one that is 100% based on sustainable renewable energy sources (RES) by 2040. The current 2030 EU RES target is not in line with the Paris Agreement objective to limit temperature rise to 1.5°C.

In principle, an ambitious (compulsory) target for the share of renewable energy in gross final energy consumption is to be supported at EU and Member State level. This is the only way to stimulate the rapid development of renewable energy and transmission networks in all EU Member States. The same applies to the heating sector.

Filed in German · English published by the European Commission

21st September 2020 AGFW’s position paper on the roadmap „EU renewable energy rules – review” The AGFW, the German association on district heating and cooling and CHP (Combined Heat and Power), welcomes the possibility to voice its opinion on the review of the Renewable Energy Directive.

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

Comments on the consultation “EU renewable energy rules – review” from the Swedish Forest Industries Federation. The Swedish Forest Industries Federation represents companies that use forests to provide the raw materials for their products and services. This includes producers of pulp, paper, cardboard, packaging and biofuel.

Introduction Preem welcomes a revision of RED II as means to support the EU’s ambitious targets of reduced carbon emissions 2030 as well a carbon neutrality 2050. It is important however that the revision of the directive is made in a timely manner ensures long term stability and operational conditions for investment and production of renewable fuels.

10.09.20 Review of Directive (EU) 2018/2001 on the promotion of the use of renewable energy SUBTITLE OF REPORT Review of Directive (EU) 2018/2001 on the promotion of the use of renewable Context, Problem Definition, and Subsidiarity Check CurrENT is the key industry association representing innovative grid technology companies operating in Europe.

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

Review of Directive (EU) 2018/2001 on the promotion of the use of renewable energy SuperNode Ltd 10/09/2020 1 Context, Problem Definition, and Subsidiarity Check SuperNodes vision is that people should have access to secure, clean and affordable energy. The costs of renewable generation technologies such as wind and solar have decreased significantly and are now lower than thermal generation.

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

Zero Waste Europe (ZWE) is the European network of communities, local leaders, experts, and change agents working towards the elimination of waste in our society and to empower communities to redesign their relationship with resources and to adopt smarter lifestyles and sustainable consumption patterns in line with a circular economy.

The EFBWW fully supports the goals laid down in the European Green Deal and welcomes the European ambitions to achieve climate neutrality by 2050. The EFBWW fully supports the goals laid down in the Paris Agreement on Climate Change. The EFBWW sectors can all play a key role in implementing climate change policies and be part of the solutions to existing challenges.

Net metering and virtual net metering are well-known support schemes for the promotion of renewable energy sources (RES). However, while the RED II has established a more coherent and comprehensive regime for RES support schemes in general, it makes no explicit reference to net metering schemes. Namely, no reference to any kind of net metering can be found in Article 2(5) of the RED II.

The Federal Chamber of Labour (Bundesarbeitskammer – BAK) recognises the need for a massive increase in the share of renewable energy in total energy consumption in climate policy and therefore supports the European Union’s ambitious target for 2030 to increase the share of renewable energy throughout the EU to at least 32 %.

Filed in German · English published by the European Commission

The Renewable Energy Directive (REDII) plays an important role in preventing climate change. Its climate aims cannot be however, valued more than environmental costs caused by hydropower development. Thus, the following recommendations should be taken into consideration during the amendment of the REDII (Option 5): 1.