Statkraft input to the public consultation for the updating of the EU Emissions Trading System: Maintaining an efficient and functional stability mechanism (Market Stability Reserve) Introduction Statkraft is Europe’s largest provider of renewable energy.
2021/0202(COD) · In Force
Revision of the Market Stability Reserve for the EU Emissions Trading System
14 submissions from 14 organizations told the European Commission what they think about this file. Here is what each of them said, in their own words.
The Commission lists 22 submissions on this file. Shown here: the 14 from organizations. Not shown, by design: submissions from private individuals, which we never publish, and anything filed since our last weekly refresh.
Who showed up
10 submissions from industry — companies and their trade associations — against 3 from civil society: NGOs, consumer organizations, environmental groups and trade unions. That is 3.3 industry submissions for every one from civil society.
Groupings use the respondent type each organization selected when filing. Counting submissions, not organizations — a body that filed twice is counted twice.
What the room declares
- 13 of 14
- in the EU Register
- 123
- full-time lobbying staff
- €17.1M+
- declared costs a year
- 91
- EP accreditations declared
Self-declared to the EU Transparency Register (snapshot 2 Sept 2026). The cost figure sums band floors, so the true total is higher.
The file, right now
The consultation closed on 8 Nov 2021 — it ran from 15 Jul 2021.
- Policy area
- Climate (DG CLIMA)
- Where it stands
- Awaiting adoption
- Legislative stage
- In Force
- Procedure
- 2021/0202(COD)
- Commission reference
- COM(2021)571
How it got here
- Prop dec8 Nov 2021
Showing 14 of 14 submissions.
To stay ahead in the global race for the best climate and energy technology solutions, companies need a clear and reliable fit-for-55 implementation plan providing a clear commitment to Europe as an attractive business, investment and innovation location.
Set an effective price signal for an early coal phase-out Environmental Action Germany (DUH) stresses that the ETS is an essential tools to set an effective price signal for an EU-wide coal phase-out by 2030 and thus to achieve the Commission's own scenario of a coal-free electricity mix. To this end, the amount of certificates should ideally be reduced to 70% by 2030, rather than 61% as proposed.
Hydrogen Europe stands for reforming carbon markets to enable a liquid, sustainable and affordable hydrogen market. A revised, more ambitious EU ETS will be an essential for deep decarbonisation. In this context, carbon content of energy carriers should become the “new currency” of the EU economy, as well as the basis for a stable economic recovery.
Association for District Heating of the Czech Republic (ADH CR) welcomes opportunity to comment on the „Proposal for a DECISION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Decision (EU) 2015/1814 as regards the amount of allowances to be placed in the market stability reserve for the Union greenhouse gas emission trading scheme until 2030“. Please find detailed comments in the Attachment.
European Federation of Energy Traders
· · filed 8 Nov 2021 · source
The European Federation of Energy Traders (EFET) welcomes the opportunity to provide our comments to the Commission consultation on strengthening the market stability mechanism (Market Stability Reserve). Having entered into force in 2019, the MSR has proven to be an effective instrument.
This summer’s extreme weather events - flooding, extensive forest fires and the most extreme heat experienced to date - coupled with the IPCC AR6 point to the urgent need to increase ambition on climate action if we are to avoid further extreme events which could lead to irreversible climate damage and further loss of lives and livelihoods.
The revision of the EU ETS represents a huge opportunity to strengthen the Directive to ensure it is in line with the 1.5˚C target under the Paris Agreement. However, the Commission proposal includes two major shortcomings that should be reconsidered. The EU wide 55% greenhouse gas reduction target by 2030 is incompatible with the goals of the Agreement, and it should be upgraded to 65%.
PGE Polska Grupa Energetyczna S.A.
· · filed 5 Nov 2021 · source
PGE Polska Grupa Energetyczna S.A. (“PGE S.A.”) believes that the revision of the Decision (EU) 2015/1814 on the functioning of the market stability reserve (“MSR Decision”) may be an opportunity for an adaptation of the current mechanism to enable a cost-effective achievement of the EU’s climate objectives.
Neste welcomes the European Commission's Green Deal and the related Fit for 55 package to meet the EU's increased 2030 climate target. Neste is committed to a carbon neutral production by 2035 and to reducing our customers' carbon footprint by at least 20 million tonnes per year by 2030. The right regulatory framework is key to realising the full greenhouse gas reduction potential.
Glass for Europe
· · filed 3 Nov 2021 · source
The European flat glass sector takes it as its role to produce the materials essential for renovating Europe’s buildings, for supporting the clean mobility transition and for increasing the share of renewable solar energy in Europe.
Verband der Chemischen Industrie e.V. (VCI)
· · filed 14 Oct 2021 · source
VCI contribution to the stakeholder consultation on the Commission proposal on the revision of the market stability reserve of 14.07.2021 (COM (2021) 571 final): — The proposal is to extend the tightening of the market stability reserve until the end of 2030, which was actually limited in time until 2023.
Filed in German · English published by the European Commission
The Danish Chamber of Commerce’s consultation response regarding the Communication on the Fit for 55-package from The European Commission. The Danish Chamber of Commerce thanks the EU Commission for the opportunity to respond to the Communication on EU Emission Trading System.
I agree that it makes complete sense to retain the 24% intake level. However it makes little difference without reducing the 833m threshold. Inclusion of aviation, with a cumulative deficit in 2024 of c286m (on my numbers), has a marked reduction in TNAC. On my estimates, TNAC will be 983m at end 2023. Reducing TNAC by 286m of cumulative aviation in 2024 alone reduces TNAC to 697m, well below the 833m threshold.
Method. Every quote is verbatim from the organization’s own submission to the European Commission, trimmed to its opening passage and never summarized by a model. Where a submission was filed in another EU language we show the English text the European Commission publishes alongside it, labeled on the quote; the original is one click away at the source. Groupings use the respondent type the organization itself selected when filing. We deliberately do not label anyone “supportive” or “opposed” — you read what they wrote and draw your own conclusion. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.