Asociación de empresas de energía eléctrica, aelec

We hereby express our agreement with the methodology already established by the Regulation for calculating emissions of electricity as a CBAM good. The use of the CO2 emission factor (resulting from dividing the CO2 emission data of the electricity sector by the gross electricity generation based on fossil fuels in the relevant geographic area), by default, is the best approach, as marginal technologies (in general…

The Spanish Association of the Electricity Industry (aelēc) would like to present the following remarks with the aim of participating in this public consultation. 1. INTRODUCCIÓN The electricity system is affected by a series of inefficiencies that make electric energy more artificially expensive, deteriorating its competitiveness.

Initial comments consultation on on the the European Roadmap Commission “Revision of the public Industrial Emissions Directive” (Inception impact assessment). April 20, 2020 THE BREF (Seville) PROCESS: It is a robust procedure that allows the participation of stakeholders to establish the Best Available Techniques.

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

aelēc welcomes the launch of this consultation as new challenges emerge on the European electricity system triggering the needs on stable and clear regulatory frameworks to contribute to its stable and secure operation.

1. There is no Green Deal without a just transition The Spanish power sector welcomes this initiative to mitigate the effects of the Green Deal, that has to be aligned with Union State aid rules currently in force as set out in Articles 107 and 108 TFEU. 2. A financially independent fund is key The JTF must be fuelled with EU “fresh money” and provide a more substantial financial support.

Please, find attached our comments on the Inception Impact assessment: Update of concentration limit values of persistent organic pollutants in waste (https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12411-Update-of-concentration-limit-values-of-persistent-organic-pollutants-in-waste) In relation to the proposal to revise down the limits of Annex IV of the European Regulation on Volatile…

Overall, we are concerned that the draft increases reporting burden without commensurate surveillance benefit. Exposure reporting is the clearest example. The notion of flagging prima facie unjustified trading behaviour implies a de facto hedge benchmark and sanctioning deviations.

We welcome the Commission proposal for Implementing Regulation on interoperability requirements and non-discriminatory and transparent procedures for access to data required for customer switching, as a necessary tool to promote competition and good functioning ok the EU electricity supply market.