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Danish Energy highly welcome the opportunity to comment on the European Commission’s Roadmap as part of the EU Emissions Trading System (ETS) review process. In light of the EU target of climate neutrality and the Commission’s proposal to increase the 2030 reduction target to at least -55%, Danish Energy supports reviewing and strengthening the EU ETS in order to ensure the ETS remains a primary driver of Europe’s…

ETS reform as part of a package to collectively increase climate ambition Deutsche Umwelthilfe (DUH) notes that even with a 2030-climate target of 55%, Europe remains off track to reach the Paris Agreement 1.5°C objective. Emission cuts of at least 65% are required for the EU to fully honor its international commitments.

This document comprise Danish Energy’s updated positions on: 1. The ETS-directive and the Market Stability Reserve (MRS) 2. The Carbon Border Adjustment Mechanism (CBAM) Generally, we find that the proposed revision of the ETS-directive is very positive.

Immediate social concerns and unclear climate benefits Environmental Action Germany (DUH) welcomes pricing in climate damage costs in the transport and building sectors, where emissions reductions are slow at best. We are concerned, however, that the introduction of a new emissions trading system is not the right instrument.

Please find the attached paper for our full feedback. Danish Energy Welcomes the Commission's initiative to evaluate the Energy Efficiency Directive (EED) in order to align it with the EU's new and more ambitious climate targets.

Deutsche Umwelthilfe (DUH) would like to stress that currently, the EED, like the other elements of the Clean Energy for All package, are inconsistent with the ambition of the Paris Agreement, as action in the next 10 years will be decisive in reaching the 1.5°C objective. We fully support the initiative to revise the EED and stresses that the ambition level needs to increase significantly.

Strengthening of the Energy Efficiency Directive DUH is calling for the adoption of a binding energy efficiency target of at least 45 % in the year 2030 (compared to the EU Reference Scenario 2007 or of at least 20 % in 2030 compared to the EU reference scenario 2020). This will help to achieve the 1.5°C target of the Paris Agreement, improve the energy security of the EU, create jobs, and reduce pollution.

We commend the Commission's proposal for a fundamental shift in the minimum taxation of energy. Due to the current incoherent system, which includes ambiguous definitions and national loopholes, green electricity does not receive the support it needs, despite the critical role electrification will play in Europe’s decarbonization.

Environmental Action Germany (Deutsche Umwelthilfe, DUH) notes that the many tax exemptions in the Energy Taxation have led to a very disparate and complex energy tax landscape in Europe, which also hinders the integration of the internal energy market.

Danish Energy highly welcomes the European Commission’s decision to revisit and strengthen the CO2 standards for cars and vans for 2030 and thanks the Commission for this opportunity to share our views on the revision. Danish Energy is a non-commercial organisation for Danish energy companies, mainly active in the electricity sector, covering activities from energy production, distribution and trading.

The car CO2 standards represent the primary EU policy instrument driving the transition to zero-emission road transport. Current standards are not in line with the Paris Agreement, and several elements of the regulation limit its effectiveness. These shortcomings must now be addressed, and the overall ambition significantly increased to set road transport on a rapid path to zero emissions within the next few years.

DUH welcomes the opportunity to submit feedback on the European Commission (EC) proposal for revised car CO2 standards. Road transport emissions have been rising over the last 30 years. Without fast and significant reductions in passenger car emissions, the EU won’t be able to meet its own climate targets, let alone the 1.5°C limit.

Danish Energy welcomes the opportunity to comment on the roadmap for the Hydrogen and Gas mar-kets Decarbonisation Package. Danish Energy is an association representing Danish electricity and gas companies. Our members include gas suppliers and companies active in the North-western Euro-pean gas markets.

Deutsche Umwelthilfe / Environmental Action Germany welcomes the opportunity to comment on the initiative at this stage. This legislation is essential in leveling the playing field between natural gas, hydrogen, other gases and renewable electricity. Natural gas currently enjoys significant regulatory advantages. While green hydrogen, renewable electricity etc.

Dansk Energi (Danish Energy Association) welcomes the opportunity to comment on the proposed revision of EU rules on market access. Dansk Energi fully supports the initiative to provide an appropriate market framework to accommodate the increasing EU climate ambitions.

Deutsche Umwelthilfe / Environmental Action Germany (DUH) welcomes the opportunity to consult on the gas market directive and regulation. In general, we are not pleased with the roles that low-carbon gases and green hydrogen are given with this reform. The broad allocation of hydrogen across many sectors is critical.

In general, we applaud the regulation's intention of facilitating the adoption, deployment, and development of charging infrastructure across Europe, as well as improving interoperability and transparency for the benefit of both customers and the green transition in transportation.

The revision of the AFIR offers the opportunity to set an important course for a change of engines towards a sustainable transport sector. We support the rapid development of the infrastructure in order to enable a faster conversion to electric motor operation.

Environmental Action Germany (Deutsche Umwelthilfe e.V.) welcomes the opportunity to comment on the ReFuelEU initiative. Greenhouse gas emissions from aviation must be reduced urgently. The ReFuelEU inception impact assessment, however, neglects important aspects of sustainability and availability of alternative fuels for aviation.

This document comprises Danish Energy’s updated positions on: 1. ReFuelEU Aviation on ensuring a level playing field for sustainable air transport 2. FuelEU Maritime on the use of renewable and low-carbon fuels in maritime transport It is important to have ambitious European targets for decarbonization and the use of renewable energy and renewable fuels.

Dansk Energi (Danish Energy Association) welcomes the opportunity to comment on the proposed revision of EU rules on market access. Dansk Energi fully supports the initiative to provide an appropriate market framework to accommodate the increasing EU climate ambitions.

Deutsche Umwelthilfe / Environmental Action Germany welcomes the opportunity to consult on the gas market directive and regulation. In general, we are not pleased with the roles that low-carbon gases and green hydrogen are given with this reform. The broad allocation of hydrogen across many sectors is critical.