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GENERAL COMMENTS: • Extension of EU ETS should not be considered as most effective solution across all sectors. Individual approach in specific sectors should be applied in order to maximize environmental benefits. • As regards waste sector, one of the main identified sources of methane are uncontrolled emissions of landfill gas in landfill sites.

•Enel welcomes the approach of the legislative initiative, aimed at strengthening the EU ETS, and the ambitious package of policies and measures to accelerate the just transition to a low-carbon economy. It is critical for the EC to adopt a holistic approach enhancing carbon pricing alongside complementary policies and measures.

GENERAL COMMENTS: • The effects of raising the contribution of the ETS towards a higher emissions reduction target will not be felt equally across the EU. Some MS will be more affected than others. • Required investment in Polish energy sector in the years 2021-2040 (according to the Polish government), are estimated at over PLN 560 bln (about EUR 125 bln). • PGNiG is concerned whether additional resources (2,5 p.p.

Please, find below a synthesis of Enel’s view on EU ETS revision proposal. For further details, please see the attached document. Enel welcomes the EU ETS Directive’s “Fit for 55” proposal of reform as it fits with the increased EU climate ambition and will help provide stable and predictable carbon price signals.

Enel strongly welcomes the Commission combined Evaluation Roadmap and Inception Impact Assessment for the review of Directive 2012/27/EU and amending Directive 2018/2002 on Energy Efficiency, as the “Energy Efficiency First” principle constitutes one of the main pillars of the EU’s fight against climate change and a successful and sustainable energy transition.

Enel welcomes the EU Energy Efficiency Directive’s “Fit for 55” recast proposal. The proposed increase of the EU target to reduce energy consumption by at least 9% by 2030 compared to the projections of the 2020 Reference Scenario baseline seems appropriate to reach the 55% GHG emissions reduction target by 2030.

GENERAL COMMENTS: • PGNiG highlights that some Member States due to national circumstances (e.g. Poland) still rely heavily on coal. PGNiG is actively involved in transformation of district heating by replacing coal plants with natural gas-fired high efficiency cogeneration units.

Since 1990, emissions from road transport have increased significantly and as of today account for almost a fifth of EU's GHG emissions. The next years are critical for curbing CO2 emission. If action is insufficient in the short-medium term, it will likely be impossible to make up for the deficit later, this requires a substantial decrease in CO2 emissions in the transport sector.

PGNiG welcomes the possibility to comment on the proposal for a regulation amending Regulation 2019/631 as regards strengthening the CO2 emission performance standards for new passenger cars and new light commercial vehicles in line with the Union’s increased climate ambition (Cars Regulation).

Maritime sector is a large and growing source of greenhouse gas emissions and related emissions are projected to increase significantly if mitigation measures are not put in place swiftly. Shipping emissions could increase between 50% and 250% by 2050 under a business-as-usual scenario, undermining the objectives of the Paris Agreement [Third IMO Greenhouse Gas Study 2014].

General comments: • The Council of the European Union recognised the need to support the development of different alternative fuels (including LNG as a transitional fuel). • As stated in the Impact Assessment accompanying the proposal for regulation, LNG provides a good solution to air pollution issues, allowing reductions in SOx and NOx emissions.