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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.

PLINOVODI d.o.o. as a TSO of gas infrastructure would like to highlight that low carbon and renewable gases, such as green hydrogen, biogas and e-gases will play important role to decarbonize the EU ETS sectors.

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.

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.

PLINOVODI d.o.o. as a transmission system operator in Slovenia supports stronger promotion of energy efficiency in all areas of the energy system and in all relevant sectors, where activity affects energy demand, as well as energy efficiency first principle as its key role.

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.

Company Plinovodi, as a transmission system operator in Slovenia, supports the ambitions of Commision to harmonise energy tax legislation in EU. However, there shall be enough flexibility to accomodate specific situation in different Member states. Please find below two proposals in this direction.

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.

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.

We support intention to strengthen reducing of emissions in road transport. This sector has indeed played and will play a key role. We support the deployment of battery electric vehicles (especially in light transport), fuel-cell electric vehicles using hydrogen and plug-in hybrid electric vehicles.

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.

Plinovodi, the Slovenian gas TSO, is summarizing its feedback in bellow points: 1. Application of Internal Energy Market rules to H2 market as H2 system is interoperable with other systems, with additional elements that reflect the particularities of H2 business.

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.

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.

Plinovodi welcomes the European Commission’s publication of the recast Gas Directive and agrees with the response given by ENTSOG, with further emphasis highlighted bellow. The opinion of the TSO company Plinovodi is that the introduction of an ITC mechanism for hydrogen would be unnecessarily complex, costly and overly burdensome for Slovenia.

Plinovodi welcomes the European Commission’s publication of the recast Gas Regulation and agrees with the response given by ENTSOG, with further emphasis highlighted bellow. Plinovodi especially supports the removal or extension of the time limitation for the financial transfers between regulated services for gas and hydrogen as in some Member States the hydrogen market does not even exists yet or is not mature…

PLINOVODI d.o.o. as a TSO of gas infrastructure would like to highlight full support for further expanding deployment of alternative fuels infrastructure, since certain limited gaps in the network and infrastructure remain and prevent some member states to reach the objective. We are of opinion that by 2025 or at least by 2030 member states should fill the remaining gaps.

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.

Deutsche Umwelthilfe / Environmental Action Germany welcomes the opportunity to comment on the initiative at this stage. Regulating methane emissions in the oil, gas and coal sectors is indeed a powerful tool and necessary in mitigating GHG emissions and meeting climate targets.

Environmental Action Germany (DUH e.V.) welcomes the Methane Regulation proposal as it will for the first time impose binding rules regarding methane leakage on operators of energy infrastructure within the EU. Particularly positive are the new provisions on Measurement, Reporting and Verification (MRV) of methane emissions, regular inspections by regulatory agencies, as well as the requirement of quarterly Leak…

Plinovodi, the Slovenian gas TSO has summarized remarks on the proposal for a Regulation on methane emissions reduction in the energy sector in the text bellow. The Regulation will introduce a relatively complex system for managing methane emissions in gas transmission systems, which will represent a major challenge for system operators to establish effective detection, control and reporting of emissions.

Environmental Action Germany welcomes the opportunity to comment on this EC initiative. We wish to make the following comments: 1. Crop biofuels are more damaging to the climate than fossil fuels. Crop biofuels must be phased out entirely and must not be incentivised for use in shipping. 2. Advanced biofuels based on wastes and residues are not automatically sustainable.

We completely agree that air pollution produced by ships at berth is a significant concern for coastal areas and port cities. And it is understandable that specific and stringent obligations should be imposed to reduce emissions at berth from ships that draw power from their engines during their stay in port. Their emissions should be addressed as a priority.