Compare organizations

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.

In short below and for details please find enclosed EDF(Electricité de France)'s contribution EDF welcomes the ambitious revision of the EU-ETS to align it with the new 2030 target. A meaningful carbon price will drive cost-effective energy transition by promoting investments in renewable and low-carbon technologies.

The Directive 2012/27/EU on energy efficiency (EED) revised in 2018 is a key element to achieve the European Green Deal objectives, with the Renewable Energy Directive (RED) and the European Emissions Trading System (EU ETS).

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.

EDF welcomes the revision of the EED, which is an opportunity to ensure that it is fully aligned with Green Deal objectives and coherent with the EU ETS, the RED, the EPBD, the ETD, the Energy System Integration Strategy, and the Renovation Wave strategy. Nevertheless, these legislative works have to be done with a focus on affordability, taking into account the most cost effective way to reach the climate targets.

EDF welcomes the intention of the Commission to review the Energy Taxation Directive (ETD). The current Energy Taxation Directive does not contribute to the EU’s climate and energy policy goals: there is no link between minimum tax rates and their energy content and CO2 emissions. The ETD does not provide preferential tax treatment for low-carbon energy final consumption.

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.

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.

Low carbon and renewable (LC&R) gases will be needed to complement direct electrification and contribute to a net-zero economy, especially in hard-to-abate sectors. To support energy sector integration, it is key to compare costs, potentials and societal benefits of decarbonisation options from production to end users and avoid the sole focus on infrastructure costs.

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.

EDF welcomes the European Commission proposal for a Regulation on the deployment of alternative fuels, as part of the “fit for 55” package. The transport sector should indeed decrease its GHG emissions drastically to reach the renewed climate objectives enshrined within the EU Green Deal and carbon neutrality by 2050.

According to latest IEA data, there were around 70 million tons of methane emitted to the atmosphere from oil and gas operations in 2020, this is broadly equivalent to total energy-sector emissions of the entire EU. EDF would like to highlight that the impact of methane is 30 times that of C02 on a 100 year time horizon, but it is ca. 85 times that of CO2 over a 20 year time span (1) .

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.

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.

EDF welcomes the European Commission’s FuelEU Maritime initiative aiming to reduce GHG emissions in the maritime sector. Today maritime transport is a growing source of GHG emissions and the EU needs to tackle this issue to be fully in line with the Green Deal and the carbon neutrality target by 2050.

EDF highlights that the decline of the use of fossil fuels in the EU energy mix is a necessity to reach the European climate objectives following different pathways and pace depending on the initial energy mix of each country.

Plinovodi, the Slovenian gas TSO, has summarized remarks on European Commission’s Proposal for the REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Regulation (EU) 2017/1938 of the European Parliament and of the Council concerning measures to safeguard the security of gas supply and Regulation (EC) 715/2009 of the European Parliament and of the Council on conditions for access to natural gas…