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•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.

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.

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.

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.

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.

• All EU policies, actions and strategies should be consistent and deliver upon both the climate objectives and the sustainable development goals across the full set of their environmental, economic and social dimensions.

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.

The Enel Group strongly welcomes the proposed review of the Energy Taxation Directive. Such review has been long due. There is an increasingly urgent need to align EU energy taxation with enhanced climate and environmental objectives and take into account current and projected energy technologies’ development.

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.

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.

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.

Enel strongly believes that the completion of the decarbonization of the power sector and the electrification of final uses, such as transport, heating and cooling and industry, along with energy efficiency, are the key levers to trigger for a clean and cost-efficient transition. These measures have the lowest CO2 abatement cost to tackle the largest part of emitting activities.

Enel strongly believes that the completion of the decarbonization of the power sector and the electrification of final uses, such as transport, heating and cooling and industry, along with energy efficiency, are the key levers to trigger for a clean and cost-efficient transition. These measures have the lowest CO2 abatement cost to tackle the largest part of emitting activities.

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…

The current directive fails to mitigate the environmental impact of transport, since many of the alternative fuels currently allowed emit CO2 since some of them are pure or derivate fossil fuels. The current directive does not set the adequate framework to achieve long-term EU CO2 emissions reduction objective, as it does not adequately support the deployment of zero emission mobility.

The ‘Fit for 55’ package paves the way for the implementation of the EU Green Deal, this set of legislative revisions represents a unique opportunity for Europe to take a step forward and win the climate race. That is why now it is the time to show steadfast commitment and prioritize the most efficient, sustainable and cost-effective pathways to decarbonize the economy.

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.

Enel welcomes the Commission communication on an EU Methane Strategy and the further proceedings on a legislative proposal to reduce EU-related methane emissions from fossil fuels, as both acknowledge methane as a relevant contributor to GHG emissions. Methane emissions contribute with a relevant share (approx. 15%) to global GHG emissions.

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.

Enel welcomes the Commission proposal on a Regulation on methane emissions reduction in the energy sector as a first step to tackle the significant contribution of methane to GHG emissions, but greater efforts are needed if the EU wants to lead global methane emissions reductions.

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].

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.

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…

New and major threats are being experienced by the continental gas sector and a coordinated action at European level is needed. Enel therefore welcomes the intention of the European Commission to revise the Regulation (EU) 2017/1938, which aims to improve the resiliency of the gas sector and ensure that security of gas supply is fit to the current challenges.