EnergyTag

Please find full response in document attached. The consultation highlights the need to clarify and strengthen PPA requirements to ensure CBAM is effective. EnergyTag welcomes this focus and offers the following recommendations, which should apply to the use of PPAs for both direct electricity imports and for electricity embedded in products.

Europe's need to shift to a regulatory framing of round-the-clock renewables from a mentality of thinking of renewable buildout in single technologies and siloes. This must be a core focus of the the post 2030 framework. See out detailed recommendations and evidence attachded

Europes electrification is being held back not by a lack of renewable generation, but by the lack of affordable, predictable clean electricity products that deliver this power to consumers when they need it most. The solution is to align clean supply with demand through market instruments that deliver electricity when its needed - such as long-term, firmed PPAs combining renewables, storage, and flexibility.

Our comments relate uniquely to Section 2.4 - Electricity Modelling of the Annex to the delegated act. We recognise that the use of contractual instruments (CIs), without solid guardrails to ensure robust zero emissions claims and avoid double counting, would weaken the battery carbon footprint regulation and that using national averages does hedge against certain risks.

We propose 3 concrete amendment to ensure data centre sustainability is centered around the future needs of europe's power system - renewables and clean flexibility. Proposed Amendment 1 Remove Granular GO Conditionality Proposed Amendment 2 Align ERES-PPA Criteria with ERES-GOO Granularity Criteria Proposed Amendment 3 Replace the Grid Functions Flag with a Flexibility Metric