CEZ Group

The revision of the EU public procurement framework is timely and particularly relevant for the energy sector. Based on experience with the application of procurement directives, a revision of their scope is recommended, including the possible exclusion of the energy sector, sectoral contracting authorities, and/or specific production sources pursuant to Article 34 of Directive 2014/25.

Public procurement in the power and heat production sector, as well as in the wholesale and retail electricity and gas sectors, has undergone significant changes since the first EU-wide regulation of the rules for the purchase of goods, services and works. The integration of markets and the strengthening of the Energy Union have contributed significantly to increased competition in the relevant markets.

CEZ Group believes,there must be no reduction of GHG thresholds,as it would discourage investments that are necessary for transitioning toward a low-carbon economy (risk investing into possibly non-aligned project).In the proposal of the SP we lack appropriate reasoning of lowered thresholds and IA.Any proposal must be based on scientific/technical evidence to prove its feasibility,be supported by references.

CEZ Group position on ESRS consultation The CEZ Group welcomes the opportunity to take part in the ESRS revision consultation. Here are some comments and suggestions: The overall structure remains the same The framework still consists of 2 cross-cutting standards (ESRS 1 and ESRS 2) plus 10 topical E/S/G standards. Therefore, this is not a replacement of the ESRS architecture with a completely different model.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

As a leading European energy producer, CEZ Group has long supported the optimal setting of the EU ETS system, so that it provides predictable and, as far as possible, stable price signals for the entities covered.

CEZ Group can support an increase of the GHG target to 55 % by 2030. However, we expected that the impact of increasing the GHG target to at least 55 % by 2030 on different Member States would be analysed in the Impact Assessment that the EC presented in September. Unfortunately, it only assessed the impact on the EU as a whole.

Extending scope of CBAM from the view of power producers Energy sector is at the forefront of the EU decarbonization efforts, which is clear not only from so far reported emission reductions but also from the short-term future emission trajectories. That is why power producers cannot unconditionally support the extension of the CBAM scope downstream. If the energy transformation is about deploying low carbon (e.g.

CEZ Group welcomes many of the proposed changes, as they remove uncertainties and express the requirements, or relevant exemptions, more clearly in taxonomy. However, we also strongly believe that in many cases the changes were not improving the situation and in some Sections we are missing a corrective action by the EC altogether and CEZ Group would very much welcome, if EC would reconsider and make some…

The CEZ Group strongly believes the revision of the Sustainable Finance Disclosure Regulation should be in line with the decarbonisation policy objectives and support transition path of energy companies, which strive to lower the carbon footprint.

The ČEZ Group recognises the urgent need to address climate change linked to ongoing global warming. Therefore, it bases its long-term activities on a responsible approach to the environment, its employees and society as a whole. The energy sector is rapidly changing towards a zero-emission future, which poses a significant challenge in terms of transforming energy sources and locations.

CEZ Group welcomes the initiative of the European Commission to revise the Batteries Directive and suggests to include the following in its Impact Assessment: Proposed policies should cover the entire value chain, starting with the secure supply of raw materials with special attention paid to local deposits of raw materials.

The CEZ Group would like to highlight, that the obligation of integrating the sustainability reporting in the management report would put an extreme time pressure on undertakings and would be very demanding from the administration and associated costs point of view.

We support the European Commissions efforts to standardise and update the methodological framework for monitoring biomass sustainability. Based on practical experience, we identify several issues related to selected values and assumptions, including biomass import distance categories, default value increases, conversion efficiency and moisture content assumptions, and the proposed Cstor factor, which may create…

A specific comment: For the successful implementation of the revised Directive Proposal into practice, the Directive should not introduce retroactivity to existing charging infrastructure. At the same time, the obligation for MID certification should be established from a certain date in the future for all "newly manufactured" charging station, not for charging stations that have not yet been sold.

ESG Rating Methodology If companies are rated based on publicly available information, methodologies for assessment of the information should also be public. There should be standardized metrics and clearly defined requirements, so that benchmarking is reliable.

Dear all, CEZ Group welcomes the opportunity to comment on the draft REMIT II Implementing Act and supports the aim of strengthening transparency and integrity, however we highlight that the proposal raises legal, operational, and technical concerns. Please find our response in the attachement. Best regards, CEZ Group

As part of the public consultation on the draft implementing legislation setting out minimum requirements for environmental sustainability for public procurement procedures, we would like to submit expert comments on the individual provisions of the submitted draft implementing regulation.

Comment on using the term metering point administrator We require to introduce the following definition of the delegated operator in Article 2 and to use this term alongside the term metering point administrator (i.e. to add the words or the delegated operator next to metering point administrator) in the provisions specified below.