CEZ Group

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.

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.

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.

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.

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…

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.