PGE Polska Grupa Energetyczna S.A.

PGE Polska Grupa Energetyczna S.A. welcomes the opportunity to provide its feedback on the Industrial Accelerator Act. Please see our feedback attached. Key messages: 1. Flexibility for the Member States in applying non-price criteria: Since the non-price criteria and the new requirements for the renewables public auctions and public procurement have not been fully tested in practice, the new rules should allow for…

PGE Polska Grupa Energetyczna S.A. (PGE) welcomes the European Commissions initiative to evaluate Directive 2014/25/EU on procurement by entities operating in the water, energy, transport and postal services sectors. PGE would like to provide its views concerning the evaluation regarding the above-mentioned directive and propose several improvements in the area of public procurement.

In PGE's opinion, the following issues should be considered: THE EXEMPTION FOR THE ENERGY SECTOR The progress of the liberalization of energy markets, the unbundling of network operations from generation and supply, the introduction of market-based mechanisms enabling non-restricted choice of contractors, has led to a significant increase in the level of competition on the energy sector in the recent years.

Please find below some general comments from PGE Polska Grupa Energetyczna to the call for evidence on the review of Climate and Environmental Delegated Acts under the EU Taxonomy. For detailed comments please see the attached document.

Please find below some general comments from PGE Polska Grupa Energetyczna to the call for evidence on the review of Climate and Environmental Delegated Acts under the EU Taxonomy. For detailed comments please see the attached document.

Summary of PGEs Position The heat benchmark is of particular importance for district heating, as it directly determines the level of free allocation for heat production. In the published Annex, the heat benchmark value for 20262030 is set at 31.2 allowances/TJ (equivalent to 31.2 kg CO/GJ), which corresponds to a 34.1% reduction compared to 20212025 and reaches the maximum reduction level under the current benchmark…

PGE welcomes the opportunity to provide its feedback on the renewable energy legal framework post-2030. Please see our comments attached. Our key points: 1) Setting the binding targets for renewable energy in 2040 is not necessary.

Please find below PGE Polska Grupa Energetyczna's key messages on the review of the EU Taxonomy climate delegated act. For specific comments please see the attached document. Key recommendations: The transition of gas-fired installations, including in the district heating sector, to full use of renewable or low-emission gaseous fuels by the end of 2035 requires broad access to decarbonized fuels.

Please find PGE's feedback attached. PGE's key messages: 1) The electrification will play a key role in achieving EUs climate goals. In order to ensure the affordable energy prices, the focus must shift to key enablers, like ensuring sufficient public funding, supporting dispatchable capacities and sector coupling, investments in grid and storage.

Please find below PGE Polska Grupa Energetyczna's key messages on the Guidance on applying the do no significant harm principle under the 2028-2034 multiannual financial framework. For specific comments please see the attached document. Key recommendations: The DNSH principle is currently applied in a fragmented, inconsistent, and overly detailed manner.

PGE Polska Grupa Energetyczna S.A. welcomes the opportunity to provide its feedback on the possible use of international carbon credits. Please find our feedback attached. Key messages: 1) Climate change is a global challenge that requires coordinated international action. The European Union has demonstrated strong leadership in emission reduction.

Below I present a summary of PGEs position on the EED post2030 framework. The full position, including detailed explanations, is provided in the attached document. PGE supports ambitious EU energy efficiency objectives, but stresses that the post 2030 revision of the Energy Efficiency Directive must be coherent, predictable and technically achievable, particularly for district heating systems in Central and Eastern…

The PGE Polska Grupa Energetyczna S.A. welcomes the opportunity to provide its feedback on the revision of the EU Energy Security Framework. Our full position is presented in the file enclosed. Key messages: Among the policy options presented by the Commission in the call for evidence, Policy option 2 targeted reinforcement appears to be the most appropriate from the perspective of subsidiarity, the allocation of…

PGE Polska Grupa Energetyczna S.A. (hereinafter: PGE) welcomes the opportunity to provide its feedback on the revision of national targets and flexibilities in the EU climate policy framework after 2030. The discussion on the post 2030 climate targets must be firmly anchored in the current geopolitical reality, including heightened security risks, volatility of global energy markets and the need to safeguard…

Please see the feedback of PGE Polska Grupa Energetyczna S.A. below: 1) The resilience of solar technologies: The Article 2 lists the circumstances which PV modules should withstand. The current wording is directly referring to the heat (hot-spot heating effects) or weather event like hail, but only indirectly suggesting the impact of harsh winter and low-temperatures occurring in some Member States: outdoor…

Position of PGE Polska Grupa Energetyczna S.A. on the draft Commission Implemented Regulation (EU) amending the Activity Level Changes Regulation PGE Polska Grupa Energetyczna S.A. (hereinafter: PGE) welcomes the opportunity to provide feedback on the draft Commission Implemented Regulation amending and correcting Implementing Regulation (EU) 2019/1842 laying down rules for the application of Directive 2003/87/EC of…