RWE AG

RWE fully supports the European Green Deal and the goal of a climate-neutral European Union by 2050. The Green Deal should enable the EU to transform its economy and put it on a more sustainable pathway. Therefore, RWE warmly welcomes the EU's various sustainability initiatives including the harmonisation of human rights and environmental due diligence obligations in the EU.

Almost all scenarios demonstrate: negative emissions are needed to achieve the objectives of the Paris Agreement to limit the global temperature increase to well below 2 degrees Celsius while pursuing efforts to limit the increase to 1.5 degrees. Also for the EU's goal of becoming climate-neutral by 2050, negative emissions are essential.

RWE welcomes the opportunity to provide feedback on the draft amendments to the Climate Technical Screening Criteria (TSC). We support most of the proposals that aim to improve the usability of the Taxonomy. However, we believe that the draft delegated act could be improved further. Please see our detailed feedback attached, focusing on Annex I on Climate Change Mitigation.

RWE welcomes the opportunity to provide feedback on the Commissions call for evidence regarding the implementing act on carbon price paid in a third country, as foreseen under Article 9 of the CBAM Regulation. Clear rules on the recognition of third-country carbon pricing are critical to ensuring the effectiveness, fairness and credibility of the EU CBAM, and avoiding unnecessary administrative burden.

Revision of the Industrial Emissions Directive (IED): transformation of industry and security of power supply at stake  As part of the EU action plan "Zero Pollution Target for Air, Water and Soil", the EU Commission presented a proposal for the revision of the Industrial Emissions Directive (IED) on 5 April 2022.

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

RWE welcomes the revision of the Non-financial Reporting Directive leading to the Corporate Sustainability Reporting Directive. Strengthening reporting requirements including relevant sustainability aspects will lead to more transparency in corporate reporting while allowing organizations and companies to follow a transition path to a sustainable and economic business model.

RWE welcomes the opportunity to provide comments on the Commissions call for evidence regarding the implementing act on the adjustment of CBAM obligations to account for free EU ETS allowances, as foreseen under Article 7 of the CBAM Regulation. Clear rules on the calculation of embedded emissions are essential to safeguard competitiveness and maintain the credibility of CBAM.

A massive speed-up and scale-up in the expansion of renewables is the answer to the current energy crisis. With the right investment framework, renewables will create valuable jobs and deliver long-term low-price electricity for consumers in Europe. However, existing regulatory frameworks and supply chain capabilities are a barrier to this expansion, putting the success of the energy transition at risk.

RWE supports the development of a CO2 network to facilitate the integration and adoption of Carbon Capture and Storage (CCS) and Carbon Capture and Usage (CCU) in hard-to-abate/decarbonise sectors, and to enable BECC(U)S or DACC(U)S projects to generate carbon removals. Regulation should be targeted to support market and infrastructure development. Please find our detailed response attached.

Are these (reporting) requirements only originating from EU law? The reporting requirements are often originating from EU law and are specified and be made even more complicate on a national level. Are there specific areas (type of reporting requirements or policy areas) that are particularly problematic?

RWE strongly supports the establishment of a robust EU framework allowing the limited use of highquality international carbon credits toward the EUs 2040 climate target. The 90% net-reduction target is ambitious and appropriate, yet residual emissions in hardtoabate sectors cannot be appropriately eliminated domestically by 2040.

Feedback of RWE An effective implementation of renewables acceleration areas for speeding up the EUs energy transition Summary: RWE generally welcomes the revised Directive (EU) 2023/2413 on the promotion of the use of energy from renewable sources (RED), which has the potential to significantly contribute to the achievement of the EU renewable energy targets.

RWE welcomes the opportunity to provide comments on the Commissions call for evidence regarding the implementing act on the adjustment of CBAM obligations to account for free EU ETS allowances, as foreseen under Article 31 of the CBAM Regulation. Clear rules on the free allocation adjustment are essential to safeguard competitiveness and maintain the credibility of CBAM.

The reform of the Electricity Market Design (EMD) is an opportunity to improve consumers ability to benefit from the roll-out of renewables and at the same time to provide confidence to investors in meeting the European decarbonisation goals. In principle, many features of the current EMD have proven themselves and are worth preserving.

RWE welcomes the opportunity to provide feedback on the initiative to update the existing network code and prepare the EU power grid for the future by reflecting key developments such as the increasing deployment of renewable energy and battery storage. Our detailed comments and recommendations can be found in the attached document.

RWE welcomes the European Commissions proposal to facilitate intra-EU shipments of fibre-reinforced composite material waste and permanent magnets from end-of-life or decommissioned wind turbines. The proposal supports RWEs circular economy ambitions, including its commitment to achieve no blades to landfill in Europe.

RWE welcomes the European Commissions initiative to revise national targets and flexibilities within the EU climate policy framework beyond 2030. EU-wide, market-based approaches remain the most efficient way to achieve emissions reductions and maintain a level playing field across Member States.

We welcome the European Commissions Market Integration and Supervision Package proposal and support efforts to increase legal certainty, harmonisation, and efficient supervision in the EU. In our comprehensive response which we attached as pdf, we highlight key areas for improvement and suggest targeted simplifications to reduce regulatory burdens and foster better market integration.

We welcome the opportunity to provide feedback on the proposed changes. We recognise the need to update the current REMIT legislation, including the Delegated Act and the Implementing Regulation, as well as their respective annexes. We appreciate the effort put in from the European Commission and ACER to dialogue with market participants.

The EU Commission is proposing to increase the budget of the Reconstruction and Resilience Facility (RRF) of the €700 billion Corona aid package, to finance the measures of the REPowerEU package. Under the Commission’s proposal, allowances worth €20 billion would be returned from the Market Stability Reserve (MSR) to the market by the end of 2026 through auctions – based on current market prices this corresponds to…