Central Europe Energy Partners (CEEP) welcomes the possibility to provide feedback on the technical screening criteria (Annex I and II) of EU Taxonomy for climate change mitigation and climate change adaptation.
We are fully committed to meeting the ambitious energy and climate targets and building a carbon neutral economy by 2050. We strongly believe that climate change remains one of the most urgent challenges and in order to accelerate our actions to reach the 1.5 degree ambition, we need to put our efforts on developing sustainable financing, in particular, cost-effective electrification, low carbon electricity and zero emission vehicles.
The Delegated Act is an important step to establish an EU classification system for sustainable activities and to help investors and companies access green financing. However, the initial proposal by the European Commission introduces several uncertainties, especially in the calculating methodology, which needs to be addressed if the Delegated Act is to be effective.
Our general remarks on the approach are supplemented by a proposal of drafting remarks included at the end of the CEEP’s position paper.
- CEEP calls on the EU to introduce, along the 100 gCO2e/kWh, an additional threshold of maximum 400 gCO2e/kWh of direct emission, which would be used to indicate installations which may still contribute to tackling climate change, during the interim period of up to 2030.
- To mitigating the climate risks, CEEP calls to introduce provisions which will allow categorising the investments in:
- stable gas fired power generation;
- transmission infrastructure required for their connection to the grid;
- transmission infrastructure required for operating these systems.
These provisions should be based on the consideration that where new gas fired power generation is constructed in the switch from coal to gas process, mitigating the 400 gCO2e/kWh threshold of direct emission indicated in point 1, can still substantially contribute to tackling climate change.
- CEEP also believes that in addition to maintaining the role of natural gas a transitional fuel in electricity production it can also play a key role in the transport sector to allow for its swift decarbonisation. The role of LNG, CNG and biomethane in the transport and energy sector is increasing and the financial opportunities for further investments in this segment should be maintained at least until the hydrogen technologies are mature enough to take over.
- CEEP calls on the EU not to introduce a single threshold for the emissions of CO2 from ammonia production. Instead CEEP calls on the EU to introduce a predictable pathway consisting of a trajectory of thresholds for the years 2020 – 2050 with respects to emissions per tonne of ammonia produced. At least until 2030, all modernization projects that reduce CO2 emissions and comply with (Best Available Technologies) BAT should be eligible for EU funding.
- CEEP call to apply the “direct emission” approach instead of “life cycle” approach across the Delegated Act. CEEP believes that this is a crucial element which needs to be addressed in order for the taxonomy system to function effectively. Currently, the draft Delegated Act introduces emission thresholds, which should be calculated as XX gCO2e/kWh either of “direct emissions” (Annex II, point 4) or in the life cycle (Annex I, point 4).
Download the full CEEP’s feedback.