Finnish Energy welcomes the Commission proposal for the directive on the internal market in electricity. We are committed to reaching the long-term vision of a well-functioning, integrated and flexible electricity market. Today the Finnish market is already functioning in many aspects according to what is aimed at by the proposal – e.g. smart metering, demand participation, new products for customers. Our experience has proved that this is possible, but at the same time you must pay attention to many details to achieve a sustainably well-functioning market. We would like to underline some strengths of the proposal and propose some areas of improvement.
We also welcome the Commission proposal for the revised Electricity Regulation which further strengthens the European electricity market and fosters the market based approach. However, while we welcome the Commission’s proposal overall, there are various key components which require some fine-tuning.
Furthermore, the electricity sector package includes the Commission proposal for a Regulation on risk preparedness in the electricity sector. It is important that Member States prepare themselves and co-operate with each other to identify and manage risks relating to security of electricity supply.
One of the most important files in the package is the proposal for renewables directive – RED II. The revised proposal is more holistic when covering all the main sectors of energy use (heating and cooling, electricity and transport). The proposal is a clear message for more market based electricity market in the future. On the other hand, the proposal raises some concerns on the future of district heating and cooling (DHC) and does not fully recognize the division of energy use in ETS and NON-ETS sectors.
The RED II also includes proposals for biomass sustainability. Bioenergy will continue to play an important role in the renewable energy mix. Increasing amounts of forest biomass for energy use must originate from sustainably managed forests. The proposal can efficiently encourage European biomass operators take care of this. However, the directive should be regarded as one of the incentives to ensure sustainability. The operators must do more than just respect the law. This will happen by using voluntary means in addition to legal demands.
The commission proposal package wants to put energy efficiency first by two directives. One is the revised Directive on energy efficiency. The current Energy Efficiency Directive (2012/27/EU) has been successful because it allows Member States to address their national challenges – it is highly important that flexibility for member states should not be lost. We would like to underline some strengths and weakness of the new proposal and propose some areas of improvement.
The other energy efficiency file is the revised directive on the energy performance of buildings. Finnish Energy is committed to reaching a decarbonized building stock by 2050. District heating and electricity sectors have the vision of being carbon neutral year 2050. It is fundamental to ensure that policies reflect both the reduction of heating demands and the connection of buildings to low-carbon heat supplies including district heating and electricity. The principal of an equal treatment between on-site RES and RES supplied through the energy carrier is essential to achieve a fully aligned framework, in line with the EU Heating & Cooling Strategy.
Finally, Finnish Energy would like to comment the Commission proposal for the Governance of the Energy Union. Our sector is committed to reaching the common EU-level energy and climate targets for 2030. The governance is a new approach to ensuring coordinated common efforts. It is of utmost importance to coordinate member states’ policies on the internal energy market. However, flexibility for member states to build on their individual strengths should be maintained.
Finnish Energy will continue working with its stakeholders to ensure a successful outcome of the proposals and construction of a prosperous Energy Union.
Our contact persons regarding these proposals are:
Clean Energy Package in general
Renewable energy directive RED II
Energy efficiency directive
Energy performance of buildings directive