Finnish Energy (ET) welcomes the Commission’s proposal to achieve 90% net emission reductions by 2040 compared to emissions’ level in 1990. Finland’s own goal is to achieve carbon neutrality by 2035.
Achieving this goal requires all zero and low carbon energy solutions, including renewables, nuclear, energy efficiency, storage, CCS, CCU, natural carbon removals, geothermal, hydro-energy, and other current and future net-zero energy technologies. This technology-neutral approach must be promoted in further development.
Sustainable bioenergy plays a crucial role in Europe as an energy source. Sustainable bioenergy is essential for heat production and serves as an energy source for bio-CHP (combined heat and power) plants during the winter season. Criteria for bioenergy sustainability are defined in the Renewable Energy Directive, and the main principles must be maintained to allow renewable energy to grow according to the Commission’s scenarios. Carbon dioxide being of biogenic origin will be also increasingly important as raw material for fuels for challenging-to-electrify uses. Legislation and the operating environment must be enabling.
Electrification is of utmost importance. This requires investments not only in emissions-free and low- emission energy production but also significant investments in strengthening, expanding, making smarter, and enhancing the flexibility of electricity grids. Climate actions should be carried out while ensuring security of supply.
In addition to electrification, comprehensive solutions for efficient heating play an important role in future energy systems, and the significance of district heating infrastructure as an enabler for various heat sources needs more focus.
The need for carbon capture in addition to emission reductions is evident for achieving first the 2040 targets, the carbon neutrality by 2050 and for being net-negative thereafter. Financing and promotional efforts should focus on capturing carbon dioxide from sustainable sources. Examples of such sources include sustainable biomass for energy use, carbon dioxide generated from waste incineration and directly from air. Incentives for capture and storage should be based on compensation for storing and the value as raw material of sustainable carbon dioxide. Ideally, this value should be determined within European markets.

We find the current structure of sectors (ETS, ESR, LULUCF) workable starting point also for the climate policy architecture in the coming decade. In addition, we propose that an indicative European level target (hence not allocated to member states) to promote technical sinks (BECCS, DACCS) is decided. For companies BECCS / DACCS must be voluntary, and the companies have freedom of choice what they will do with the certificates received and to which party they will offer them.
Given the uncertainty related to LULUCF and the challenges following climate change, we call for cautious in setting the target, and the importance of managing the uncertainties. One measure to help the member states to efficiently achieve the targets set could be to allow the use of international credits. The use of international credits could be limited and could be allowed for reaching the 2030 LULUCF targets also already.
Asiantuntijamme tällä aihealueella
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