Round-up on consultations: EU Smart Sector Integration, Hydrogen Strategy and TEN-E


As of the 8th of June, the first step in the ongoing process to deliver on these promises were marked by the closing of the open calls for replies to the Commission’s Roadmaps. Commending the Commission’s dedication to the timely progress and finalisation of these initiatives, in the midst of challenging times, Bellona Europa issued several recommendations on all three files.

As outlined by the European Green Deal published in December 2019, the transition towards climate neutrality requires smart infrastructure as well as increased cross-border and regional cooperation to help achieve the “benefits of the clean energy transition at affordable prices”. For this to become a reality, the European Commission promised the development of a Smart Sector Integration Strategy as well as a EU Hydrogen Strategy. Additionally, the Commission outlined plans to review the regulatory framework for energy infrastructure – including the TEN-E Regulation.

Revision of the TEN-E Regulation

Bellona Europa is a strong supporter of the EU’s commitment to climate neutrality by 2050, and the need to revise regulation (EU) No 347/2013 “Guidelines for Trans-European Energy Infrastructure” (TEN-E). In our reply, we highlighted the importance of ensuring TEN-E compatibility with more ambitious climate action and the vision of a carbon neutral Europe by 2050.

In this context, the highest priority must be given to electricity grid expansion, hydrogen dedicated infrastructure and CO2 infrastructure. This will connect Europe’s different renewables, facilitating their direct and effective use as well as ensuring security of supply and availability. In situations where gaseous fuels may be used, or where electricity is not used directly, only dedicated hydrogen infrastructure should be developed, and industrial clusters should be prioritised in this regard. See the full reply here.

Bellona Europa therefore recommends that the European Commission ensures the revised TEN-E: 

  1. Keep Carbon Dioxide Transport as one of the 12 strategic trans-European energy infrastructure priorities
  2. Exclude unabated fossil fuel infrastructure as eligible for EU funding under the regulation

EU Smart Sector Integration Strategy
In our reply to the European Commission, we highlighted the importance of ensuring that Smart Sector Integration Actions actually contribute to emissions reductions. As Smart Sector Integration, particularly in sectors such as energy intensive industries, only result in climate change mitigation under certain conditions, other direct climate change mititgation efforts are necessary in parallel to the proposed strategy.

To ensure that smart sector integration actions actually contribute to emissions reductions, Bellona Europa recommend the European Commission to take use of the below screening criteria, in addition to the development of a robust GHG methodology for measuring its impact. Full details of respective metrics provided in full reply, here.

Bellona Europa Recommended screening criteria for climate evaluation of Smart Sector Integration Actions:

  1. Evaluate efficiency of climate change mitigation per input of energy
  2. Evaluate the use of resources and do not discount “waste” carbon flows to the atmosphere
  3. Do not include emissions avoided elsewhere in the system into the calculation of GHG emission reductions
  4. Do not use data which does not reflect real-life and real-time emissions in the system

EU Hydrogen Strategy

Low- and zero-carbon fuels (hydrogen, ammonia, methane and other hydrocarbons) will be a valuable and scarce resource in the future, due to their high resource requirements. Set to explore how clean hydrogen can help reduce the EU economy’s carbon emissions in a cost-effective way, we welcome the Commission’s initiative to define a comprehensive EU Hydrogen Strategy. Given the high resource intensity of hydrogen, it is imperative that the environmental production criteria are robust, in line with emission reduction targets and in place prior to the technology’s large-scale deployment.

Bellona Europa therefore issued several recommendations in its full reply including on matters of hydrogen production, hydrogen use and hydrogen infrastructure. The full list of recommendations can be found here.