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AUGUST
Ref. Ares(2020)6967261 - 20/11/2020
2020
IOGP Initial Feedback to the Taxonomy: 
Final report of the Technical Expert 
Group on Sustainable Finance
a) TEG Report (short paper – here)
Topic/section
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Comment
Rationale
Supporting documents
Sectors covered by the 
13
We recognise the challenges imposed by the ambitious timeline 
The energy transition will require enabling policies, significant 
Taxonomy
to deliver the detailed TEG report and we welcome the progress 
investments and behavioural changes across the economy.
made so far. However, we believe that each sector must 
contribute to the energy transition and therefore we encourage 
further efforts to be made to cover a wide(r) range of activities.
Types of economic 
14
The adopted EU Taxonomy Regulation introduced an additional, new 
The Taxonomy Regulation agreed by the Council and the Parliament 
Taxonomy Regulation 2018/0178 
activity that 
category of “transitional activities” which is considered to contribute 
clearly sets 3 different categories of activities that substantially 
(COD) – Final Compromise Text
substantially contribute
substantially to climate change mitigation by phasing out greenhouse 
contribute to climate change mitigation: 1) activities that directly 
gas emissions, in particular from solid fossil fuels (article 6.1.a). 
contribute to climate change mitigation, 2) transition activities and 
The addition of transitional activities is supported by the industry 
3) enabling activities. However, TEG’s proposed technical screening 
as enormous potential exists in the market for the transformation 
criteria do not sufficiently consider item 2) transitional activities.
of existing carbon-intensive industries and processes.
Given this development, we believe that a separate, additional 
list of transitional activities (including retrofit options) with its 
own specific Technical Screening Criteria (TSC) reflecting its 
transitional nature, should be created in the delegated acts 
(instead of having these activities as a subcategory of “green 
activities” as outlined in the TEG report).
Establishing such a list will add clarity to the framework and will 
help the EU to deliver its climate and energy objectives while 
providing a wide range of opportunities for the energy transitions 
across Europe. The policy focus should include feasible, near-term 
steps that act as building blocks and timely reduce emissions 
to deliver the Paris Agreement and the EU’s long-term climate 
targets. There is no silver bullet to combat climate change. All 
technologies reducing GHG emissions in all economic activities 
will need to be considered to deliver on the Green Deal ambition, 
and will be necessary for this energy transition.
1

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Supporting documents
Life-cycle 
16
‘Greening by’ and ‘greening of’ activities should be based on 
Having a simple indicator such as % reduction in GHG emissions per 
(1) HERE (2) HERE
considerations
a Life Cycle Analysis to create a level playing field among all 
unit (e.g. kWh or tonne of product produced) or considering the total 
technologies and assess their total impact on climate.
CO2 reduction is the most suitable metric. Overall, to achieve a long-run 
We believe a lifecycle requirement should be technology neutral. 
transition to a climate-neutral economy, there is a need for the wider 
In order to ensure an operational taxonomy, it is important that 
greening of markets and other incentives to promote innovation (2).
any LCE or LCA methodology has a clearly defined scope and 
is aligned with EU policies both in terms of design and time of 
introduction.
Thresholds
The entire 
The threshold level should be technology-neutral and be based 
Technical screening criteria should reflect a gradual approach and 
doc
on GHG emission to be achieved and not technology types. It 
efficiently incentivise transitional efforts. Setting thresholds and ceilings 
should allow all energy types that meet the threshold to be 
too low at the beginning could de facto exclude relevant activities 
accepted. 
regardless of both their potential contribution to the transition and their 
The first step in the 5 yearly threshold reduction cycle is an 
ability to improve their own environmental performance, running the 
independent review of power generation and power systems/
risk of unintentionally creating a niche market. Therefore, the threshold 
grid technologies to set guidance on the capabilities of existing 
level should be technology-neutral and based on GHG emission 
technologies with the aim to set the reduced threshold and still 
reductions on life-cycle analysis to be achieved, and not on technology. 
allow for stable power supplies to all.
In our view, the single threshold proposed by the TEG is not appropriate 
for the transitional activities. We, therefore, encourage the Commission 
to determine a methodology for establishing dedicated thresholds for 
these activities. For example, the transitional activity threshold should 
be aligned with existing legislation such as the Electricity Regulation. 
Such an alignment will ensure a trajectory for meeting the targets and 
ensure inclusion of activities that contribute to emission reduction 
including retrofitting of existing processes. The threshold can be 
reduced with time but should not be set too low too early as otherwise 
suitable technology, that can contribute to the transition or could be 
retrofitted, will be excluded already at this stage.
The threshold is proposed to reduce to 0g CO2e / kWh by 2050. With 
current technologies, in order to provide stable electricity grids, there is 
the need to have a range of different power generation sources feeding 
into the grid. Renewables are critical for the supply of electricity, but 
there is a need for other power generation sources to be operational 
to address the times when renewable sources are unavailable due to, 
e.g. lack of wind or darkness. Care needs to be taken that the Taxonomy 
and the proposed 5 yearly threshold reductions process takes account 
of power generation technology developments and any challenges 
toCO2e g / kWh reductions. There is a need to ensure that there is a 
stable electricity grid from a variety of power generation sources – if 
the technology faces a hurdle and can’t meet the threshold for a certain 
period of time, decisions on allowing for this in the Taxonomy need to 
be taken to prevent there being a potentially unstable and/or unreliable 
power supply.
2

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Supporting documents
Minimum safeguards
17
The European Parliament and the Council established that for an 
The TEG report refers to the risk-based approach to due diligence as 
economic activity to be Taxonomy-aligned, the activity should be 
promulgated by the OECD Guidelines and Due Diligence Guidance 
carried out “in alignment with the OECD Guidelines for Multinational 
for Responsible Business Conduct. However, there is no overarching 
Enterprises and UN Guiding Principles on Business and Human 
recognition in the report that the means through which a business 
Rights, including the International Labour Organisation’s (‘ILO’) 
enterprise meets its responsibility to respect human rights is 
declaration on Fundamental Rights and Principles at Work, the eight 
proportional to factors like size amongst others (as provided in UNGP, 
ILO core conventions and the International Bill of Human Rights”. 
commentary to GP 14). In addition to this recognition, a statement which 
Where applicable, more stringent requirements in EU law still apply. 
notes that there is no “one-size fits-all” approach in aligning with these 
Section 2.1.5 of the TEG report aims to provide understanding 
Guidelines and Principles is important as it underscores the practical 
of these standards’ frameworks and how to apply them in the 
reality of implementation. This statement would not take away from the 
context of the Taxonomy. There are a few additional elements that  importance of aligning but would show that the TEG recognises that the 
we believe should be considered in this context (see rationale).
way of alignment may differ depending on a variety of factors.
International use of the 
18
The EU Taxonomy should recognise that other regions and 
For example, the Report of the Expert Panel on sustainable finance 
HERE
EU Taxonomy
jurisdictions may have different drivers and boundary conditions 
“Mobilizing Finance for Sustainable Growth” outlines recommendations 
and, therefore, the proposed EU requirements may not be 
for Canada.
applicable as such globally.
The Taxonomy should aim for international coordination, in this 
context, we recommend that the EU continue its efforts at the 
global level.
Definition of lock-in/
20
The EU Taxonomy should be inclusive and allow all sectors 
The Taxonomy Regulation only excludes solid fossil fuels. The Taxonomy 
carbon lock-in
and technologies/activities that can contribute to the energy 
screening criteria should be consistent with this Regulation and not go 
transition to be part of the solution. To meet EU targets it will 
beyond.
be necessary for all economic sectors to lower their carbon 
emissions. Therefore, all sectors should have the ability to be 
recognised for decarbonisation efforts within the scope of the 
Taxonomy.
Fossil fuels 
20
Natural gas should be recognised for the enabling and transition 
Switching from coal to gas can be done easily contributing to deliver 
HERE
role that it can play alongside renewables in the energy 
immediate CO2 emissions reduction (up to 50%) and to improved air 
European Commission, Electricity 
transition.
quality by reducing emissions of NOx, SOx and particulate matters. 
Market Report here
The challenges that certain regions face to decarbonise and 
In the long-term natural gas can decarbonise (e.g. with CCS, via 
switch to low carbon solutions should be acknowledged and 
hydrogen).
addressed. Investment in transitional activities that can become 
In 2019, the EU electricity sector decreased its GHG emissions by 
low carbon in the long-term should be encouraged in these 
approx. 12% thanks to higher renewables generation and coal-to-
regions.
gas switching, bringing about a substantial contribution to Europe's 
decarbonisation efforts.
Disclosure
26-27
It is of utmost importance that the Taxonomy is operational and 
easy-to-use by those for whom disclosure is required.
3

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Comment
Rationale
Supporting documents
Financial metrics
28
% of turnover and capex/opex of taxonomy eligible activities is 
Rationale (calculation): The calculation of these metrics requires 
likely to take time to set it up
tagging (and maintenance of the tagging over time) of companies’ 
economic activities against the taxonomy. This is a highly complex task 
which represents a significant practical constraint for many companies. 
The fact that the Taxonomy remains a “live” list of activities that will 
continue to change is particularly challenging. To accurately capture 
financial transactions and records in line with the tagging would require 
a complex business/system solution (which does not exist yet in the 
market) on top of companies’ core financial transaction processing and 
reporting systems. These challenges should be carefully weighed in 
terms of implementation timeline. 
Rationale (comparability): Turnover may be meaningful for certain sectors 
but not for other sectors. Similarly, certain sectors are inherently more 
capital intensive than others (e.g. manufacturer vs retailer). Further, some 
companies are multi-sectorals, but others are not. These differences 
render these metrics inherently unrepresentative and incomparable 
across the different economic players therefore undermining their 
utility as decision-useful criteria for the investment community. 
Due diligence
32
EU legislation on due diligence could have adverse economic 
The state’s duty to protect and fulfill human rights includes the duty to 
implications and may also deter broader stakeholder 
enforce legislation.
engagements done as part of businesses voluntarily adhering 
With globalisation, the management of supply chains has become very 
to the UN Guiding Principles on Business and Human Rights 
complex and involves a broad range of suppliers and sub-contractors, 
(UNGPs).
comprising multiple tiers with hundreds or thousands of locations 
and individuals. While offering expanded sourcing opportunities for 
companies, it also brings challenges in identifying and managing 
possible adverse environmental or social impacts caused at different 
stages of the supply chain.
In order to manage these risks, companies generally refer to 
international guidelines like the OECD Guidelines for Multinational 
Enterprises or the UN Guiding Principles on Business and Human 
Rights (UNGPs). These texts set out clear recommendations as to how 
businesses are expected to address possible negative impacts of their 
activities through the supply chain.
The concept of due diligence is highly complex and requires the 
collaboration of many stakeholders, within but also outside companies: 
suppliers, sub-contractors, clients, investors, States, local authorities 
and communities, NGOs, consumers:
a)   Companies alone cannot be expected to solve all the problems 
arising from failing states or weakly governed states in which 
protective laws, guaranteeing human rights or the protection of 
the environment, are either inexistent or not applied.
b)   It would be unfair to hold only European companies liable for 
damages occurring through global supply chains when it is 
impossible to fully control every single part of the chain and many 
other actors in third countries are involved.
4

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Brown taxonomy
51
The principle of technology neutrality should be the basis of the 
We recognise the EU Taxonomy Regulation contains a review clause 
HERE
EU Taxonomy.
to assess activities with negative impact. However, the EU Taxonomy 
should adopt an inclusive approach that considers that all different 
technologies/activities and sectors can contribute to the energy 
transition and can be part of the solution.
This inclusive approach is showcased in the Canadian Report of the 
Expert Panel on sustainable finance “Mobilizing Finance for Sustainable 
Growth”. The document outlines opportunities to develop and scale up 
market structures and financial products that would have particular 
impact in facilitating Canada’s transition and adaptation. For example 
how governments at every level should support the oil & gas industry to 
transition to deliver low-emission solutions. As our industry underpins 
the whole economy while providing solutions to mitigate climate 
change, it is very important to include our sector in the EU Taxonomy.
b) Technical Annex (here)
Topic/section
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Supporting documents 
Screening criteria climate change mitigation 
Manufacture of Iron and  176-179
We note a reference to a specific form of hydrogen on page 177 
We propose to recognise all forms of clean hydrogen in the 
The future of Hydrogen, IEA, June 
Steel
(subsection: Rationale): hydrogen steelmaking in shaft furnaces 
manufacturing of products as these thresholds are further developed.
2019
using H2 produced via water electrolysis (e.g. using renewable 
SINTEF: 
electricity sources).
a) The pre-study Executive Summary 
We propose to replace the aforementioned text with:  
hydrogen steelmaking in shaft furnaces using clean H2 produced via 
b)  The full pre-study report can be 
water electrolysis (e.g. using renewable electricity sources).
accessed here 
IEAGHG Techno-Economic 
Evaluation of SMR Based 
Standalone Hydrogen Plant with 
CCS 
Zero Emission Platform (2017): 
Commercial Scale Feasibility of 
Clean Hydrogen here
See relevant studies performed by 
Navigant (Gas for Climate) here
Poyry (Fully decarbonising Europe’s 
energy system by 2050) report on 
decarbonisation here
Frontier economics (the future 
value of gas infrastructure in a 
climate-neutral Europe) here
5

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CCS and CCU (section 
157
We agree CCS is a key technology to reach the EU carbon 
The IEA, IPCC Report and EC Pathways show that CCS is essential 
The IEA, IPCC Report, European 
on manufacturing) 
neutrality objective by 2050.
to meet the targets set by the Paris Agreement and the EU. CCS will 
Commission “Clean Planet for All”
It is important that there is the ability for CCU to qualify, if the 
be a necessary part of the decarbonisation of industry, representing 
Zero Emissions Platform (2017): 
emission mitigation benefit can be demonstrated. There is a 
one of the most cost-effective way to reduce post-combustion and 
Climate solutions for EU industry – 
need to define what “substantial mitigation” means so that any 
process-related emissions. Gas-fired power plants (and CHP plants) 
Interaction between electrification, 
demonstrations of this can be performed on a fair basis.
with CCS can help ensure grid resilience as renewable generation 
CO2 use and CO2 storage here
grows, supporting decarbonised energy system flexibility. Techniques 
to capture CO2 released by industrial processes can be converted into 
IOGP (2019): The Potential for CCS 
valuable applications (e.g. construction materials, raw materials for 
and CCU in Europe – Report to 
the chemical industry, etc.). This way CCU can contribute to a circular 
the thirty second meeting of the 
economy subject to a lifecycle analysis and clear carbon accounting 
European Gas Regulatory Forum 
rules.
5-6 June 2019 here
Article 33 of CCS Directive (EU 
Directive 2009/31/EC) states 
that it must be economically and 
technically possible to retrofit all 
new combustion plants for CO2 
capture.
Hydrogen 
180-182
We support the classification of manufacturing of hydrogen as an 
Hydrogen from natural gas with CCS has the potential to provide 
The future of Hydrogen, IEA, June 
manufacturing 
environmentally sustainable activity.
significant volumes of near zero-carbon energy to the EU. With 
2019
We also request that all forms of clean hydrogen are recognised 
technical adaptation, hydrogen can be transported in existing EU gas 
SINTEF: 
in the manufacturing of products as these thresholds are further 
infrastructure, thereby using current gas infrastructure in a cost-
a) The pre-study Executive Summary 
developed.
effective way and avoiding the need to duplicate transmission. For this 
reason, we also encourage the Commission to incorporate a section on 
b)  The full pre-study report can be 
For the clarification purposes, we propose to combine two metrics  transportation of hydrogen.
accessed here 
(Electricity use for hydrogen produced by electrolysis is at or 
lower than 58 MWh/t Hydrogen) and (Average carbon intensity of 
IEAGHG Techno-Economic 
the electricity produced that is used for hydrogen manufacturing 
Evaluation of SMR Based 
is at or below 100 gCO2e/kWh) in the following way:
Standalone Hydrogen Plant with 
CCS 
“Electricity use for hydrogen produced by electrolysis is at or 
lower than 58 MWh/t Hydrogen and Average carbon intensity of 
Zero Emission Platform (2017): 
the electricity produced that is used for hydrogen manufacturing 
Commercial Scale Feasibility of 
is at or below 100 gCO2e/kWh (Taxonomy threshold for electricity 
Clean Hydrogen here
production, subject to periodical update)”
Our understanding is that the last threshold (100 gCO2e/kWh) is 
See relevant studies performed by 
intended for electrolysis only.
Navigant (Gas for Climate) here
We also encourage the Commission to add a section on 
Poyry (Fully decarbonising Europe’s 
transportation of hydrogen to link to the manufacture of 
energy system by 2050) report on 
hydrogen and storage of hydrogen.
decarbonisation here
Frontier economics (the future 
value of gas infrastructure in a 
climate-neutral Europe) here
6

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Electricity, gas, steam, 
205-211
The threshold level should be technology-neutral and based 
We believe a lifecycle requirement should be technology neutral. 
Our slides on natural gas
and air conditioning 
on GHG emission reductions to be achieved and not technology 
In order to ensure an operational taxonomy, it is important that any 
supply
types. It should allow all energy types that meet the threshold to 
lifecycle methodology has a clearly defined scope and is aligned with EU 
be accepted.
policies both in terms of design and time of introduction.
Technical screening criteria should reflect a gradual approach 
Regarding methane emissions measurement, the EC is currently 
and efficiently incentivise transitional efforts. Setting thresholds 
developing an EU strategy to regulate and reduce methane emissions. 
and ceilings too low at the beginning could de facto exclude 
The Taxonomy must be aligned with EU regulation and should look into 
relevant activities regardless of both their potential contribution 
harmonising standards rather than developing diverging ones. This will 
to the transition and their ability to improve their own 
facilitate implementation and comparison of activities across various 
environmental performance, running the risk of unintentionally 
policy frameworks.
creating a niche market. Therefore, the threshold level should be 
technology-neutral and based on GHG emission reductions on 
life-cycle analysis to be achieved, and not on technology. In our 
view, the single threshold proposed by the TEG is not appropriate 
for the transitional activities. We, therefore, encourage the 
Commission to determine a methodology for establishing 
dedicated thresholds for these activities. For example, the 
transitional activity threshold should be aligned with existing 
legislation such as the Electricity Regulation. Such an alignment 
will ensure a trajectory for meeting the targets and ensure 
inclusion of activities that contribute to emission reduction 
including retrofitting of existing processes. The threshold can 
be reduced with time but should not be set too low too early 
as otherwise suitable technology, that can contribute to the 
transition or could be retrofitted, will be excluded already at this 
stage.
Furthermore, future taxonomy should take into account EU 
regulations on methane emissions.
Waste to Energy - 
209
“The TEG has not included WtE, but recommends bringing this 
Not all residual waste can be reused or recycled (as acknowledged by 
EC Communication (2017)34 on 
Electricity, gas, steam, 
matter for further discussion and consideration to the Platform 
the EC in its Communication COM(2017)34 on ‘the role of waste-to-
The role of waste-to-energy in the 
and air conditioning 
on Sustainable Finance, in light of the changes in the political 
energy in the circular economy.
circular economy
supply 
agreement text”
The final text of the EU Taxonomy Regulation agreed by the European 
Taxonomy Regulation 2018/0178 
However, following the Taxonomy Regulation, waste incineration 
Parliament and Council stipulates that the incineration of waste is not 
(COD) – Final Compromise Text
of non-recyclable hazardous waste with energy recovery should 
considered an eligible activity, with the exception of the incineration of 
be considered a sustainable activity offering a substantial 
non-recyclable hazardous waste, Article 12(d).
contribution to climate mitigation.
The technical screening criteria need to reflect this exception that 
was added by the co-legislators to the European Commission’s initial 
proposal.
7

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Production of Electricity 
231-233
The threshold level should be technology-neutral and be based 
We understand that if power generation has CCS (geological storage) 
Our slides on natural gas
from Gas
on GHG emission to be achieved and not technology types. It 
facilities, it is eligible under taxonomy. We welcome this approach.
should allow all energy types that meet the threshold to be 
We also support the fact that if the power generation is from H2 fired 
accepted.
power plant, the H2 must come from any clean hydrogen (produced 
Technical screening criteria should reflect a gradual approach 
from reforming natural gas, pyrolysis or electrolysers).
and efficiently incentivise transitional efforts. Setting thresholds 
and ceilings too low at the beginning could de facto exclude 
relevant activities regardless of both their potential contribution 
to the transition and their ability to improve their own 
environmental performance, running the risk of unintentionally 
creating a niche market. Therefore, the threshold level should be 
technology-neutral and based on GHG emission reductions on 
life-cycle analysis to be achieved, and not on technology. In our 
view, the single threshold proposed by the TEG is not appropriate 
for the transitional activities. We, therefore, encourage the 
Commission to determine a methodology for establishing 
dedicated thresholds for these activities. For example, the 
transitional activity threshold should be aligned with existing 
legislation such as the Electricity Regulation. Such an alignment 
will ensure a trajectory for meeting the targets and ensure 
inclusion of activities that contribute to emission reduction 
including retrofitting of existing processes. The threshold can 
be reduced with time but should not be set too low too early 
as otherwise suitable technology, that can contribute to the 
transition or could be retrofitted, will be excluded already at this 
stage.
Production of Electricity 
234 - 237
Propose to merge Section 4.7 – Production of Electricity from Gas  The TEG proposal does not make it clear whether biomethane is 
from Bioenergy 
(not exclusive to natural gas), with Section 4.8 – Production of 
included under the “biogas” category, and whether “biogas” should 
(biomass, biogas, 
Electricity from Bioenergy (Biomass, Biogas and Biofuels)
be considered as ‘other natural gas’ under section 4.7 Production of 
biofuel)
Electricity from Gas.
The TEG proposal leaves ambiguity between these categories 
and proposes different thresholds for them. Product blends such 
as biomethane and natural gas, which provide decarbonisation 
opportunities, are potentially excluded depending on which criteria 
apply (4.7 or 4.8)
Storage of Hydrogen
247-248
We support this section.
8

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Manufacture of 
249-251
TEG’s restrictions are not aligned with the EU existing 
Under RED II, any biofuel meeting the sustainability criteria is eligible, 
biomass, biogas or 
legislation: all types of biofuels meeting the carbon intensity 
not only biofuels made from feedstock listed in Annex IX, Part A. TEG’s 
biofuel
and sustainability criteria will be needed to help decarbonize 
criteria would remarkably narrow the raw material base for replacing 
transport sector to 2030 and be further needed in the long term 
conventional fuels.
for aviation, marine and heavy duty.
Therefore, we are calling on the Commission to ensure alignment 
between different pieces of EU legislation. Otherwise, we are 
limiting the impact of RED and making it more difficult to finance the 
investments required.
Retrofit of Gas 
252-254
The boundaries of the activity should be extended to cover 
The existing gas transmission and distribution networks support the 
Transmission and 
the construction and operation of networks for gaseous fuels, 
integration of renewable energy both in electric form and gaseous 
Distribution Networks
mirroring the provisions for electricity transmission and 
form (biomethane, hydrogen, synthetic methane) into the energy 
distribution lines.
system. They also support significant GHG emissions reductions 
from fuel switching or merit order optimisation in industry, power 
generation, heating, and transport. The transition from natural gas to 
renewable and decarbonized gas relies on the possibility to connect 
production units to the grid and final customers. Renewable gas can 
be carbon neutral and even negative as outlined in Annex VI of REDII. 
Gas transmission and distribution are regulated businesses falling in 
the scope of the Directive 2009/73/EC that has introduced rules aimed 
at creating not only a competitive secured but also environmentally 
sustainable market, in line in particular with the EU climate objectives. 
The foreseen gas market reform currently prepared by the Commission 
should define its contribution to the 2030 energy and climate objectives 
and make them future-proof so they can bring their full contribution 
to reach climate neutrality in 2050. The TEN-E regulation and the EU 
support to the Projects of Common Interest (PCI) has fostered a high 
level of security of supply and integration of the European energy 
market. Only a few major PCI projects still need to be implemented. 
In the context of the energy transition, the pressing need to ensure 
optimal use of existing gas infrastructure (to avoid the risk of stranded 
assets and technological lock-in) implies thorough Cost Benefits 
analysis taking all externalities into account before making any decision 
on a major gas project such as an interconnection between member 
states. Moving forward the next revision of the TEN-E regulation 
should support the projects facilitating the integration of renewable 
and low-carbon gases (including hydrogen). Setting as a priority the 
decarbonisation of existing gas networks would contribute to the EU 
energy transition objectives in a smart and cost-efficient way. This 
would also ensure that upcoming investments are futureproofed, when 
it comes to environmental impacts in particular.
9

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District Heating / 
255-257
Metric and thresholds state: “Construction and operation of 
The EED defines efficient district heating and cooling as a “district 
H21 North England website
Cooling Distribution
pipelines and associated infrastructure for distributing heating 
heating or cooling system using at least 50% renewable energy, 50% 
and cooling is eligible, if the system meets the definition of 
waste heat, 75% cogenerated heat or 50% of a combination of such 
efficient district heat/cool systems in the EU Energy Efficiency 
energy and heat”.
Directive”
Operating such infrastructure with e.g. 100 % blue hydrogen (ref. e.g. 
However, this threshold would effectively exclude some sources 
H21 North of England) would then not be eligible – despite being able to 
that could deliver heating and cooling with far lower GHG 
deliver H&C with a far lower carbon footprint than the definitions above. 
emissions.
This is probably not the intention and it seems not to be consistent with 
the other principles and framework of the TEG report.
Cogeneration of Heat/
266-268
Technical screening criteria should reflect a gradual approach 
We understand that if power generation has CCS (geological storage) 
Cool and Power from 
and efficiently incentivise transitional efforts. Setting thresholds 
facilities, it is eligible under taxonomy. We welcome this approach.
Gas
and ceilings too low at the beginning could de facto exclude 
We also support the fact that if the power generation is from H2 fired 
relevant activities regardless of both their potential contribution 
power plant, the H2 must come from a blue H2 source, or green H2.
to the transition and their ability to improve their own 
environmental performance, running the risk of unintentionally 
creating a niche market. Therefore, the threshold level should be 
technology-neutral and based on GHG emission reductions on 
life-cycle analysis to be achieved, and not on technology. In our 
view, the single threshold proposed by the TEG is not appropriate 
for the transitional activities. We, therefore, encourage the 
Commission to determine a methodology for establishing 
dedicated thresholds for these activities. For example, the 
transitional activity threshold should be aligned with existing 
legislation such as the Electricity Regulation. Such an alignment 
will ensure a trajectory for meeting the targets and ensure 
inclusion of activities that contribute to emission reduction 
including retrofitting of existing processes. The threshold can 
be reduced with time but should not be set too low too early 
as otherwise suitable technology, that can contribute to the 
transition or could be retrofitted, will be excluded already at this 
stage.
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Production of Heat/Cool  278-280
Technical screening criteria should reflect a gradual approach 
We understand that if power generation has CCS (geological storage) 
from Gas Combustion
and efficiently incentivise transitional efforts. Setting thresholds 
facilities, it is eligible under taxonomy. We welcome this approach.
and ceilings too low at the beginning could de facto exclude 
We also support the fact that if the power generation is from H2 fired 
relevant activities regardless of both their potential contribution 
power plant, the H2 must come from a blue H2 source, or green H2.
to the transition and their ability to improve their own 
environmental performance, running the risk of unintentionally 
creating a niche market. Therefore, the threshold level should be 
technology-neutral and based on GHG emission reductions on 
life-cycle analysis to be achieved, and not on technology. In our 
view, the single threshold proposed by the TEG is not appropriate 
for the transitional activities. We, therefore, encourage the 
Commission to determine a methodology for establishing 
dedicated thresholds for these activities. For example, the 
transitional activity threshold should be aligned with existing 
legislation such as the Electricity Regulation. Such an alignment 
will ensure a trajectory for meeting the targets and ensure 
inclusion of activities that contribute to emission reduction 
including retrofitting of existing processes. The threshold can 
be reduced with time but should not be set too low too early 
as otherwise suitable technology, that can contribute to the 
transition or could be retrofitted, will be excluded already at this 
stage.
CCS (section on water, 
289-291
We agree CCS is a key technology to reach the EU carbon 
We understand that if power generation has CCS (geological storage) 
sewerage, waste, 
neutrality objective by 2050.
facilities, it is eligible under taxonomy. We welcome this approach.
remediation)
We also support the fact that if the power generation is from H2 fired 
power plant, the H2 must come from a blue H2 source, or green H2.
Direct Air Capture of 
311-312
We support this section.
CCS is critical to achieving negative emissions when applied to 
CO2
bioenergy, which is viewed by the IPCC as crucial to achieving the 1.5 °C 
objective under the Paris Agreement.
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Capture of 
313-315
We support this section. CCS with power generation is key. 
The ISO/CD 27919-2 refers to integration in a power station and should 
Anthropogenic 
Delivery of CO2 transportation and storage networks is key to 
be removed where it is not relevant. Capturing of CO2 is relevant for a 
Emissions
meet the emissions reduction targets.
number of activities and is not limited to power stations. There is not an 
However, an ISO standard linked to carbon capture for power 
ISO standard for carbon capture in general.
generation is proposed as metric for several activities for which it 
The addition to this last TEG report of “ISO/TR 27912 - Carbon dioxide 
is not relevant: ISO/CD 27919-2 - Carbon dioxide capture – Part 2:  capture – Carbon dioxide capture systems, technologies and processes” 
Evaluation procedure to assure and maintain stable performance 
is an improvement and a better standard for carbon capture, but should 
of past-combustion CO2 capture plant.
replace the ISO/CD 27919-2 and not add to it.
We agree with the observation that the efficiency of power 
We would like to draw the Commission’s attention to the fact that 
generation plants and capture plants is increasing and will 
there is ongoing work by equipment manufacturers, universities and 
continue to be a focus of many suppliers.
others, with aim of improving both power plant efficiencies and capture 
plant efficiencies. Put together, be it via the Allam cycle or combined 
cycle technology, this work is chipping away at the energy efficiency 
challenge. Therefore, it is suggested that the TEG note that enhanced 
efficiencies in power generation with carbon capture facilities are being 
delivered through various lines of technology development, and are 
not limited to the work of a single supplier/technology developer. The 
energy intensity of carbon capture is being reduced.
Transport of CO2
316-318
We support this section, in particular that all modes of CO2 
Under the TEG proposal, it could be understood that only transport 
transportation are recognised, and we request that any 
modalities which lead directly to an eligible permanent sequestration 
combination of transportation modes is eligible as long as they 
site are eligible. The threshold needs to include for instance ship-
meet the leakage requirements and arrive at a permanent 
to-ship or ship-to-well, as future options which are currently being 
sequestration site.
developed in Europe.
As drafted, there is ambiguity under Metric and Threshold 
The 0.5% CO2 leakage rate threshold for the transport of CO2 by ship 
section:
might pose a challenge to enabling large scale shipping of CO2. The 
“Transport modalities that contribute to the transport of CO2 
performance threshold might mean that there is a need for more 
to eligible permanent sequestration sites are eligible, only if the 
complex ship-bourne systems to be developed and deployed, which 
asset operates below the leakage/tonne of CO2 threshold.”
might result in a possible delay or limitation to the deployment of large 
scale shipping of CO2 from industrial clusters as part of the CCS chain 
We also propose to remove the following statement under 
to reduce emissions in Europe. This area is being investigated and a 
“metric & threshold”: Assets or activities that enable carbon 
better understanding is anticipated later in 2020. We would welcome the 
capture and use (CCU) will deem all the connected elements of an 
opportunity to share findings with the Platform when available.
existing transport network ineligible.
We believe the Commission should include the role of CCU into the 
delegated acts to be published by the end of 2020.
Not including CCU now may, through limiting/stopping access to 
financing, slow down technical development of CCU which could provide 
valuable means to meet the net zero target. Perhaps more importantly, 
it may also prevent the development of the rest of the associated CO2 
transport and storage network which may send most of the CO2 to 
geological storage.
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Permanent 
319-320
We support this section. We support the reference to ISO 27914:2017.
It is important that the periodical review is performed, and the revision 
GCCSI’s Global Status of CCS 
Sequestration of 
However, we believe the following statement under DNSH 
of the ISO 27914 that is applicable is updated so that learning from 
report
Captured CO2
assessment should be modified:
storage activities is accounted for in this.
•  the long-term lack of geological containment of the reservoirs, 
CO2 storage in saline aquifers is a mature technology which is in 
central issues regarding the monitoring and the interrelation of 
operation worldwide at >5 large-scale CCS projects
carbon with physical, chemical and geological conditions in the 
CCS is a proven technology. There are 19 large-scale CCS facilities in 
reservoir is still a debated argument (change for → discussed 
operation globally.
however the safety of CO2 storage may be assured with the 
implementation of specific rules and requirements.
(similar language exists in the section on climate change 
adaptation, therefore, similar change should be made )
Transport
321-358
Transport of low carbon and blended fuels should be eligible, 
The transition to zero-emission mobility will take time and during the 
Several studies showing that there 
especially if meeting the criteria mentioned in the report.
transition, the use of blends will be critical to delivering the GHG 
are different pathways / solutions 
The threshold level should be technology-neutral and be based 
reduction ambitions. Therefore, freight rail transport that transports 
to decarbonize maritime transport
on GHG emission to be achieved and not technology types. It 
blends of fossil and sustainable fuels should be eligible. The TEG 
DNV-GL (2018). Energy Transition 
should allow all energy types that meet the threshold to be 
report’s restriction to narrow sustainable raw materials only to those 
Outlook report. Main Report.  
accepted. The threshold can be reduced with time but should not 
listed in Part A of Annex IX (in RED II), would differ significantly from the 
www.Dnvgl.com
be set too low too early or suitable technology that can contribute 
sustainability definitions in the RED II. Under RED II, any biofuel meeting  DNV-GL (2018). Energy Transition 
to the transition will be excluded.
the sustainability criteria are sustainable, not only biofuels made from 
feedstock listed in Annex IX, Part A. Moreover, when compared with the 
Outlook report. MARITIME — 
Establishing only thresholds on tank-to-wheel (tailpipe) values is 
RED II, the criteria would remarkably narrow the raw material base for 
FORECAST TO 2050.  
inappropriate as it does not take into account the GHG emissions 
replacing conventional fuels. This cannot be considered acceptable, 
www.Dnvgl.com
associated with the production of the fuel or the vehicles and so 
especially when taking into account the need for rapid and significant 
https://www.lr.org/en/insights/
it will give an inaccurate picture of the true GHG performance 
emission reductions in the transport sector (including aviation and 
global-marine-trends-2030/
of each drive train (energy and vehicle) Therefore, tailpipe 
maritime). All sustainably produced raw materials as allowed by RED II, 
zero-emission-vessels-transition-
values should at least be replaced by an LCA/WTW metric. The 
incl. waste and residue materials are therefore needed.
pathways/ 
thresholds to be used should be consistent with those defined in 
the Clean Vehicle Directive as this already sets out the definition 
The Communication ‘Clean Planet for All’ shows that within the NZE 
According to the IEA WEO 2019 and 
of a clean vehicle for LDV and HDV.
scenarios, biofuels and synthetic fuels (liquid and gas) will be needed 
the Commission’s ‘Clean Planet 
in those sectors that will continue to need high-density energy. Until 
for All’, liquid fuels will still be 
Section 6.3 Public transport: Through the introduction of a 
there is sufficient volume to use 100% drop-in biofuels and synfuels 
needed in 2050, at least for the 
uniform threshold (50gCO2/km), a number of investments 
there will be a continued need to use these as blends. Therefore, the 
sectors where there are currently 
delivering emission reductions in public transport will be 
Taxonomy definitions should not preclude infrastructure dedicated 
no alternatives. According to the 
excluded.
to the transport and use of blends. In the context of the transitional 
IPCC Special Report on the impacts 
Section 6.5 Passenger cars and commercial vehicles: We should 
activities, the following ones should be taken into account:
of global warming of 1.5°C, titled 
keep consistency across the legislation. If not then FCEV and 
•  Natural gas and Europe’s natural gas infrastructure play a decisive 
‘Mitigation Pathways Compatible 
BEVs should also only qualify when their production emissions 
role in climate mitigation. Europe can only benefit from natural gas 
with 1.5°C in the Context of 
are below a certain threshold as some battery technology is more 
if it has a functioning, safe and efficient gas infrastructure. To reach 
Sustainable Development’ - in 
carbon intensive than others.
the European Union’s climate targets gas technologies, including the 
the 1.5 scenarios, fossil share 
infrastructure, must be considered as sustainable technologies. It is 
of primary energy in 2050 is 
widely agreed upon that in Europe the most efficient way to reduce 
approximate ~33%. (Chapter 2, 
CO2 emissions significantly is to replace coal with gas. When natural 
page 133). 
gas replaces coal, 15 percent of total GHG emissions can be saved 
throughout Europe – in the electricity sector even 40 percent. This 
positive contribution must be taken into account accordingly.
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• Furthermore, natural gas together with its infrastructure is central to gas in 
mobility applications. Compressed natural gas (CNG) can contribute to a low 
carbon economy, as it is currently the most cost-effective way to significantly 
reduce road traffic emissions. Gas-powered vehicles save 20 to 30 percent 
CO2 compared to diesel or petrol and emit hardly any fine particles. Also, 
using LNG as fuel for trucks and ships can lower GHG emissions notably as 
well. The current climate targets can be reached only if natural gas 
and its infrastructure are fully utilized and understood as sustainable.
Eligible infrastructure should include biofuels, PtX synthetic fuels 
(produced from blue H2 and CO2) plants as these can produce very low 
carbon fuels that will be needed both in the transition as blends and 
eventually as final fuels in hard to decarbonize sectors such as aviation, 
marine, and heavy-duty road transport. It is not clear what is meant by 
excluding Infrastructure that is predominantly dedicated to the transport of 
fossil fuels (more than 50%). Many alternative fuelling locations could likely 
be co-located on retail sites and it is possible the proposed exclusion could 
preclude the development of these alternative fuel locations on retail sites.
The threshold can be reduced with time but should not be set too low too early 
or suitable technology that can contribute to the transition will be excluded. 
This is particularly true for heavy-duty transport where battery-electric 
and hydrogen driven trains are still at a development stage and costly. In 
the short to medium term, biofuels and biogas represent a cost-effective 
pathway to decarbonization of heavy-duty transport and therefore should be 
supported. Efficient ICE and gas vehicles that can use these fuels should also 
be supported. Freight transport dedicated to the transport of blended fuels 
should not be excluded as it will also contribute to the overall GHG emission 
reduction from freight transport. If it is excluded, then the transport of 
blended fuels could continue using higher emission freight transport.
The Taxonomy should not exclude barges that use blends during the transition 
to the use of 100% advanced biofuels or RFNBOs, as these vessels will be 
able to use the 100% advanced biofuels and RFNBO when they are available in 
sufficient quantities. As the average age of a barge is 20-30 years, this would 
allow investment in new barges now and this will have the added benefit 
of better efficiency and air quality benefits immediately. The production of 
biomass, biogas, and biofuels should not be reduced to only Annex IX A of the 
2018 /2001. The TEG report considers eligible only the production of advanced 
biofuels as per Art 2.34, RTFNBOs per Art. 2 (36) and certified low-ILUC risk 
biofuels, in line with the requirements of RED II. The approach in the TEG 
report would differ significantly from the sustainability definitions in the RED 
II. Under RED II, any biofuel meeting the sustainability criteria are eligible, 
not only biofuels made from feedstock listed in Annex IX, Part A. Moreover, 
when compared with the RED II, the criteria would remarkably narrow the 
raw material base for replacing conventional fuels. This cannot be considered 
acceptable, especially when taking into account the need for rapid emission 
reductions in the transport sector (including aviation and maritime). All raw 
materials as allowed by RED II, incl. waste and residue and recycled materials 
are therefore needed and recycle carbon fuels (RCF) should also be included.
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Information and 
359-367
We support the TEG’s recommendation for the Commission to 
Further to the examples listed, for transport, significant opportunities to 
communications
work on the criteria to support more software investments that 
improve emissions can be enabled by software innovations. We suggest 
will digitally enable GHG reduction.
to include further examples to illustrate this point:
Smart charging/vehicle-to-grid, telematics to inform better driving, 
locational services to enable autonomous/shared vehicles and more 
on-demand last mile solutions.
Even in the Sector on Forestry projects, issues relating to long term 
monitoring requirements over a vast geography can be enabled by 
digital solutions.
Forestry
40-102
We support and are encouraged by the inclusion of forestry as 
a sector given the significant potential such projects have to 
contribute to EU’s NZE ambitions, as outlined in the IPCC report.
For all categories of Forestry Projects, we agree that 
Additionality and Permanence will be important criteria to ensure 
environmental integrity of such projects. One comment on the 
baseline:
Criterion 2: Verified GHG Baseline (Additionality) for all categories 
of Forestry (e.g. pg.45) – it would be useful to create a list 
of approved verification bodies and standards that meet the 
required criteria to be made available to investors on public 
domain.
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