Dear Ebba Busch, Deputy Prime Minister and Energy Minister of Sweden
Dear Deputy Permanent Representatives

Dear Executive Vice-President Frans Timmermans
Dear Commissioner Kadri Simson

Dear Mr Markus Pieper MEP
Dear Mr Casares Gonzalez MEP
Dear Mr Christope Grudler MEP
Dear Mr Ville Niinistö MEP
Dear Ms Sira Rego MEP

Brussels, 23 March 2023

The fight against climate change is a race against the clock. We must pave the way for Europe to
scale up renewables at unprecedented speed. A rapid transition to a 100% renewables-based
energy system will make it possible to achieve our targets under the Paris Agreement and enable
the whole EU to reap the benefits of its own energy transition: local job creation in the renewable
energy value chain, lowering energy bills, reducing dependence on expensive and insecure fossil
fuel imports, and enabling citizens to actively participate in and directly benefit from the energy

We are writing to express our serious concerns regarding ongoing efforts1 to include so-called
‘low-carbon’ technologies into the centrepiece of the EU’s legal instruments to advance
renewables. ‘Low-carbon’ energy sources are framed as a solution but in fact, they are part of the
problem. They are expensive, rely on imports and infrastructure that is slow to build. As
non-renewable energy sources, they should not be included in any provision under the Renewable
Energy Directive (RED) nor should they count towards the EU’s binding 2030 renewable energy

Renewable energy and reduction of energy consumption are at the core of delivering the EU’s
ambition from the Green Deal, Fit-for-55, and REPowerEU initiatives. The EU’s RED has proven
effective in driving down the costs of renewable energy technologies and fostering investments in renewables assets across Europe. While a target of at least 45% renewables in the EU’s final
energy demand by 2030 must be defended at all costs in the current trilogue negotiations, the
focus of the RED must also remain entirely on the transition towards renewable, cost-competitive,
and domestic sources of energy that can be rapidly built.

Nuclear energy is expensive, unreliable and takes a very long time to build2. Due to its centralised
structure, it risks delaying the development of decentralised renewable energy systems, including
by diverting subsidies meant to support renewables, hence distorting both competition and the
power market(s).

Broadening the scope of the RED beyond renewables is counter-productive and risks promoting the
very fossil fuels that renewables should be displacing in Europe’s energy mix. Including
‘low-carbon’, non-renewable energy forms into the RED would not only undermine public trust in
the EU’s climate policies. It would also add uncertainty and delay much-needed investments in the
manufacture, deployment, operation, maintenance, and recycling of renewable energy technologies
in Europe. This would further damage European competitiveness in the crucial renewable energy
sector vis-á-vis the US and China who are already stepping up their regulatory support of
renewables, including for technology export purposes.

We are calling on you to seize the opportunity to adopt a clear policy framework in the RED by
resisting the pressure to incorporate, either directly or indirectly, any reference to non-renewable,
‘low-carbon’ technologies in ongoing legislative revision. Keeping the RED focused on renewables
only will give Europe a better chance of achieving cost-efficient and rapid decarbonisation, energy
sovereignty, and economic regeneration.

We hope that you will be able to give due consideration to the concerns we have expressed and are
available for discussion on the issues raised here.

1 Proposals to allow Member States to take so-called ‘low-carbon’ energy sources to account towards the overall EU renewable energy target (article 3 of the RED) or to be part of measures contributing to national renewable energy contributions, proposals to allow so-called ‘low-carbon’ energy sources to account towards the EU’s sub-targets on Renewable Fuels of Non-Biological Origin (RFNBOs) (article 22a and 25 of the RED and under Article 8a of the Gas markets and hydrogen directive)

2 Nuclear energy (i) implies high costs in both construction, waste storage, and management (ii) has important proven risks and potential major health impacts (iii) has been an unreliable power source in times of drought in some countries and (iv) often takes many years longer than planned to be realised, hence delaying potential GHG emission reductions far into the future.

Signatories (alphabetical order)
Air Pollution & Climate Secretariat (AirClim) – Emilia Samuelsson, Energy Expert
Association négaWatt – Hélène Gassin, President
Climate Action Network (CAN) Europe – Chiara Martinelli, Director
CEE Bankwatch Network – Anelia Stefanova, Strategic Area Leader for Energy Transformation
Centre for Transport and Energy – Veronika Murzynová, Energy Transition Expert
E3G – Nick Maybe, CEO
EKOenergy ecolabel – Steven Vanholme, Programme Manager
Electra Energy Cooperative – Chris Vrettos, Communications Manager
Ember – Sarah Brown, Europe Programme Lead
EuroNatur – Gabriel Schwaderer, Executive Director
Europe Beyond Coal – Mahi Sideridou, Managing Director
European Environmental Bureau – Patrick ten Brink, Secretary General
European Renewable Energies Federation (EREF) – Dörte Fouquet, Director
Focus Association for Sustainable Development – Živa Kavka Gobbo, Chair
Food & Water Action Europe – Frida Kieninger, Director of EU Affairs
France Nature Environnement – Arnaud Schwartz, President
Friends of the Earth Cyprus – Anastasia Korae, President of the Board
Friends of the Earth Europe – Eilidh Robb, Fossil Fuels Campaigner
Greenpeace European Unit – Magda Stoczkiewicz, Programme Director
LEGAMBIENTE – Mauro Albrizio, European Affairs Director
ÖKOBÜRO Alliance of the Austrian Movement – Thomas Alge, Managing Director
Partnership for Policy Integrity – Mary S. Booth, Director – Dirk Vansintjan, President
Réseau Action Climat France – Morgane Créach, Executive Director
Solar Heat Europe – Pedro Dias, Secretary General
Transport & Environment – William Todts, Executive Director
Umanotera, The Slovenian Foundation for Sustainable Development – Gaja Brecelj, Managing
Umweltdachverband – Gerald Pfiffinger, Managing Director
Circular Economy VšĮ “Žiedinė ekonomika” – Domantas Tracevičius, Director
Women Engage for a Common Future WECF9 – Katharina Habersbrunner, Board Member

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