Feedback from: Ember

This document is a feedback submission from the NGO Ember to the European Commission regarding the revision of guidelines for Trans-European energy infrastructure. Ember argues for a rapid shift away from fossil gas infrastructure, an increase in renewable energy sources (RES) and grid flexibility, and more transparent governance of infrastructure planning.

• Ember recommends that the 4th Project of Common Interest (PCI) list be the final one to include fossil gas projects, citing evidence that EU fossil gas infrastructure is already sufficient for future demand and security of supply. The organization warns that further investment in fossil gas would be a "catastrophic misdirection" of funds during a period when renewable energy and grid infrastructure investment is insufficient.
• The document advocates for the prioritization of Hydrogen infrastructure and the repurposing of existing gas infrastructure in regions with high potential for renewable Hydrogen production and large off-takers in hard-to-decarbonise sectors. It also notes that while CO2 storage capacity may be needed by 2030, it should be focused on difficult-to-decarbonise industries rather than the power sector, where significant CCS need is not shown before 2050.
• Ember asserts that renewable energy source (RES) capacity must increase 2-3 fold to achieve the EU's target of at least a 50% reduction in CO2 emissions by 2030. The organization criticizes the 4th PCI list for under-valuing grid flexibility, noting it contains only 6 smart grid projects and no battery storage, which indicates a "bias towards a supply-side paradigm."
• The submission highlights a RES ambition gap that is most significant in Central and Eastern Europe (CEE) and Southern and Eastern Europe (SEE), suggesting these areas present the greatest challenge. Additionally, Ember warns that interconnection with third countries carries a risk of carbon leakage unless implemented alongside a border carbon adjustment.
• Ember proposes expanding the responsibility for writing the Ten-Year Network Development Plan (TYNDP) beyond the two European Network of Transmission System Operators (ENTSOs) to reduce conflicts of interest. This change is intended to shift focus toward demand-side and non-infrastructure solutions and to align infrastructure needs with realistic energy demand predictions.

APA

Rosslowe, C. (2020). Feedback from: Ember. Ember. https://ember-energy.org/app/uploads/2024/12/Feedback-from_-Ember.pdf

Chicago

Rosslowe, Christopher. Feedback from: Ember. Ember, 2020. https://ember-energy.org/app/uploads/2024/12/Feedback-from_-Ember.pdf.

Wikipedia

{{cite press release |last1=Rosslowe |first1=Christopher |title=Feedback from: Ember |publisher=Ember |date=8 June 2020 |url=https://ember-energy.org/app/uploads/2024/12/Feedback-from_-Ember.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{rosslowe2020feedback, author = {Rosslowe, Christopher}, title = {{Feedback from: Ember}}, publisher = {Ember}, year = {2020}, month = jun, url = {https://ember-energy.org/app/uploads/2024/12/Feedback-from_-Ember.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }