Bioenergia ry – the Bioenergy Association of Finland – considers that the primary function of the Governance Regulation should be to serve as a management dashboard for both the Member States and the Commission (which analyses aggregated data from the Member States) in the planning, reporting, and monitoring of energy and climate policy. The dashboard should mainly track those targets and sectors that will be defined at EU level for the period 2030–2040. The association emphasises that these targets and sectors do not necessarily need to be the same as those applied during the 2020s, if they are consistent with the recently agreed EU Climate Law.
As a general principle for decarbonisation, the focus should be on decreasing fossil emissions in the EU. Renewable energy, improvements in energy efficiency, carbon capture and technical carbon sinks should all be considered key tools as the EU advances toward its 2040 climate target. Once Member States have achieved a minimum level of renewable energy deployment and energy efficiency (for example, the 2030 target), Member States and companies should have greater flexibility in choosing subsequent measures to reduce emissions and increase carbon sinks. Progress monitoring should increasingly focus on greenhouse gas emissions and removals in the agreed sectors – not on secondary indicators, such as the shares of different energy sources or the total amount of energy saved.
The Governance Regulation should also support the resilience of the energy system and strengthen cooperation both between Member States and within Member States. However, the regulation should not be burdened with an excessive number of different indicators and monitoring requirements; instead, it should be kept strictly as a dashboard for agreed policy objectives.
The Bioenergy Association of Finland notes that, in designing the Governance Regulation, it must be considered that, under the EU Climate Law, reassessments will be carried out every two years during the 2030s, and the Governance Regulation will play a key role in this process.