The European Geothermal Energy Council (EGEC) welcomes the European Commission's initiative to review the Climate and Environmental Delegated Acts of the EU Taxonomy legislation. We strongly support the objectives of simplification, reduction of administrative burden, and alignment of Taxonomy with the EU's industrial and climate ambitions. In this context, and with the intention of contributing to a more coherent and technology-neutral sustainable finance framework, we wish to suggest the following modifications.
- Remove the emission threshold and mandatory LCA requirements for geothermal technologies
- Create a coherent taxonomy category for geothermal heat pumps
- Clarify the scope of the "Manufacturing of renewable energy technologies" category
- Address practical challenges in DNSH criteria for DHC networks
