Gas and hydrogen markets directive (common rules)

EASEE-gas, the European Association for the Streamlining of Energy Exchange – gas, welcomes the Commission's proposal for a Hydrogen and Gas markets Decarbonisation Package. EASEE-gas appreciates the inclusion of provisions on gas quality (GC) and hydrogen quality (HQ) handling, which reflect the relevance of gases quality management to ensure a smooth functioning of natural gas (including blends with renewable and…

Nordion Energi welcomes the proposed revisions. However, we find that more efficient measures could be included to facilitate a fast conversion to renewable and low-carbon gases, while allowing more synergies and ensuring security of supply.

•VIK and VCI welcome the steps taken by the legislative initiative for the integration of low greenhouse gas pipeline gases into the internal market. •The technology-open approach to taking into account low carbon hydrogen and low carbon fuels favours a rapid market uptake for climate-friendly gaseous fuels and feed stock.

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Neste Corp. (www.neste.com, the world's largest producer of renewable diesel refined from waste and residues, introducing renewable solutions also to the aviation and plastics industries) welcomes the revised Gas Directive proposal.

Business & Science Poland welcomes the opportunity to comment on the Gas Directive and Regulation. The proposed documents contain very ambitious proposals that will directly affect the shape and functioning of the European gas market. Hydrogen, at the heart of the European debate on the future of the EU, has a good chance of becoming the fuel of the 21st century.

Environmental Defense Fund Europe welcomes the opportunity to provide feedback on the proposed directive on the common rules for the internal markets in renewable and natural gases and in hydrogen. We believe that the proposed legislation, together with the related regulation on internal markets for renewable and natural gases and for hydrogen, will be central to ensure that hydrogen is produced and deployed in the…

E.ON supports the Commission proposal. By integrating hydrogen into the regulatory framework and applying many rules and principles set out for gas to H2, the Commission’s approach is to be supported. However, there are also provisions that seem to hinder more than to spur the transition, especially with regards to the unbundling rules. Therefore, we propose the following modifications: 1.

INES thanks for the opportunity to participate in this consultation and hereby provides feedback on specific aspects of the Directive that will directly and indirectly influence the gas storage sector. The central points of our feedback are: - INES proposes that certification of not only gases but all energy carriers should be regulated in a separate “Energy Certification Directive” (ECD).

Polskie Górnictwo Naftowe i Gazownictwo S.A. (Polish Oil and Gas Company; hereafter: PGNiG) supports objectives of the European Commission’s proposal for a directive on common rules for the internal markets in renewable and natural gases and in hydrogen (COM/2021/803), namely development of the low-emission and renewable gas market.

Swift, diversified and affordable climate neutrality can only be achieved if all available decarbonisation options can be used in all sectors, taking into account macroeconomic and cross-system considerations. It is therefore true that in its proposals the Commission also gives renewable and decarbonised gases an important role in the energy mix in the long term and applies in principle the well-established rules…

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A flexible, fit-for-purpose and progressive approach towards a regulatory framework for hydrogen is paramount. Coherence is particularly needed with: (1) The EU Hydrogen strategy: Today, hydrogen producers and industrial consumers are connected in regional clusters.

ESWET welcomes the European Commission’s proposal for a Gas Directive, as it accurately addresses the urgency of up-taking every low carbon energy source available, including the hydrogen and fuels generated from non-recyclable waste.

GRTgaz welcomes the revision of the EU gas legislation which, along with the revised rules for the EU electricity market, should enable the clean energy transition and the resilience of the energy sector by building on the synergies between electrons and molecules.

RTE takes note of the European Commission’s proposals to revise the Gas Markets Directive and Regulation. The European Commission is sending a clear message in favour of achieving climate objectives for 2030 and 2050 by including specific provisions for renewable and low carbon gases and by creating a legal framework for the hydrogen market.

Gas Infrastructure Europe (GIE), representing almost 70 European companies operating transmission pipelines, storage facilities and LNG terminals, shares the European Commission’s (EC) objectives of improving the gas market framework and to decarbonise the gas system.

The Gas Chamber of Commerce welcomed the possibility of submitting comments on the draft Directive of the European Parliament and of the Council on common rules for the internal markets in renewable gases, natural gas and hydrogen [COM(2021) 803]. We enclose the comments and requests which are the result of an analysis of the provisions of the draft Directive.

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Euro Chlor would like to thank the European Commission for the opportunity to provide feedback to this important legislative proposal. Euro Chlor represents the interests of chlor-alkali producers in Europe, we are a sector group of Cefic. Please find attached our input.

Given the challenges and complexity of the decarbonisation process, CRE considers it is paramount to show flexibility and pragmatism. The objective of any new regulation must be to allow the development and proper functioning of the renewable and low-carbon (R&LC) gases’ sectors. This requires the organisation of effective coordination between the different levels of governance.

The current proposal from the European Commission fails to free Europe from a fossil lock-in. This has become all the more clear with the release of the REPowerEU and a renewed dedication to reducing Europe’s dependency on fossil gas.

Terna welcome this EC opportunity to re-think the existing gas regulatory framework and to support the quantum leap needed for the greening of the "hard-to-abate sectors", where decarbonisation through full electrification is unlikely to be technically or economically viable, unleashing the full energy system integration.

The Hydrogen and Gas Market Decarbonisation Package launched by the EU Commission in December 2021 has been timely, as it is essential to foster the decarbonisation of the European economy while ensuring Europe's security of supply and competitiveness.

The fundamental view should be that technology neutral market driven approaches are the first choice, with other policies and measures to be considered only if there are compelling reasons. Given the level of state intervention in the economy through the EGD and the Fit for 55 package, any additional intervention should need to be carefully weighted and considered.

Fluxys is a fully independent gas infrastructure group with 1,200 employees active in gas transmission & storage and liquified natural gas terminalling across Belgium, Germany, France, and the UK. Fluxys welcomes the Commission’s proposal to decarbonize the European gas market and to facilitate the uptake of low-carbon and renewable hydrogen.

Gas Connect Austria welcomes the revision of the “Gas Package” aiming to facilitate the integration of renewable and low-carbon gases in the energy system and to establish a framework for a sustainable European hydrogen economy. Thank you very much for giving us the opportunity to participate in this consultation.

Teréga welcomes the EC’s revision of the third energy package for gas and the introduction of a hydrogen framework, in line to achieve EU climate targets for 2030 and 2050. An important focus should be on the coherence between the different legislations that are being updated as part of the ’Fit for 55’ package.

Europe is currently facing the double challenge of the Ukraine war and the ongoing climate and ecological crisis. It is more urgent than ever to recognise the need to end our dependence on fossil fuels and adequately plan their phase out, with a clear roadmap that leaves no one behind.

IFIEC, representing energy intensive customers, welcomes and in many aspects supports, the European Commission's proposal for a Hydrogen and Gas Decarbonisation Package. We agree that renewable and low-carbon gases, including hydrogen, have an important role to play as we move towards a carbon neutral society.

• DEPENDENCY ON FOSSIL GAS. To reduce this dependency, fossil gas-based H2 should be excluded from the definition of low-carbon H2 (even when fitted with CCS/CCU). This is especially relevant as this Directive includes measures to promote low-carbon gases, thus risking increasing such dependency. • FOSSIL FUEL COMPARATOR. The renewable and low-carbon gases injected are intended to substitute fossil gas.

In order to reach climate neutrality, especially what regards energy-intensive processes exposed to international competition, renewable energies, according technologies and input materials need to be available securily in amounts and quality as well as at internationally competitive conditions, especially prices. Otherwise, business cases cannot be established and according investments cannot be made.

FGSZ Ltd. is committed to take part in building the future hydrogen grid, but due to the peculiar situation of the nascent hydrogen market – neither demand, supply, nor mature technology and extensive infrastructure exist yet – we believe that certain provisions in the Hydrogen and Gas Market Decarbonisation Package proposal are holding back the quick transition to a decarbonised gas market.

Enagás welcomes the Commision's legislative proposal. Please find below comments (amendments in pdf attached): 1. Vertical unbundling: the ownership unbundling model should be favoured … since it is the most effective one and entailing less regulatory monitoring efforts. Enagás supports the proposal for HNOs and encourages to foresee a transition for gas TSOs to OU by 31 Dec 2030.

In view of the current geopolitical developments it is now necessary - with a holistic focus on the economy, politics and society - to succeed not only in overcoming the acute crisis in shaping the future, but also in bringing together security of supply and climate protection to a much greater extent, while not losing sight of the economic viability and affordability of energy supply for industry and consumers.

Yara shares the EU’s ambition of a climate neutral future, is actively working to decarbonize our industry in collaboration with partner companies and governments and pursues projects that can allow a rapid replacement of fossil fuels and cut the carbon footprint of nitrate-based fertilizer products up to 80-90%.

Enel welcomes the European Commission proposal on a Regulation and Directive on the internal markets for renewable and natural gases and hydrogen, as a necessary step to align the regulatory and policy framework of the gas sector to the 2030 and 2050 EU climate ambition.

ENGIE welcomes the EC’s proposal, which acknowledges the role of Renewable & Low Carbon (R&LC) gases in the energy transition. Definition of gases The proposed gas regulation and directive are reviewing definitions to cover R&LC gases. However, the proposed definitions and the additional (undefined) terms are mixing different elements: main chemical element, origin or GHG content.

There needs to be an own definition for biogas from anaerobic digestion and thermochemical conversion. Including in its definition also other low carbon gases and mixing it with natural gas can only be seen as a very bad approach and is not in line with definitions of RED Article 2 28 and contradicts stipulations in article 19 guarantees of origin for renewable energies.

Deutsche Umwelthilfe / Environmental Action Germany welcomes the opportunity to consult on the gas market directive and regulation. In general, we are not pleased with the roles that low-carbon gases and green hydrogen are given with this reform. The broad allocation of hydrogen across many sectors is critical.

OGE is one of the leading European Transmission System Operators (TSO) for gas with a pipeline network of approx. 12.000 km and is a frontrunner in building a future hydrogen backbone in Germany and Europe. We are fully committed to the European Green Deal and want to contribute to decarbonising the European economy by making use of our infrastructure in a sustainable and secure way.

Synergrid is focusing in its response mainly on the: • Directive on common rules for the internal markets in renewable and natural gases and in hydrogen. • Regulation on the internal markets for renewable and natural gases and for hydrogen. Our paper and response starts with a general position on the proposed EU legislation, followed by the main attention points in the new proposed legislation.

EFET response to the Hydrogen and Gas Markets Decarbonisation Package Recent exceptional events have obscured the successes of the European gas market in the last 20 years and its ongoing importance to achievement of the Fit for 55 objectives.

ENTSO-E welcomes the EC’s proposal for a hydrogen and gas markets decarbonisation package. Given the need to fully decarbonise the European economy while ensuring Europe’s security of supply and competitiveness, the proposals are timely. Direct electrification is the most cost-effective and energy-efficient way to decarbonise final energy demand for most applications.

EASE – The European Association for Storage of Energy welcomes the proposal for the Hydrogen and Decarbonised Gas package. The Directive is fundamental for the clean energy transition. Yet, renewable and low-carbon gases’ role in energy storage solutions and technologies is not sufficiently acknowledged.

MOL Group has a strong ambition to improve its operations and gradually transition to a low-carbon, sustainable business model. We welcome the Gas Package aiming to establish rules for the transport, supply and storage of natural gas system and its transition to the system based on renewable and low-carbon gases.

General remarks: Energinet generally welcomes the package of proposals from the European Commission (EC), noting that the market-based approach is maintained, and that there is a focus on promoting green gasses and establishing regulation for the future hydrogen market.

Red Eléctrica welcomes the European Commission´s initiative on the revision of EU rules on market access for gas networks, To achieve the EU climate neutrality objectives in a timely, cost-effective manner while ensuring secure and affordable energy, a well-integrated energy system linking different sectors and exploiting synergies is necessary.

GNI welcomes the ECs draft legislative proposal on Gas networks - revision of EU rules on market access (Directive). In light of recent geo-political events and the REPowerEU plan, developing an enabling framework to establish a market for renewable and low carbon gases is now more critical than ever.

The European Commission suggests that a timely and significant biomethane scale up will be key to disentangle the EU from Russian gas dependency. It proposed a target of 35 bcm of biomethane production by 2030 in its RePowerEU Communication , the equivalent of 10% of today’s natural gas consumption.

Italgas welcomes the introduction of this new Gas Package. Our vision fully aligns with the idea of a net zero economy by 2050. Natural gas, and later on gases (including biomethane, hydrogen and synthetic methane) are a crucial part of our energy systems, and it is essential to accelerate their path to decarbonisation.

GEODE believes the proposal represents a unique opportunity to promote system integration in the EU energy sector and scale up the share of renewable and low carbon gases as key drivers for decarbonisation. Hydrogen plays a central role in this context and this legislative text can dramatically enable its growth.

Gas Distributors for Sustainability (GD4S) welcomes the timely publication of the ECs draft legislative proposal on Gas networks - revision of EU rules on market access (Directive), in light of the recent EC REPowerEU Communication.

Interconnector Limited supports the EC’s proposals to decarbonise the EU gas market by facilitating the uptake of renewable and low carbon gases, including hydrogen. We also welcome the continued commitment to ensure there is energy security for all EU citizens.

The European steel industry welcomes the opportunity to provide its feedback and disclose its position on the European Commission's proposals on the revision of the rules on infrastructure and market design for renewable and low-carbon gases (EU Regulation 715/2009 and Directive 73/2009) in the context of the Fit-for-55 Package and the binding climate neutrality trajectory set out in the European Climate Law (EU…

The current geopolitical situation makes it very clear that the world urgently needs to increase and accelerate renewable energy projects. Europe finds itself in an important position to ensure energy security without continuing the development of fossil-based energy sources. In addition, the worrying findings in the most recent IPCC report remind us that the world needs to raise climate ambitions.

essenscia, the Belgian cross-sectoral federation of the chemical and life sciences industries, represents and promotes the interests of of more then 720 companies in the chemical and life sciences sector. The chemical sector is a large producer and consumer of H2 and expects H2 to play an import role in the future.

Helen thanks to the European Commission for the opportunity to leave feedback on Proposal for a directive of the European Parliament and of the Council on common rules for the internal markets in renewable and natural gases and in hydrogen 2021/0425 (COD). Helen is the second biggest energy company and in Finland with the largest district heating and cooling network in Finland what is the fifth largest in the world.

GRDF welcomes the EC’s draft legislative proposals. Overall, it is aligned with our ambition to facilitate the development of renewable and low carbon gases and move forward with the energy transition. As a gas distribution system operator (DSO), GRDF is keen to be part of the process towards a more sustainable society and adopt a common vision on the development of the energy market.

The Czech Gas Association welcomes the opportunity to comment on the recast Gas Directive. Below we highlight our key positions, the full assessment of the proposal is attached in the annex. 1) The proposal defines two separate systems. The requirements applicable to one system are, for the most part, different from those applicable to the other.

Wintershall Dea welcomes the opportunity to contribute to the public consultation on the Hydrogen and decarbonised Gas Market package, As a general matter, we consider the package as an important step to decarbonise the gas market, especially by the deployment of renewable and low-carbon gases. With respect to some details, we refer to the document attached.

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The Dutch distribution system operators (DSOs) Alliander, Enexis and Stedin welcome the European Commission's proposal for the "Decarbonised Gas and Hydrogen Package". This package aims to significantly modernise the current regulatory framework for gas, bring it into line with the current climate objectives and determine the market organisation for hydrogen.

The European Heating Industry, EHI, welcomes the publication of the Hydrogen and Decarbonised Gas Package that sets the rules for creating a competitive hydrogen market and better includes renewable and low-carbon gases in the legislation. In the current international context, it is more important than ever to reduce our energy dependence, especially from Russian gas.

The construction sector accounts for around 38 % of total CO2 emissions into the atmosphere and is one of the priority areas for action to meet the 2030 and 2050 decarbonisation targets. In this respect, there is much to say about the important role that electrification can play by heat pumps, but also in the 2050 scenario with a strong electrification scenario, it should be borne in mind that at least half of the…

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RAG Austria AG welcomes the creation of appropriate framework conditions for the H2 market/infrastructure. Nevertheless, we see considerable need for improvement in the current draft of the gas package: • The role of large-volume seasonal storage is still undervalued and has regulatory gaps: In the ramp-up phase, there should be the possibility of so-called "regulatory sandboxes" similar to those for grids.

JOINT VIK/VCI OPINION Legislative proposals on hydrogen and gas market decarbonisation Key messages •VIK and VCI welcome the steps taken by the legislative initiative for the integration of low greenhouse gas pipeline gases into the internal market.

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The European Commission published the revised text of the Gas Directive on 15 December 2021. MVM Group (a 100% state-owned integrated energy company active in the wholesale, retail, DSO and storage segments of the natural gas sector) has analysed the text.

The German Gas TSOs welcome in principle a revision of the Gas Directive to develop a clear legal and regulatory framework for the hydrogen market and dedicated hydrogen infrastructure. Extending the scope of the Gas Directive to hydrogen is sensible and effective, given that the majority of the future European hydrogen system will be developed by repurposing existing gas infrastructure and therefore operated by…

The Norwegian Oil and Gas Association (NOROG) welcomes this opportunity to contribute to the public consultation on the Hydrogen and Decarbonised Gas Marked Package in the context of the European Green Deal ambition to decarbonize the EU gas sector.

Repsol welcomes the proposal of the Hydrogen and Gas Market Decarbonization Package as it constitutes a framework that paves the way for a fast transition away from coal to natural gas and a progressive transition from natural gas to renewable and low-carbon gases, while establishes a regulatory framework for hydrogen with the same principles as for natural gas, including a transitional period which will favor the…

• Overall, the Directive and Regulation proposals are much in line with Naturgy’s observations during the consultation process. • In the REPower EU, the EC has recently proposed a longstanding request of the EU gas industry by defining a 35bcm biomethane gas target for 2030, together with the strengthening of the renewable hydrogen goals.

EDF recognizes that the revision of the Gas Directive & Regulation is needed to adapt the regulatory framework to the necessary changes in the gas system to progress towards a decarbonised Europe, while preserving the fundamentals of the current market structure.

The vzbv is grateful for the opportunity to comment on the European Commission’s proposals for the recast of the Regulation on the internal markets for renewable gases and natural gas and for hydrogen (COM(2021) 804 final) and on the Directive on common rules for the internal markets for renewable gases and natural gas and hydrogen (COM(2021) 803 final). Please find attached our opinion. Warm greetings [name removed]

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This is an expert opinion of AIB based on its experience in managing GO systems but not necessarily reflecting the opinion of all members, who may not have the mandate to decide on this topic. AIB appreciates the focus on empowering consumers through facilitating transparency regarding the origin of gases they consume.

HSE Group welcomes the process of modifying existing EU rules in the gas market with the aim to facilitate the integration of renewable and low-carbon gases. We believe that this is an Utmost necessary step in achieving a completely functioning internal energy market and ensuring security of supply as well as competitiveness of the EU industry.

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Farecogaz on “Hydrogen Ready Devices” Farecogaz is the European Associations of the manufacturers dealing with the gas metering chain, gas pressure regulator with associated safety devices and relevant stations. As Farecogaz we are keen to foster innovation in the gas market so that the ambitious EU Green Deal targets for 2030 and 2050 can be reached in time and with a positive impact on EU society.

CEFACD as the voice of individual heating and cooking appliances welcomes the European Commission’s proposals (regulation and directive) for a new EU framework to decarbonise gas markets and promote hydrogen (the Gas and Hydrogen Package). The European local space heaters (LSH) industry plays a key role in the European energy transition by its ability to reduce carbon emissions in European households.

ENTSOG welcomes the European Commission’s publication of the recast Gas Directive but finds there is need for certain amendments to achieve EU goals. The introduction of a system of financial compensation to ensure financing for cross-border hydrogen infrastructure (effectively an ITC mechanism for hydrogen) would be unnecessarily complex and overly burdensome.

Feedback on Gas Package We welcome the possibility to give feedback on the legislative proposals of the gas package published by the EU Commission on Dec. 15th, 2021. The initiative to introduce renewable and low-carbon gases in the regulatory environment as well as the commitment to reduce methane emissions from fossil as well as renewable and low-carbon sources is highly appreciated.

This is an expert opinion of the RECS Secretariat based on its experience of representing the users of GOs. It may not reflect the opinion of all members, but has been approved by the organisation's board. RECS appreciates the focus on empowering consumers through facilitating transparency regarding the origin of gases they consume.

Elia Group encompasses two electricity Transmission System Operators, Elia Transmission Belgium and 50Hertz in the northeast of Germany. Contributing to achieving the EU Green Deal’s objectives is at the heart of our company’s strategy.

IOGP Europe welcomes the proposed Hydrogen and Decarbonised Gas Market package as a necessary framework to decarbonise the gas sector by accommodating renewable and low-carbon gases under the gas market rules while safeguarding the achievements of the Internal Gas Market.

Dansk Energi (Danish Energy Association) welcomes the opportunity to comment on the proposed revision of EU rules on market access. Dansk Energi fully supports the initiative to provide an appropriate market framework to accommodate the increasing EU climate ambitions.

Company eustream, a.s. is a gas transmission system operator (TSO) located in Slovakia, operating one of the biggest gas transmission corridors in European Union. We highly welcome the proposal of the new energy package. It is a long awaited framework which is very much urgently needed to enable the pathway towards carbon neutral EU.