Gas and hydrogen markets regulation

INES thanks for the opportunity to participate in this consultation and hereby provides feedback on specific aspects of the Regulation that will directly and indirectly influence the gas storage sector. Key aspects of our feedback are: - Cross-subsidization hydrogen / natural gas networks: It seems quite absurd that the introduction of a so-called dedicated charge is proposed as it allows – even though in a limited…

KGHM Polska Miedź S.A. is a Polish multinational corporation that employs over 32,000 staff around the world. We have been a major copper and silver producer for 60 years. We welcome the possibility to comment on Proposal for a Regulation of the European Parliament and of the Council on the internal markets for renewable and natural gases and for hydrogen (recast, hereinafter: revision of EU rules on gas market…

Eni welcomes the proposal for a hydrogen and decarbonised gas market package. We regard it as a key framework for decarbonization of the gas sector in line with the EU Green Deal energy and climate goals, by including renewable and low carbon gases in the gas market rules.

The Global Alliance Powerfuels welcomes the revision of the EU Gas Directive and the Gas Regulation and endorses the European Commission’s goal to support the EU's delivery of its strengthened climate targets by facilitating the gas market integration of renewable and low carbon gases, including renewable hydrogen and other renewable fuels of non biological origin (RFNBOs).

EASE – The European Association for Storage of Energy welcomes the proposal for the Hydrogen and Decarbonised Gas Regulation. This Regulation is fundamental for the clean energy transition. Yet, the role of renewable and low-carbon gas in energy storage solutions and technologies is not sufficiently acknowledged, which may hinder the security of supply efforts and lead to legal uncertainty.

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.

The Gas Chamber of Commerce welcomed the possibility of submitting comments on the draft Regulation of the European Parliament and of the Council on the internal markets for renewable gases, natural gas and hydrogen (recast) [COM(2021) 804]. We enclose the comments and requests which are the result of an analysis of the provisions of the draft Regulation.

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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 ensuring energy security for all EU citizens. The functioning of the internal market through effective market arrangements and facilitation of cross border trade are critical to meeting these goals.

Polskie Górnictwo Naftowe i Gazownictwo S.A. (Polish Oil and Gas Company; hereafter: PGNiG) supports objectives of the European Commission’s proposal for a regulation on common rules for the internal markets in renewable and natural gases and in hydrogen (COM(2021) 804), namely development of the low-emission and renewable gas market.

Eneco welcomes the Europeans Commission’s proposals to establish the conditions for a European internal hydrogen market to develop and facilitate the role of natural gas in the transition to a decarbonised energy sector. Green hydrogen is an important step in the implementation of Eneco's One Planet Plan, which is aiming at climate neutrality by 2035 for Eneco and its customers.

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…

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.

Plinovodi welcomes the European Commission’s publication of the recast Gas Directive and agrees with the response given by ENTSOG, with further emphasis highlighted bellow. The opinion of the TSO company Plinovodi is that the introduction of an ITC mechanism for hydrogen would be unnecessarily complex, costly and overly burdensome for Slovenia.

Plinovodi welcomes the European Commission’s publication of the recast Gas Regulation and agrees with the response given by ENTSOG, with further emphasis highlighted bellow. Plinovodi especially supports the removal or extension of the time limitation for the financial transfers between regulated services for gas and hydrogen as in some Member States the hydrogen market does not even exists yet or is not mature…

The Swedish Gas Association welcomes the EU’s ambitious comprehensive approach to climate policy. The climate package “Fit for 55” is an important big step in reducing emissions by at least 55 per cent by 2030 and achieving climate neutrality by 2050 – two urgent targets that the Swedish Gas Association fully supports and stands behind.

Dear Sirs, On behalf of our Clients JSC NJSC Naftogaz of Ukraine and Gas Transmission System Operator LLC, please find attached their joint comments to the recast Gas Regulation of the EU Hydrogen and Decarbonization Package. Kind regards, [name removed].

Enagás welcomes the Commision's legislative proposal. Please find below our comments (amendments 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.

Enagás welcomes the Commision's legislative proposal. Please find below our comments (amendments 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.

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.

Overall, E.ON supports the Commission proposal to revise the current gas markets rules and establish a framework that aims to boost the hydrogen and decarbonized gas markets. We are fully committed to support the energy transition which is at the heart of Europe’s climate ambitions.

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 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.

STATKRAFTS CONSULTATION RESPONSE ON THE HYDROGEN AND DECARBONISED GAS MARKET PACKAGE Statkraft refers to the European Commission’s proposed revision of the Directive of the European Parliament and Council no. 803/2021 on common rules for the internal markets in renewable and natural gases and hydrogen and the Regulation of the European Parliament and Council no.

The proposed hydrogen and decarbonized gas package outlines a vision to decrease emissions in the gas sector. 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.

Teréga welcomes the European Commission’s publication of the recast Gas Regulation, and suggests certain amendments needed to achieve EU goals. Cross-subsidies between natural gas and hydrogen H2 Terega welcomes the EC flexible approach to hydrogen infrastructure financeability given by mechanisms such as financial transfers between regulated services for gas and hydrogen under regulatory scrutiny and negotiated TPA…

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.

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.

• CROSS-SUBSIDIES BETWEEN DIFFERENT ENERGY CARRIERS. Cross-subsidies means deviating from the cost-reflective tariffs principle, thus distorting competition between different energy vectors, which is the essence of an efficient energy system integration according to Commission's Strategy itself.

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.

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%.

Deutsche Umwelthilfe / Environmental Action Germany (DUH) 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.

ENGIE welcomes the EC’s proposal, which acknowledges the key role of renewable & low carbon gases in the energy transition. Gases market design: operational impacts and incentives The introduction of an entry-exit system that merges Transmission&Distribution (T&D) levels should ensure the integration of the distribution system level in the balancing zone and help to achieve a level playing field for Renewable and…

Position regarding legislation that affects conditions to promote bioenergy Bioenergy offers a range of benefits and potential for Östergötland Östergötland is a prosperous region, with a thriving forestry industry and agricultural sector.

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.

General remarks Energinet welcomes the proposal from the European Commission (EC), noting that the market-based approach is largely maintained, that there is focus on establishing regulation for the future hydrogen market and that some efforts have been pointed towards green gasses.

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.

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.

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.

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 is key in this context and this legislative text can dramatically enable its growth.

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

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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.

GNI welcomes the ECs draft legislative proposal. In light of recent geo-political events and the REPowerEU plan, developing an enabling framework to establish a market for renewable gases is critical. GNI welcome the opportunity to express our views on key topics below: Following Brexit in June 2020, Ireland is no longer directly connected to the EU gas system.

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 (Regulation), in light of the recent EC REPowerEU Communication. This proposal will act as a key enabler to GD4S’ vision and we welcome the clarity provided.

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 German Biogas Association (GBA) welcomes the fact that the EU Commission wants to regulate, facilitate and expand market access for renewable gases – including hydrogen – in the common market. However, in the draft proposal there is no distinction made between renewable, low-carbon or fossil-based gases.

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 hydrogen and expects hydrogen to play an import role in a low carbon economy.

The Czech Gas Association welcomes the opportunity to comment on the recast Gas Regulation. 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.

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.

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 text of the Decarbonised Gases Regulation 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 Regulation and the efforts of the European Commission to develop a clear legal and regulatory framework for the hydrogen market and dedicated hydrogen infrastructure. The EU energy transition can only succeed if the affordability of energy is guaranteed for consumers and thus positive acceptance of the change is created.

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. • We welcome the increased efforts, targets and instruments announced to ensure an early deployment of renewable hydrogen technologies. Hydrogen will be a critical lever in all LT scenarios.

The wastewater services sector currently produces biogas that can be upgraded into biomethane. In some Member States biogas is mostly upgraded to biomethane for injection into the gas network. There is significant potential, and more recently growing necessity, to ramp up the volume of biomethane and biogas produced by wastewater service providers.

ENTSOG welcomes the European Commission’s publication of the recast Gas Regulation but finds there is need for certain amendments to achieve EU goals. ENTSOG welcomes the EC’s proposal to allow financial transfers between regulated services for gas and hydrogen as one way to finance the hydrogen network. However, there should be some degree of flexibility for Member States in this matter.

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.

As EnBW, we very much welcome that large parts of the proposals of the Directive and Regula-tion on the internal gas market for the establishment of a hydrogen market, correspond to the model of the existing and functioning internal gas market. However, we see some points in the draft that could considerably delay the rapid development of a hydrogen market.

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.

UPRIGAZ, which brings together the main companies operating in France throughout the gas value chain and on the electricity market, is directly concerned by this European Commission proposal, and wishes to highlight several points: 1.UPRIGAZ welcomes the fact that the Commission’s proposals do not call into question the rules for the functioning of the natural gas market laid down in 2009.

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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.

COGEN Europe welcomes the European Commission's initiative to propose a Hydrogen and Gas markets Decarbonisation Package, with a view to deliver carbon neutrality by 2050 through higher energy efficiency and energy systems integration. The cogeneration sector is committed to the creation of a resilient, decentralised and carbon neutral European energy system by 2050 with cogeneration as its backbone.

AFG: 1.Implement a binding European gas target based on a clear terminology for all green gases and an adequate guarantee of origins (GO) system In order to accelerate the production and deployment of green gases in a long term vision, AFG calls for a binding European target.

Norway supports the vision for a European Green Deal. Without prejudice to the scope of the EEA Agreement, we contribute to this consultation. Natural gas accounts for 95 % of gaseous fuel demand and is an indispensable part of Europe's energy mix. It has many advantages: It is flexible, plentiful, affordable and an important industrial feedstock.

Norway supports the vision for a European Green Deal. Without prejudice to the scope of the EEA Agreement, we contribute to this consultation. Natural gas accounts for 95 % of gaseous fuel demand and is an indispensable part of Europe's energy mix. It has many advantages: It is flexible, plentiful, affordable and an important industrial feedstock.

The impact assessment of Direct Gasification of Waste (municipal waste or cellulosic biomass) may be included in the Hydrogen and Gas markets Decarbonisation Package. 100 mton of non-recyclable waste in EU represents more than 10 mton of Hydrogen and could replace 40 billion litres of fossil Diesel.

General observations EnBW Energie Baden-Württemberg AG shares the vision of a climate neutral energy system and supports the objective of EU-climate neutrality. Renewable and decarbonized gases like biomethane and hydrogen will have to play a key role to reach this objective. For this reason, EnBW is engaged in the EU Clean Hy-drogen Alliance, working on projects along the gas value chain.

Given the significant economic and climate risks of overinvesting in methane gas, ClientEarth’s response to the Roadmap/IIA consultation focuses on measures to avoid investment in methane gas and hydrogen projects at the cost of clean alternatives.

VKU would like to highlight seven key points for consideration regarding the transformation of the gas distribution networks and the role of gas distribution system operators in building a competitive European H2 economy. The propositions are being addressed in greater detail in the paper attached – please have a look.

CEDEC believes that a new policy framework supporting the uptake of renewable, decarbonised and low-carbon gases, is urgently needed to allow these gases to play a role in achieving an integrated, reliable, sustainable and affordable energy system.

France Hydrogène welcomes the revision of the Gas Directive and Regulation in order to prepare the design of a competitive hydrogen market by 2030, as promoted in the EU Strategy on Hydrogen. Renewable and low-carbon hydrogen are efficient solutions to decarbonize hard-to-abate sectors such as chemicals, heavy industries, heavy-duty road transport, railway, aviation and shipping.

Gas for Climate welcomes the European Commission’s vision described in the combined roadmap and inception assessment on the Hydrogen and Gas Markets Decarbonisation Package, and would like to emphasise the importance of the topic and give brief feedback on the described problem areas and objectives. Please find our response attached.

VDMA The Mechanical Engineering Industry Association (VDMA) is the largest European industrial association. VDMA represents more than 3.300 member companies in the SME-dominated mechanical engineering industry in Germany and Europe.

Gasgrid Finland welcomes the initiative of the European Commission to future-proof the Gas Market Directive and Regulation. Furthermore, we appreciate the European Commission for giving the public an opportunity to provide feedback on this initiative. Please find Gasgrid Finland’s response attached. Respectfully, Gasgrid Finland Oy

Hydrogen Europe welcomes the European Commission’s objective to fully align energy markets to the ambitions of the Green Deal. Indeed, the EU Strategy for Energy System Integration and the Hydrogen Strategy set ambitious targets with a view to developing a secure, safe and affordable hydrogen economy in Europe.

Deutsche Umwelthilfe / Environmental Action Germany welcomes the opportunity to comment on the initiative at this stage. This legislation is essential in leveling the playing field between natural gas, hydrogen, other gases and renewable electricity. Natural gas currently enjoys significant regulatory advantages. While green hydrogen, renewable electricity etc.

Confederation of Industry of the Czech Republic (SP CR) welcomes the opportunity to comment on the Inception Impact Assessment on Hydrogen and Gas markets Decarbonisation Package. SP CR believes he amendment of the Gas Directive and Regulation should achieve the following objectives: maximize synergies between gases (methane) and hydrogen (in particular, repurposing or retrofitting gas infrastructure opportunities)…

WindEurope welcomes the European Commission combined roadmap and inception impact assessment on the Hydrogen & Gas Markets Decarbonisation Package and calls for this package to: - Foster renewable hydrogen in the hard-to-abate sectors - Ensure the development of a competitive European hydrogen market - Accelerate the deployment and reinforcement of a cost-efficient energy infrastructure WindEurope believes that a…

Grid operators are also challenged to seek for new ways of integrating the electricity and gas grid, and possibly even district heating grids. This integration of causes a major change of our role and function in the system, developing them from a traditional grid operator and towards an integrated system operator.

2020 was a turning point for the discussion on environmental issues and in this context hydrogen received unprecedented attention, being recognized as a strategic energy vector to achieve the EU decarbonisation targets, together with other renewable and low-carbon gases such as Biogas and Bio-Methane.

(PART 3/3) ... Given that the future hydrogen network will share the same intrinsic characteristics to the natural gas system, FSR suggest that the starting point for the future hydrogen market would be to parallel these rules. As mentioned above, it is important that effective competition for low and zero-carbon hydrogen develops effectively from the beginning.

(PART 2/3) .... The Internal Energy Market in its current form has proven to deliver effective energy prices as well as driving innovation and security of supply. Wherever possible, the Internal Energy Market should be used to drive energy sector integration in a technology-neutral and cost- effective manner that will benefit citizens and ensure affordable energy.

(PART 1/3) The Florence School of Regulation (FSR) welcomes the European Commission’s (EC) initiative to begin mapping the development of future gas regulation and widely supports the direction of this Roadmap/ Inception Impact Assessment (IIA) in achieving that. FSR is a center of excellence for independent research and knowledge exchange with the purpose of improving the quality of European regulation and policy.

Danish Energy welcomes the opportunity to comment on the roadmap for the Hydrogen and Gas mar-kets Decarbonisation Package. Danish Energy is an association representing Danish electricity and gas companies. Our members include gas suppliers and companies active in the North-western Euro-pean gas markets.

SolarPower Europe provides the following recommendations to scale up the market uptake of renewable hydrogen, building on the priorities provided to the EU Hydrogen Strategy, EU Strategy on Energy Sector Integration, and the revision of the TEN-E Regulation: 1. Foster targeted deployment of renewable hydrogen in hard-to-abate sectors, where direct electrification is not cost-efficient or technically viable.

EFET welcomes the publication of initial ideas on how to establish a suitable market framework for hydrogen and gas to support achievement of EU climate ambitions, and strongly endorses that this should be a central part of the Fit for 55 package. The following is an extract from the more detailed response attached. It is increasingly accepted that net zero emissions by 2050 will be impossible without molecules.

Repsol appreciates the opportunity to submit our views and opinions to the European Commission’s roadmap on Gas networks - revision rules on market access. Please find our feedback in the document attached. We look forward to continuing participating actively in the development of this legislative procedure, by providing further input to upcoming consultations and addressing other information requests the Commission…

PGNiG welcomes the opportunity to comment on the Commission’s Inception Impact Assessment as regards the revision of EU rules on market access to gas networks. The planned revision of EU should include only targeted changes in the regulatory framework in order not to undermine the benefits of the Third Energy Package.

The Association of Energy Trading (TOE) response to the European Commission initiative ‘Hydrogen and Gas markets Decarbonisation Package’ In regard to the consultations on changes in EU regulations regarding access to the gas market, entitled: ‘Hydrogen and Gas markets Decarbonisation Package’, below we hereby present TOE’s suggestions and comments in order to provide directional support in the following regulatory…

The Austrian Federal Economic Chamber (WKÖ) welcomes the initiative of the European Commission to review the legislative framework in order to design competitive decarbonised gas markets as a means to facilitate the gas sector’s contribution to the overall energy system decarbonisation.

The H2/Gas Markets Decarbonisation Package is necessary to prepare the energy system for the challenges posed by the decarbonisation journey. The framework should be coherent with the energy efficiency first principle and the EU’s acquis. Moreover, a pragmatic approach should be adopted regarding the contribution of a decarbonised gas sector to a carbon-neutral Europe.

You can find SEDIGAS´s response to European Commission’s consultation on the revision of EU rules on gas market access in the document attached. consider only the document under the name "20210309 Respuesta Consulta roadmap Gas networks - revision of EU rules on market access def" Please reach bach to us to expand any argument given in that document.

DEDA S.A. welcomes the proposal for a regulation updating common rules for the natural gas internal market and for the conditions for accessing natural gas distribution networks. In principle DEDA identifies the same problem areas, as well as the need for replacing coal in power generation, liquid fuels for heavy road and maritime transport.

Eurogas is committed to achieving the objectives of the Paris Agreement. We support the EU’s aim to reach climate neutrality by 2050 and the intermediary target of reducing GHG emissions by at least 55% by 2030. The speed with which change must happen to meet these objectives requires policy makers to take decisive action and acknowledge the role of the gas sector in achieving these goals.

We welcome the opportunity to respond to this Inception Impact Assessment (IIA). Our observations and recommendations are: • Significant competitive distortion: The Internal Market for Gas legislative basis is one of the largest and most sophisticated fossil fuel subsidy regimes in the EU.

St1 would like to thank the Commission for the opportunity to comment on the review of the Union’s rules and regulations to better support the decarbonisation of European gas networks. We support a common gas strategy that can quicken the pace of the energy transition and would like to highlight the following points: - St1 encourages the harmonisation of sustainability criteria for all energy carriers.

Elettricità Futura welcomes the development of a Hydrogen and Gas markets Decarbonisation Package. Direct electrification is a viable and efficient solution to decarbonize a large part of the energy demand, while hydrogen can play a significant role in specific hard to abate sectors. Other green gases and biofuels can also be part of a decarbonized energy mix.

The EU needs to deliver markets that are ‘fit for 55’ by 2030 and ensure that the needs of energy consumers are met in a world in which a variety of new energy solutions become available. These imply a reduction of 29-37% in fossil gas consumption by 2030. This dynamic will fundamentally transform the shape of the gas market.

Low carbon and renewable (LC&R) gases will be needed to complement direct electrification and contribute to a net-zero economy, especially in hard-to-abate sectors. To support energy sector integration, it is key to compare costs, potentials and societal benefits of decarbonisation options from production to end users and avoid the sole focus on infrastructure costs.

1. Application of Internal Energy Market principles to the future H2 market Regulatory intervention for H2 networks is justified on economic grounds. Incorporating the rules for H2 in the gas legislation would be the most efficient way of ensuring regulatory alignment between H2 and CH4. 2.

Gas Infrastructure Europe (GIE) welcomes the European Commission's initiative to give feedback to the roadmap on Gas networks - revision rules on market access. We appreciate the opportunity to submit our views and opinions in the document attached. We are looking forward to continuing the discussion with the European Commission.

Siemens Energy welcomes and supports the European Commission's initiative to prepare gas markets for the increased EU's climate ambition with the roadmap on "Gas networks - revision of EU rules on market access". Please find attached a white paper on "Hydrogen infrastructure – the pillar of energy transition. The practical conversion of long-distance gas networks to hydrogen operation".

As far as natural gas is concerned, the results of the implementation of the third legislative package are very positive, as it has allowed a real integration of national markets to the benefit of the European market, as evidenced by competition development, security of supply at European level, convergence of market rules and of prices on wholesale markets.

Feedback from Europex, the Association of European Energy Exchanges. The progressive evolution of the gas legislative framework is a necessary prerequisite to ensure gas markets are ready to integrate and foster the use of renewable and low-carbon gases while maintaining a high-level of security of supply and guaranteeing an efficient price formation.

Electrification and sector integration play an essential role in Europe’s ambition achieving climate neutrality by 2050. Vattenfall believes in a future where electrification is an efficient tool to realise the decarbonisation of, for instance, the transport and industrial processes to the greatest extent possible.

COMBINED EVALUATION ROADMAP/INCEPTION IMPACT ASSESSMENT HYDROGEN AND GAS MARKETS DECARBONISATION PACKAGE 10 March 2021 Note: Fertilizers Europe as an active member of the IFIEC gas working party supports this particular position put forward by IFIEC to the inception impact assessment. IFIEC supports the aim of the Green Deal Strategy to transform the energy markets in a non-disruptive and cost-effective manner.

The Zero Emissions Platform (ZEP) is a European Technology and Innovation Platform (ETIP) under the Commission’s Strategic Energy Technology Plan (SET-Plan) and acts as the EU’s technical adviser on the deployment of Carbon Capture and Storage (CCS), and Carbon Capture and Utilisation (CCU) under Horizon2020 R&I programme (grant agreement 826051).

In 2018, 32% of EU households’ energy demand was met with gas, over 99% of fossil origin. To tackle the climate crisis, consumers will need to change the way they heat their homes. To increase public acceptance of the change, the EU should promote infrastructure and fuel options leading to decarbonisation at the lowest cost and hassle for consumers and support them to switch primarily to smart electrification and…

Gas Distributors for Sustainability (GD4S) welcomes the opportunity to provide feedback on the “Gas networks - revision of EU rules on market access” IIA consultation. In particular, we agree with the EC’s assessment that “full electrification is unlikely to be technically or economically viable”, and that “the share of gaseous fuels to total EU energy consumption in 2050 would be about 20%”, broadly in line with…

DVGW welcomes the European Commission’s initiative to revise the existing gas market rules in a legislative “Hydrogen and Gas Markets Decarbonisation Package” with the aim of decarbonising Europe’s energy demand.

It is important that the EU- regulation help and not risk hindering the EU Member States to reach energy, environmental and climate goals. In line with the Green Deal Strategy, energy markets will need to transform to enable moving towards a net zero target, and it is important that these objectives can be realised in a non-disruptive and cost-effective manner.

• This package should be framed within the 2030 and 2050 goals. Hence, it must: o be consistent with the goals and principles of the Green Deal; o respect the basic principles of liberalisation; o be aligned with the decarbonisation-enabling initiatives of the CEP; o be realistic regarding the contribution of hydrogen and gas to carbon neutrality (i.e.

• This package should be framed within the 2030 and 2050 goals. Hence, it must: o be consistent with the goals and principles of the Green Deal; o respect the basic principles of liberalisation; o be aligned with the decarbonisation-enabling initiatives of the CEP; o be realistic regarding the contribution of hydrogen and gas to carbon neutrality (i.e.

Gas Networks Ireland (GNI) welcomes the opportunity to provide feedback on this consultation. We agree with the EC’s assessment that “full electrification is unlikely to be technically or economically viable”, and that “the share of gaseous fuels to total EU energy consumption in 2050 would be about 20%”, broadly in line with today’s share.

We recognize that this initiative can make a significant contribution for a decarbonization pathway that i) leaves nobody behind, ii) optimizes costs for the energy system transition, iii) facilitates competitive energy prices.

DVGW welcomes the European Commission’s initiative to revise the existing gas market rules in a legislative “Hydrogen and Gas Markets Decarbonisation Package” with the aim of decarbonising Europe’s energy demand.

The Federal Chamber of Labour (BAK) is the statutory body representing the interests of around 3,8 million workers and consumers in Austria. It represents its members in all social, educational, economic and consumer policy issues at national level and in Brussels at European level. 1.) Renewable gas: The production of both biomethane and green hydrogen involves a great deal of resources.

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Italgas welcomes the possibility offered by the Commission to react to the Roadmap on the Hydrogen and Gas markets Decarbonisation Package. We share the Commission's vision of the future long-term role of gas in Europe's energy supply, which states that gas will provide roughly the same contribution in 2050 as it does today, remaining an essential balancing source in a system increasingly relying on RES generation.

EUGINE, the European Engine Power Plants Association, together with EUTurbines, the European Association of Gas and Steam Turbine Manufacturers, welcome and support the European Commission’s initiative to prepare gas markets for the increased EU’s climate ambition.

EUTurbines, the European Association of Gas and Steam Turbine Manufacturers, together with EUGINE, the European Engine Power Plants Association, welcome and support the European Commission’s initiative to prepare gas markets for the increased EU’s climate ambition.

Terna welcomes the opportunity to provide a response to the European Commission public consultation on the Roadmap for the revision of Regulation (EC) No 715/2009 and Directive 2009/73/EC (the “Gas Package”). Accelerating the electrification of energy demand, building on a largely renewables-based power system will provide the main contribution to decarbonization by 2050.

In the EU, carbon dioxide emissions from fossil gas have now exceeded those from coal, and could overtake oil to become the largest source of carbon emissions by 2040. The European Commission’s own analysis shows that fossil gas demand will have to fall by up to 37% by 2030 and almost entirely eliminated by 2050 if Europe is to meet its climate targets.

The BDEW supports the objective of EU climate neutrality by 2050 and the Commission’s proposal for a net GHG reduction target for 2030 of at least 55 %. The revision of the EU legal framework for gas must recognise the role of gas and its infrastructure and create the necessary framework conditions for the high flow of climate-neutral gases.

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For the successful implementation of the Green Deal the development of an internal hydrogen market is of vital importance. The existing regulatory framework for gas should be made fit and adaptive to integrate renewable and low-carbon gases into the system.

Confindustria welcomes the revision of Directive 2009/73 and Regulation 715/2009, considering that the future H2 framework can be embedded within the principles of the Gas Internal Energy Market. Gas is an enabler of the EU decarbonization: several sectors rely on natural gas to fuel industrial processes (directly or through cogeneration) or as input for chemical production.

Fluxys welcomes the opportunity provided by the Commission to consult stakeholders’ views to complement the Commission’s work on an Inception Impact Assessment for a Hydrogen and Gas markets Decarbonisation Package.

EEX welcomes the Commission´s initial impact assessment / roadmap for the hydrogen and gas markets decarbonization package. Scaling up markets for clean hydrogen affects many dimensions that require coordinated European answers and framework conditions.

The SWM welcomes the Commission’s initiative to seek a revision of the gas package to regulate competitive markets for renewable and low-emission gases. Only a secure legal framework will provide the necessary financial resources from both the public and private sides to achieve the decarbonisation of the entire gas sector.

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The SWM welcomes the Commission’s initiative to seek a revision of the gas package to regulate competitive markets for renewable and low-emission gases. Only a secure legal framework will provide the necessary financial resources from both the public and private sides to achieve the decarbonisation of the entire gas sector.

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GAZ-SYSTEM welcomes the opportunity to provide the European Commission with a gas TSO view on the proposal for a revision of the EU rules on market access. Having in mind the current status of development of energy markets in different regions, including those that are highly dependent to coal and lignite, GAZ-SYSTEM is convinced that the ramp-up of the new gases market will go in parallel to the functioning of a…

Finnish Energy represents the Finnish electricity, gas, and heating sectors, and we have 270 members. We strongly support the EU’s climate targets for 2030 and 2050. We are also committed to Finland’s carbon neutrality target for 2035.

The European Lime Association (EuLA) welcomes the initiative of the European Commission (EC) to receive feedback on the inception impact assessment on the Hydrogen and Gas markets Decarbonisation Package, revising Directive 2009/73/EC and Regulation (EC) No 715/2009.

GENERAL COMMENTS: Energinet would like to thank the EC for the timely initiative for a revision of the gas legislation and legislative proposals for regulation of hydrogen infrastructure. Ultimately, the gas legislation will be a crucial piece in the comprehensive regulatory puzzle, which should ensure deliverance on long term political targets for climate and energy throughout the entire European economy.

Although the roadmap broadly addresses the right questions, it omits to include the relevance of the local level and the role of gas DSOs in the transition. We will mainly comment on two of the four questions raised by the EC: 1. How should the hydrogen infrastructure and market be regulated in the future and which role should (gas) TSOs / DSOs play? In general, we miss the inclusion of the local perspective.

GRTgaz welcomes the opportunity to provide its feedback to the combined evaluation roadmap related to the “Hydrogen and Gas Markets Decarbonisation Package” initiative. Making our infrastructure futureproof to fully contribute in the EU climate neutrality objective is the way forward while also representing a real paradigm shift for the gas industry and our company.

GRTgaz welcomes the opportunity to provide its feedback to the combined evaluation roadmap related to the “Hydrogen and Gas Markets Decarbonisation Package” initiative. Making our infrastructure futureproof to fully contribute in the EU climate neutrality objective is the way forward while also representing a real paradigm shift for the gas industry and our company.

The European Heating Industry welcomes that the European Commission is proposing to review EU gas rules to facilitate the market entry of renewable and decarbonised gases. The future greening of energy carriers (i.e. electricity, gaseous fuels) is crucial for a decarbonisation pathway that i) leaves nobody behind, ii) optimises costs for the energy system transition, iii) facilitates competitive energy prices.

As of 1 January 2024, it will be mandatory in the European Union to provide citizens with separate treatment methods for bio-waste, the potential for material and energy recovery of which is important, from a circular economy perspective, as a necessary condition for sustainable development. On the other hand, residents will be asked to carry out this new sorting without being obliged to do so in many Member States.

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Cefic supports Europe’s ambition to become climate neutral by 2050 requiring breakthrough technologies and enabling frameworks for the very large investments required. The chemical industry is already nowadays a major producer and consumer of hydrogen. On a local level, production and consumption are typically well-balanced today.

The European Industrial Gases Association, EIGA, is pleased to share its views on the Inception Impact Assessment on the reform of Europe’s gas markets. We especially welcome the European Commission’s objective of strengthening the market for hydrogen and other low carbon gases, governed by sound principles which ensure fair competition between market operators.

IFIEC position COMBINED EVALUATION ROADMAP/INCEPTION IMPACT ASSESSMENT HYDROGEN AND GAS MARKETS DECARBONISATION PACKAGE IFIEC supports the aim of the Green Deal Strategy to transform the energy markets in a non-disruptive and cost-effective manner.

Association for District Heating of the Czech Republic (ADH CR) welcomes the opportunity to comment on Roadmap to Hydrogen and Gas markets Decarbonisation Package (Roadmap). AHD CR understands Gas markets decarbonisation as major tool how to deliver on ambitious EU targets for 2030 and 2050 as well. ADH CR would like to raise following issues: 1.

Association for District Heating of the Czech Republic (ADH CR) welcomes the opportunity to comment on Roadmap to Hydrogen and Gas markets Decarbonisation Package (Roadmap). AHD CR understands Gas markets decarbonisation as major tool how to deliver on ambitious EU targets for 2030 and 2050 as well. ADH CR would like to raise following issues: 1.

HSE GROUP’S CONTRIBUTION HSE Group welcomes the Commission's intention to assess and revise the existing EU gas rules to facilitate the market entry of renewable and low-carbon gases. We consider it as a much-needed step towards a fully functioning internal energy market and ensuring security of supply and industry competitiveness alongside contributing to the goals of the European Green Deal and ambitious…

In reference to the revision of EU gas rules, we would like to present our conclusions and observations from the perspective of an owner of companies selling ecological energy in Poland. GAS MARKET The current provisions of the national law for the sale of gaseous fuels require a license from the enterprise, which involves high start-up costs and a long period of implementation of the necessary documents.

In reference to the revision of EU gas rules, we would like to present our conclusions and observations from the perspective of an owner of companies selling ecological energy in Poland. GAS MARKET The current provisions of the national law for the sale of gaseous fuels require a license from the enterprise, which involves high start-up costs and a long period of implementation of the necessary documents.

The Gas Grid Group AISBL represents four German Gas TSOs in Brussels: bayernets, OGE, ONTRAS and GASCADE. We are fully committed to the objectives of the EU green deal and believe that kick-starting a hydrogen economy in this decade is crucial for becoming the first climate neutral continent.

Enel strongly believes that the completion of the decarbonization of the power sector and the electrification of final uses, such as transport, heating and cooling and industry, along with energy efficiency, are the key levers to trigger for a clean and cost-efficient transition. These measures have the lowest CO2 abatement cost to tackle the largest part of emitting activities.

Enel strongly believes that the completion of the decarbonization of the power sector and the electrification of final uses, such as transport, heating and cooling and industry, along with energy efficiency, are the key levers to trigger for a clean and cost-efficient transition. These measures have the lowest CO2 abatement cost to tackle the largest part of emitting activities.

The Clean Air Task Force (CATF) welcomes the European Commission’s climate ambition, leadership on decarbonisation and innovation, and pursuit of policies to decouple greenhouse gas emissions from economic growth.

The VCI advocates a non-disruptive and cost-effective transition of energy markets towards net-zero greenhouse gas emissions in planned stages of development. This requires cost efficiency and sufficient availability of greenhouse gas neutral energy sources at competitive prices. Otherwise, transition in industry cannot succeed; As a result, there is a risk of carbon leakage.

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This response is non-confidential Introduction Aughinish Alumina Limited (Aughinish) since 1983 has operated a large alumina refinery based in West Limerick. The alumina plant is one of the most energy efficient in the world and produces 30% of EU alumina requirements.

Plinovodi, the Slovenian gas TSO, is summarizing its feedback in bellow points: 1. Application of Internal Energy Market rules to H2 market as H2 system is interoperable with other systems, with additional elements that reflect the particularities of H2 business.

We welcome the approach of the European Commission that the reforms should enable fair competition between smart electrification, energy efficiency, and renewable gases in achieving decarbonisation targets. To maximise the potential decarbonisation effects of renewable energies, we regard it particularly important to define two basic principles: technology and source neutrality.

DEPA INFRASTRUCTURE S.A. (Greece)welcomes the initiative of the Commission to update the Directive and Regulation on the natural gas market and networks towards the deployment of renewable and low-carbon gases (including hydrogen and biomethane)- “new gases”, while recognizing the significant role of natural gas in the transition towards climate neutrality by 2050.As the existing regulation of EU energy deals…

VIK welcomes the opportunity to participate in the consultation on the roadmap and inception impact assessment hydrogen and gas markets decarbonization package. VIK supports the goal of the Green Deal to change energy markets in a non-disruptive and cost-efficient manner. However, the industries concerned are exposed to international competition.

Bosch Thermotechnik GmbH welcomes the proposed European Commission review of the EU gas rules to facilitate the market entry of renewable and decarbonised gases. The decarbonisation of both gaseous fuel and electrical energy carriers is vital for the decarbonisation of buildings. “Renewable and decarbonized” gases and electricity all have an essential role in achieving a carbon-neutral building stock by 2050.

Uprigaz wonders on the basis of the Commission’s view that electrification of uses is the most efficient solution for most sectors except for transport, industry and regrets the lack of an evaluation taking into account the principle of technological neutrality.

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Total welcomes the initiative of the Commission to update the Directive and Regulation on the natural gas market and transmission networks towards the deployment of hydrogen and biogas/biomethane, while maintaining the necessary infrastructure for natural gas to play its essential role in the energy transition as a quick win in replacing coal for power generation, liquid fuels for heavy road and maritime transport…

Total welcomes the initiative of the Commission to update the Directive and Regulation on the natural gas market and transmission networks towards the deployment of hydrogen and biogas/biomethane, while maintaining the necessary infrastructure for natural gas to play its essential role in the energy transition as a quick win in replacing coal for power generation, liquid fuels for heavy road and maritime transport…

EUROMOT very much supports the EU ambition for a rapid reduction of greenhouse gas emissions and of the unabated use of fossil fuels, and for a progressive increase in the market penetration of low-carbon gases.

The Czech Gas Association (CGA) welcomes the possibility to comment on the inception impact assessment on the revision of the Gas Directive and Gas Regulation and would like to express its opinions on the Hydrogen and Gas markets Decarbonisation Package.

The CFE Energies, a french union federation of employees in the power and gas sectors, welcome the European initiative for a public consultation on Hydrogen and Gas markets Decarbonisation Package. This reflects the European Union (EU) willingness to be the driving force of the international community in the fight against climate change.

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The Norwegian Oil and Gas Association (Norwegian Oil and Gas) welcomes this roadmap to better facilitate market entry of renewable and low-carbon gases in the EU. Well-functioning markets for these commodities will be crucial to achieve the climate targets, and the industry in Norway can be a safe and reliable partner for the EU in achieving these goals.

Solvay answer. The new hydrogen and gas markets decarbonisation package needs to enable the supply of clean, competitive and secured gaseous energy 1) Competitive access to renewable gas and green hydrogen will be key to reach carbon neutrality in the EU Green hydrogen production will need to be competitive before becoming a viable alternative to conventional energy and should not bear high surcharges for industrial…

IOGP response to the roadmap and inception impact assessment concerning revision of the 3rd Gas Package (Directive 2009/73/EC and Regulation No 715/2009) IOGP recommends that the impact assessment considers the following as the basis for its amendment consideration: • Ensure that the regulatory framework for decarbonisation of the gas sector builds on the achievements of the Internal Gas Market.

ENTSOG welcomes EC’s analysis of hydrogen and gas markets and agrees in principle with the identified problem areas. Key ENTSOG statements: 1. Infrastructure will serve as driver for competitive hydrogen markets 2. Building on similar legislative principles, preferably by integrating hydrogen into the gas legislation, is relevant for current stage of hydrogen development 3.

Our observations: • The introduction of binding renewable/decarbonisation gas targets should be assessed to meet the objectives and policies identified • Renewable gas should be encouraged to enter the system and the gas market, through existing gas infrastructure and platforms.

The Norwegian Oil and Gas Association (Norwegian Oil and Gas) welcomes this roadmap to better facilitate market entry of renewable and low-carbon gases in the EU. Well-functioning markets for these commodities will be crucial to achieve the climate targets, and the industry in Norway can be a safe and reliable partner for the EU in achieving these goals.

To ensure relevance of the revision of EU rules on market access for the EU's climate objectives as well as to enable smooth delivery of objectives 2,3 and 4 of the planned initiative- particularly to level the playing field and ensure robust consumer rights - we recommend a mandatory methane emissions performance standard effective on all gas sold in the EU's market as of 1 January 2025 and inspired by the OGCI…

Turboden S.p.A. welcomes the publication of combined evaluation roadmap/inception impact assessment-Hydrogen and Gas markets Decarbonisation Package, which represents an improvement of this sector in the European Energy System.

Assitol, the Associazione Italiana dell’Industria Olearia (Associazione Italiana dell’Industria Olearia), represents, among others, undertakings which produce and/or process and/or import oils and fats of vegetable and animal origin for purposes other than food, including the production of renewable electricity from sustainable bioliquids. Joins Confindustria and the European federations of the sectors represented.

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