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Deutsche Umwelthilfe (DUH) would like to stress that currently, the EED, like the other elements of the Clean Energy for All package, are inconsistent with the ambition of the Paris Agreement, as action in the next 10 years will be decisive in reaching the 1.5°C objective. We fully support the initiative to revise the EED and stresses that the ambition level needs to increase significantly.

GAZ-SYSTEM welcomes the opportunity to express its views in the public consultation on the proposal for a directive on energy efficiency (hereafter EED). Energy efficiency is a key tool to achieve emission reduction targets and use more effective technologies.

Strengthening of the Energy Efficiency Directive DUH is calling for the adoption of a binding energy efficiency target of at least 45 % in the year 2030 (compared to the EU Reference Scenario 2007 or of at least 20 % in 2030 compared to the EU reference scenario 2020). This will help to achieve the 1.5°C target of the Paris Agreement, improve the energy security of the EU, create jobs, and reduce pollution.

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…

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.

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.

Regulation (EU) 2022/869 (TEN-E) plays an important role in facilitating the development of the European energy networks. The application of dedicated regulatory measures foreseen in TEN-E for the PCI projects together with the possibility for financial assistance under Regulation (EU) 2021/1153 (CEF) has proven useful and successful to accelerate the implementation of projects in the gas sector.

Deutsche Umwelthilfe / Environmental Action Germany welcomes the opportunity to comment the EU Grid Package. We would like to draw attention to one specific concern: the role of electricity DSOs. While grid expansion and modernisation is indeed necessary at DSO level, it is time and money consuming.

Deutsche Umwelthilfe / Environmental Action Germany welcomes the opportunity to comment on the initiative at this stage. Regulating methane emissions in the oil, gas and coal sectors is indeed a powerful tool and necessary in mitigating GHG emissions and meeting climate targets.

GAZ-SYSTEM welcomes the possibility to provide comments to the European Commission proposal on new rules to prevent methane emissions. Herein, we would like to highlight the main points that in our view should be taken into consideration while working on the subject legislation. Broader explanation is attached in the pdf file.

Environmental Action Germany (DUH e.V.) welcomes the Methane Regulation proposal as it will for the first time impose binding rules regarding methane leakage on operators of energy infrastructure within the EU. Particularly positive are the new provisions on Measurement, Reporting and Verification (MRV) of methane emissions, regular inspections by regulatory agencies, as well as the requirement of quarterly Leak…

Environmental Action Germany welcomes the opportunity to comment on this EC initiative. We wish to make the following comments: 1. Crop biofuels are more damaging to the climate than fossil fuels. Crop biofuels must be phased out entirely and must not be incentivised for use in shipping. 2. Advanced biofuels based on wastes and residues are not automatically sustainable.

GAZ-SYSTEM Capital Group supports the European Commission's plan to accelerate the implementation of low-carbon shipping and port operations by supporting the deployment of alternative, sustainable energy sources and vessel propulsion. In terms of climate and air quality, LNG in the maritime sector should and will play a key role in achieving these goals.