Side by side
Consultation participation and their own register declarations, side by side. Counts, not judgments — participation is not influence.
Counts here are a floor, never a total: they cover the 583 consultation files tracked so far (42,224 submissions, mostly 2025–26), so an organization's real filing history is larger, not smaller.
Company · Poland
NGO · Germany
Declared costs: not declared · in the register since 2012
Deployment of alternative fuels infrastructure · Methane emissions reduction in the energy sector
Register facts self-declared (snapshot 2 Sept 2026); cost bands are floors. Shared files are shared attention, not evidence of coordination.
Their opening passages on the files they share, verbatim and in filing order. We do not summarize, compare, or characterize positions — read them at source.
PGNiG S.A. · filed 4 May 2020 · source
GENERAL COMMENTS • Currently, transport sector accounts for a quarter of the UE’s greenhouse gas (GHG) emissions and this value continues to grow. • Natural gas (LNG/CNG) powered vehicles reduce GHG emissions of approximately 20-22% (sum of CO2, CH4 and N2O) and produce three times less NOx compared to gasoline or diesel vehicles. LNG-fuelled ships emit up to 100% less PM, up to 80% less NOX and up to 100% less SOX.
PGNiG S.A. · filed 18 Nov 2021 · source
GENERAL COMMENTS • Defining compressed natural gas (CNG) and liquefied natural gas (LNG) as transition phase fuels and limiting infrastructure commitments only to LNG and until 1 January 2025 may result in a time-limited support for these technologies and hamper the development not only of the bioLNG and bioCNG sector, but also projects developed for mixtures of hydrogen and natural gas.
Deutsche Umwelthilfe e.V. · filed 18 Nov 2021 · source
The revision of the AFIR offers the opportunity to set an important course for a change of engines towards a sustainable transport sector. We support the rapid development of the infrastructure in order to enable a faster conversion to electric motor operation.
Deutsche Umwelthilfe e.V. · filed 25 Jan 2021 · source
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.
PGNiG S.A. · filed 26 Jan 2021 · source
GENERAL COMMENTS • EU legislation may lead to increased revenues, but also significant costs, for energy companies. However, to assess that, precise cost analyses must be conducted. Cost-efficiency should be at the heart of any policy planning. • All measures related to the reduction of methane emissions should be reasonable but not overly prescriptive to avoid excessive financial and technical burdens.
Deutsche Umwelthilfe e.V. · filed 12 Apr 2022 · source
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…
PGNiG S.A. · filed 15 Apr 2022 · source
• Taking into account stringent obligations set out in Regulation, it is reasonable to set a 5 years deadline for full implementation the provisions of Regulation. • The „measurement” term should be replaced with „quantification” throughout the text of the regulation in order to allow additional instruments for better estimation of methane emissions. • The proposed term "component" in Article 2(8) is not defined.
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