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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.

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.

EDF welcomes the European Commission proposal for a Regulation on the deployment of alternative fuels, as part of the “fit for 55” package. The transport sector should indeed decrease its GHG emissions drastically to reach the renewed climate objectives enshrined within the EU Green Deal and carbon neutrality by 2050.

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.

According to latest IEA data, there were around 70 million tons of methane emitted to the atmosphere from oil and gas operations in 2020, this is broadly equivalent to total energy-sector emissions of the entire EU. EDF would like to highlight that the impact of methane is 30 times that of C02 on a 100 year time horizon, but it is ca. 85 times that of CO2 over a 20 year time span (1) .

• 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.