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The current directive fails to mitigate the environmental impact of transport, since many of the alternative fuels currently allowed emit CO2 since some of them are pure or derivate fossil fuels. The current directive does not set the adequate framework to achieve long-term EU CO2 emissions reduction objective, as it does not adequately support the deployment of zero emission mobility.

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.

The ‘Fit for 55’ package paves the way for the implementation of the EU Green Deal, this set of legislative revisions represents a unique opportunity for Europe to take a step forward and win the climate race. That is why now it is the time to show steadfast commitment and prioritize the most efficient, sustainable and cost-effective pathways to decarbonize the economy.

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.

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.

Enel welcomes the Commission communication on an EU Methane Strategy and the further proceedings on a legislative proposal to reduce EU-related methane emissions from fossil fuels, as both acknowledge methane as a relevant contributor to GHG emissions. Methane emissions contribute with a relevant share (approx. 15%) to global GHG emissions.

Enel welcomes the Commission proposal on a Regulation on methane emissions reduction in the energy sector as a first step to tackle the significant contribution of methane to GHG emissions, but greater efforts are needed if the EU wants to lead global methane emissions reductions.

• 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.