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The Directive 2012/27/EU on energy efficiency (EED) revised in 2018 is a key element to achieve the European Green Deal objectives, with the Renewable Energy Directive (RED) and the European Emissions Trading System (EU ETS).

Synergrid is the Belgian association representing all Belgian TSOs and DSOs (electricity and gas). In our response we are focussing mainly on article 25 about energy transformation, transmission and distribution in the recast EED. Synergrid can comfortably state that energy efficiency runs already for many years through the ‘veins’ of its member companies.

EDF welcomes the revision of the EED, which is an opportunity to ensure that it is fully aligned with Green Deal objectives and coherent with the EU ETS, the RED, the EPBD, the ETD, the Energy System Integration Strategy, and the Renovation Wave strategy. Nevertheless, these legislative works have to be done with a focus on affordability, taking into account the most cost effective way to reach the climate targets.

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.

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.

Synergrid, Association representing the Belgian gas TSO Fluxys and DSO’s Fluvius, Ores, Resa and Sibelga welcomes the possibility to provide feedback to this public consultation and acknowledge the efforts of the EC to accelerate methane emissions reduction to support the EU’s climate ambition for 2030 and its 2050 climate neutrality objective.

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) .

Synergrid is focusing in its response on the: • Regulation on methane emissions reduction in the energy sector. 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. Amended text proposals can be found in the Annex I (still in elaboration). Paper in attachment.

EDF recognizes that the revision of the Gas Directive & Regulation is needed to adapt the regulatory framework to the necessary changes in the gas system to progress towards a decarbonised Europe, while preserving the fundamentals of the current market structure.

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.