Czech Gas Association

Buildings: CGA considers the nature and the level of the newly proposed binding target for Member States as regards the share of RES in heating and cooling by 1.1 pp/per year as unachievable in the given conditions of the Czech Republic. We are afraid that unrealistic targets would fail reaching even lower, still realistic targets.

The Czech Gas Association welcomes the opportunity to comment on the recast of EPBD. Below we highlight our key positions, the full assessment of the proposal is attached in the annex. In our opinion, the present proposal of the recast of EPBD is an important part of the proposals to meet the EU's ambition to achieve climate neutrality goals by promoting the use of low-emission and zero-emission technologies in the…

The ČPS generally disagrees with the increased reduction in the values for free allocation of emission allowances for industry and energy. We call for the current legislation in this area to be left intact and for the revision to be rejected in its entirety.

Filed in Czech · English published by the European Commission

● The proposed target under Article 8 to be applied as of 2024 is perceived as a hardly achievable limit in terms of the capacity of the Czech economy and households. As regards the newly proposed commitment - almost doubled annual cumulative final energy savings for the Member States (i.e. 1.5 pp per year) - we oppose its binding nature and „one-size-fits-all“ approach to Member States.

Removal of the exception for the financing of fossil fuel-fired district heating (DH) in certain Member States from the Modernization Fund may hinder transformation of the DH (the so-called coal-to-gas switch) and is not in line with a cost-effective decarbonization pathway of the Czech Republic, which threatens the fulfillment of the Czech Republic's future climate and energy commitments.

The Czech Gas Association (hereinafter CGA) is an independent association of companies and experts operating in the gas and related industries. It brings together organizations active in the gas industry, along with research and scientific institutes, and further comprises experts whose specialization corresponds to the focus of the CGA.

• Given the recast of Council Directive 2003/96/EC restructuring the Community framework for the taxation of energy products and electricity, Czech Gas Association calls for an optional exemption (in the form of total or partial tax exemptions below the minima as in the current Art. 15h) to be maintained for all low- and middle-income households using natural gas for heating at least until 2033.

Reply of the Czech Gas Association to the public consultation of the European Commission on the revision of directive 2003/96/EC restructuring the Community framework for the taxation of energy products and electricity The Czech Gas association would like to hereby express its opinion on the revision of the Energy Taxation Directive as currently presented by the European Commission in the Inception Impact…

• CGA argues for a change in the methodology for environmental impact assessment of vehicles from "tank-to-wheel" approach, i.e. emissions measured on the tailpipe to "well-to-wheel" approach or "life-cycle assessment" with an open cycle taking into account the so-called "end-of-life" of vehicles.

The Czech Gas Association (hereinafter CGA) is an independent association of companies and experts operating in the gas and related industries. It brings together organizations active in the gas industry, along with research and scientific institutes, and further comprises experts whose specialization corresponds to the focus of the CGA.

The Czech Gas Association welcomes the opportunity to comment on the recast Gas Regulation. Below we highlight our key positions, the full assessment of the proposal is attached in the annex. 1) The proposal defines two separate systems. The requirements applicable to one system are, for the most part, different from those applicable to the other.

The Czech Gas Association (CGA) welcomes the possibility to comment on the inception impact assessment on the revision of the Gas Directive and Gas Regulation and would like to express its opinions on the Hydrogen and Gas markets Decarbonisation Package.

• The proposal for the revision of Directive (EU) 2014/94 of the European Parliament and of the Council on the deployment of alternative fuels infrastructure under Article 2(3) introduces a new classification of the alternative fuels in sub-paragraphs (a), (b) and (c) on the basis of sub-definitions.

The Czech Gas Association (CGA) welcomes the Commission's proposed revision of the current TEN-E Regulation to better reflect the new political context and the goals of the European Green Deal. The CGA would like to make some comments and suggestions of substance aimed at improving the effectiveness and functioning of the revised approach.

The Czech Gas Association (CGOA) welcomes the European Commission’s plan to revise the current TEN-E Regulation, which should support the utilisation of existing gas infrastructure and recognise that gas infrastructures are already capable of transporting new gases and can be progressively developed, adapted or repurposed to further accommodate these gases.

The Czech Gas Association supports the joint position of ENTSOG, Eurogas, GERG, GIE, and MARCOGAZ. In addition to the position, we would like to provide the Commission with the attached document to offer an extended fact-based reasoning and to support some of the key points: 1) A prescriptive regulation of LDAR parameters does not guarantee a reduction in methane emissions.docx 2) The benefits of using a…

The Czech Gas Association would like to share its experience and views on the topic of methane emissions with special focus on its area of expertise – the gas sector. From the gas business perspective, methane emissions have been primarily related to security concerns because natural gas leaks could pose a significant safety risk.

The Czech gas association is of the opinion that the Regulation should promote the use of renewable fuels and synthetic fuels in line with the Fit for 55 legislations, specifically the Renewable Energy Directive (RED) and REPowerEU. Both RED and REPowerEU promote and set targets for the use of advanced biofuels and biomethane.

The Czech Gas Association welcomes the opportunity to comment on the recast Gas Directive. Below we highlight our key positions, the full assessment of the proposal is attached in the annex. 1) The proposal defines two separate systems. The requirements applicable to one system are, for the most part, different from those applicable to the other.

We appreciate the opportunity to provide feedback on relevant issues for the impact assessment and ask to consider attached position of the Czech Gas Association in detail during the impact assessment. We would like to stress out that we welcome the possibility to indicate future H2-ready appliance on the upcoming energy label.

• CGA is of opinion that the establishment of the SCF represents unnecessary transaction costs (setting up Social Climate Plan, its administration etc.) for the Czech Republic, in contrast to the direct national redistribution of finances (e.g., lower income tax, VAT, lump sum transfers), respectively the establishment of a national fund.