Enagás GTS

As the European energy transition moves beyond 2030, the main challenge is no longer the deployment of renewable generation capacity, but its effective integration into the energy system. Higher renewable electricity shares expose daily, seasonal and structural mismatches between supply and demand that cannot be addressed through shortterm flexibility solutions alone.

The document attached provides Enagás GTSs technical feedback on Annex VI of the RED III implementation, focusing particularly on the treatment of biomethane transport, liquefaction and related emissions accounting. A key concern is the lack of clarity and methodological consistency in how virtual liquefaction is addressed.

Enagás GTS is the body responsible for ensuring the security of supply in the Spanish gas system, which involves guaranteeing its proper planning and operation. In carrying out its functions as Technical System Operator, Enagás GTS safeguards the continuous balance between supply and demand, coordinates the operation of gas infrastructures, and prepares preventive and emergency plans.

Please find attached our recommendations in the document attached, that can be summarized as: Extend the transaction timeline beyond three working days to accommodate the complexities of data reporting. Define the triggering point for gas injection in alignment with regulated gas market processes, particularly those related to the balancing network point.