Enagás

Enagás welcomes the European Commissions proposal for the Industrial Accelerator Act (IAA) as a clear signal of commitment to accelerating industrial decarbonisation while reinforcing Europes industrial competitiveness. The IAAs effectiveness will ultimately depend on its ability to ensure a coherent framework that enables scalable and bankable decarbonisation pathways across industrial value chains.

Enagás is the natural gas transmission system operator and provisional hydrogen transmission network operator in Spain. Additionally, Enagás is actively engaged in Carbon Capture, Utilisation, and Storage (CCUS) projects, with a particular focus on CO2 transmission.

Enagás welcomes EC’s ambition to increase the overall target for renewable energy to 40%, as well as introducing/adjusting several sector-specific sub-targets. The new Directive (REDIII) represents an opportunity to develop renewable and low carbon gases in order to achieve carbon neutrality on a cost-efficient way.

Enagás welcomes this EC’s initiative for a Regulation. To ensure an ambitious, but implementable Regulation, we would like to share some recommendations: • The EU shall establish a common standard for carbon removals, with a smooth and clear interaction with (i) the EU ETS, as avoided greenhouse gas shall not pay a carbon price, and (ii) a system of guarantees of origin to trace the production and consumption of…

Energy efficiency improvement is a key lever of the European transition towards a neutral economy. However, measures should be coherent and guided by cost-efficiency so to do not jeopardize energy supply and consumers bills.

Enagás supports a revision of the ETD. The current directive has been in place since 2003 and is outdated. As part of the ‘Fit for 55’ package, a common EU-framework on the taxation of energy products is necessary for the smooth functioning of the energy market, to take account of the new energy mix and to deliver on the EU’s climate ambitions.

Enagás the natural gas transmission system operator and provisional hydrogen transmission network operator in Spain welcomes the opportunity to share its thoughts on the renewable energy legal framework post-2030.

Enagás fully supports the establishment of a robust and forward-looking legislative framework to deliver the 2040 climate target. The company is committed to playing an active role in the decarbonisation of the European economy through the development of renewable hydrogen infrastructure, the transformation of existing assets, and the deployment of innovative solutions across the energy value chain.

Enagás welcomes this Commission’s initiative and its invitation to provide our opinion on the proposal for a Regulation of the European Parliament and of the Council amending Regulation (EU) 2016/1011 on low carbon benchmarks and positive carbon impact benchmarks. In general Enagás supports the amendments and the text inserted.

Enagás welcomes the Commission initiative to upscale the Union industrial capabilities amid the complexities and opportunities of increasing global industrial competition. At the same time, it should ensure a sustained cost reduction for key technologies as a central condition for the continent to effectively transform its value chains and remain competitive.

Enhanced ambition regarding road transport emissions is one of the key levers towards carbon neutrality of the EU. They represent almost 20% of total EU GHG emissions, and have significantly increased since 1990.

Enagás welcomes the Commision's legislative proposal. Please find below our comments (amendments attached): 1. Vertical unbundling: the ownership unbundling model should be favoured … since it is the most effective one and entailing less regulatory monitoring efforts. Enagás supports the proposal for HNOs and encourages to foresee a transition for gas TSOs to OU by 31 Dec 2030.

Enagás welcomes the Commision's legislative proposal. Please find below our comments (amendments attached): 1. Vertical unbundling: the ownership unbundling model should be favoured … since it is the most effective one and entailing less regulatory monitoring efforts. Enagás supports the proposal for HNOs and encourages to foresee a transition for gas TSOs to OU by 31 Dec 2030.

1. Application of Internal Energy Market principles to the future H2 market Regulatory intervention for H2 networks is justified on economic grounds. Incorporating the rules for H2 in the gas legislation would be the most efficient way of ensuring regulatory alignment between H2 and CH4. 2.

Fast-track PCI renewal. Enagás proposes a simplified renewal process for PCIs with no significant changes, avoiding full reassessment and reducing administrative burdens Allow the request the CEF-E funds for works in parallel with the approval with the CBCA. Allowing conditional CBCA agreements would accelerate funding access and reduce delays.

Fuelling infrastructure plays a critical role on the decarbonisation pathway of the transportation sector. Further emission reduction will require a decisive participation of all technologies from today towards 2050, where renewable and low-carbon fuels are called to play an increasingly relevant role.

The EU Aviation Strategy represents a unique opportunity to accelerate the transition towards a sustainable, competitive and resilient European aviation sector. By explicitly integrating civil aviation, aerospace and defence considerations, and by addressing financing gaps, facilitating the large-scale deployment of SAF and e-SAF, and supporting the timely development of enabling hydrogen infrastructure, the…

Air transportation is an increasingly growing industry; it became a backbone of citizen’s mobility across borders and central asset for local businesses like tourism, from which several regions depend upon. With the coming of just-in-time logistics, aviation now also plays a key role on agile supply chains across the globe. Aviation currently contributes to the order of 2.4% of global emissions [1][2].

Please find attached Enagás' feedback on the legislative initiative concerning CO transportation infrastructure and markets. A summary of the key points is provided below. To ensure the successful deployment of CO2 infrastructure and the emergence of a well-functioning European CO2 market, it is essential to adopt a pragmatic and flexible approach.

Enagás would like to highlight the following key messages: Inclusion of renewable & low-carbon hydrogen in the TEN-E - The focus of the TEN-E as regards new gases should be on renewable hydrogen Energy infrastructures categories - Enagás welcomes the introduction of new categories concerning H2, electrolysers and smart gas grids - TEN-E should clearly support the repurposing of existing natural gas pipelines…

The EU is assessing at carbon neutrality by 2050. Considering the combination of renewable electricity and cleaner gases will be possible to retain the level of the EU economy is possible. The role of Clean Gases, in particular Clean Hydrogen, in the decency should not only be carried out in the benefit, but they should be allowed to be allowed to be used by subsidiarity, but should be the most long term in the long…

Filed in Spanish · English published by the European Commission

Enagás welcomes this EC’s Proposal for a Regulation. To ensure an ambitious, but implementable Regulation, we would like to share some recommendations: As technologies, methodologies and practices evolve very quickly, we recommend to ensure flexibility to prioritise the most effective measures.

Enagás acknowledges the opportunity to provide feedback on this inception impact assessment. We fully support the EC efforts to accelerate methane emissions reduction from all sectors to contribute to the EU’s greater climate ambition for 2030 and its 2050 climate neutrality objective.

Enagás welcomes the European Commissions initiative to revise Annexes V and VI of Directive (EU) 2018/2001 and supports the effort to improve the accuracy, transparency and regulatory consistency of greenhouse gas accounting for biomethane, bioLNG and associated logistic pathways.

Enagás welcomes the European Commissions initiative to revise Regulation (EU) 2018/1999 on the Governance of the Energy Union and Climate Action. Security of supply (SoS) should be more clearly integrated as a core pillar of the Governance framework.

Enagás appreciates the opportunity to contribute to the European Commissions review of the EU energy security framework. Please find attached our response, which highlights areas where the current regulation could be enhanced to better address emerging risks, strengthen security of supply, and support the energy transition.

From the point of view of a large enterprise, on the Connecting Europe Facility 2021-2027, I consider the following comments: 1- the political scope of the mechanism has a significant and therefore positive impact. It really helps companies minimise their risk by investing in sustainable mobility. 2- the organisation of CET -T, AFIF, etc. is professional and the management of CINEA positive.

Filed in Spanish · English published by the European Commission

The "FuelEU Maritime" initiative is an excellent opportunity to promote the use of alternative fuels, thus allowing to help the decarbonization of maritime transport in line with the objectives of IMO (International Maritime Organization) and the EU.

The "FuelEU Maritime" initiative is an opportunity to further develop LNG as an alternative fuel, in order to achieve Green Deal objectives in maritime transport and port areas. Regarding the analyzed barriers, LNG is part of the solution, based on: PREDICTABILITY & INVESTMENTS Investment risk exists for any fuel, so shipowners need certainty about which fuels they can use and which are available in ports at a…

While the “Sustainable and Smart Mobility Strategy" reveals the main guidelines towards a neutral emission mobility in the forthcoming decades, a transparent and common European methodology is still needed. “CountEmissions EU” is a largely expected initiative that can contribute to the transparent and widespread comparability of GHG emissions.

Enagás' feedback is aligned with the responses of NGVA & GASNAM. Air quality, especially in urban areas, is one of the key objectives to ensure health protection and reduce social costs. In this road transport sector has an important role to play together with other parallel actions to reduce traffic congestion and optimize freight logistics and personal mobility models In view of the revision of the current…

Enagás welcomes the Commision's legislative proposal. Please find below comments (amendments in pdf attached): 1. Vertical unbundling: the ownership unbundling model should be favoured … since it is the most effective one and entailing less regulatory monitoring efforts. Enagás supports the proposal for HNOs and encourages to foresee a transition for gas TSOs to OU by 31 Dec 2030.

Enagás welcomes the revision of the Combined Transport Directive; combined freighting offers a unique opportunity to cut down emissions through the reduction of duplicated and scattered means of transport that cannot easily scale. At the same time, this effort can drive down transport costs per ton substantially.

Enagás welcomes the opportunity to contribute to the public consultation on the draft REMIT Implementing Regulation. This summary highlights the most relevant points. Additional analysis and legislative proposals are included in the attached document. 1.

Enagás welcomes the opportunity to contribute to the public consultations. The following main ideas are further elaborated in the attached document: 1. Inclusion of hydrogen in the energy security architecture Enagás considers that the EU energy security framework should cover electricity, gas and hydrogen to support the transition to a sustainable energy system. 2.

From the point of view of a large enterprise, on the Connecting Europe Facility 2021-2027, I consider the following comments: 1- the political scope of the mechanism has a significant and therefore positive impact. It really helps companies minimise their risk by investing in sustainable mobility. 2- the organisation of CET -T, AFIF, etc. is professional and the management of CINEA positive.

Filed in Spanish · English published by the European Commission

As regards the Directive, Enagás would like to send the following messages: • “In order to verify compliance with the Directive, control mechanisms (inspections, monitoring, audits, request for information...) shall be put in place” — > Certification in certain international regulations related to resilience should be taken into account as evidence of such compliance in order to reduce the administrative burden on…

Filed in Spanish · English published by the European Commission

Enagás welcomes the opportunity to provide feedback on the evaluation roadmap of the 2014 Alternative Fuels Infrastructure Directive. Natural gas will have an important role in the future to contribute to the decarbonisation of the transport sector. CNG/LNG in the transport sector is already a reality as well as its high availability, flexibility and scalability.

Enagas welcomes the European Commissions proposal to amending Regulation (EU) 1227/2011 and Regulation (EU) 2019/942, as part of the revision of the electricity Market Design. As a general overview, Enagás point of view is that: - some of the amendments proposed to REMIT revision are not directly linked to the Electricity market Design, and should not be linked to it; - some of the amendments proposed comes from the…

Enagás, the Transmission System Operator for natural gas and provisional hydrogen transmission network operator in Spain, welcomes the opportunity to share its thoughts on ACER evaluation. ACER Framework Guidelines & Network Codes: more flexibility required. ACERs Recommendations: Legal consistency with binding EU legislation. ACERs role under REMIT framework: interpretative clarity under the REMIT framework.

Welcome the Commission’s legislative proposal. Please find below a summary of commitments (amendments and detailed justifications agreed): 1a Mandatory Filling target of 80 % is fit for purpose to ensure the use of gas storage as a fundamental element of a comprehensive security of supply policy.

Filed in Spanish · English published by the European Commission

Public Consultation Proposal for a regulation Multiannual Financial Framework: Connecting Europe Facility 2021-2027 Enagás comments NON-CONFIDENTIAL RESPONSE 27th July 2018 Public consultation on the Proposal for a regulation Multiannual Financial Framework: Connecting Europe Facility 2021-2027 Enagás comments 1 NON-CONFIDENTIAL RESPONSE Introduction a) Enagás welcomes to this opportunity to contribute to the public…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)