Swedish Gas Association / Energigas Sverige

The Swedish Gas Association – Energigas Sverige, the industry organisation in Sweden – is thankful for the invitation to contribute comments on the Commission’s revision of the Renewable Energy Directive (hereafter called RED III), 14 July 2021. The Swedish Gas Association has only had a short time to examine the proposal, and thus has only been able to analyse it a limited amount of detail.

The Swedish Gas Association supports the Commission's proposal to revise the EU ETS so that the regulations are in line with the goal of reaching net greenhouse gas emission reductions of at least 55% compared to 1990 levels, by 2030. According to the stated proposal, the combustion of biofuels will continue to be assigned an emission factor of zero, and will therefore not be affected by emission allowance costs.

The EU Emissions Trading Scheme, EU ETS, aims to reduce fossil emissions in the most cost-effective way. But this is not possible for industries and energy production plants that use fossil gas as a fuel and gradually choose to switch to renewable gases such as biogas or bio-LPG. The reason is that there are shortcomings in the current EU ETS regulations.

The Swedish Gas Association – Energigas Sverige – welcomes a review of the Energy Tax Directive (ETD). The current ETD is an outdated directive from 2003 that does not reflect the EU’s climate goals. We welcome the position taken in “Fit for 55” that regulations should work better together but it is a challenge that so many directives are being changed at the same time while also referring to each other.

The Inception Impact Assessment points out that the ambitious EU Climate ambition requires effective carbon pricing and the removal of fossil fuel subsidies. It also specifies that well-designed taxes play a direct role by sending the right price signals and providing the right incentives for sustainable practices of producers, users and consumers.

We welcome strict requirements in the EU’s CO2 emission performance standards, but we believe that EU legislation should be built around research-based well-to-wheel or life-cycle analysis on climate emissions. We are very critical of the persisting with the tailpipe approach, as proposed by the Commission.

The EU has committed itself to carbon neutrality by 2050. The Swedish Gas Association supports this commitment, and we are convinced that all sustainable technologies will be needed if the EU is to have a chance of succeeding. This is especially true for the decarbonization of the transport sector – one of the biggest challenges of the EU Green Deal.

The Swedish Gas Association welcomes the EU’s ambitious comprehensive approach to climate policy. The climate package “Fit for 55” is an important big step in reducing emissions by at least 55 per cent by 2030 and achieving climate neutrality by 2050 – two urgent targets that the Swedish Gas Association fully supports and stands behind.

It is important that the EU- regulation help and not risk hindering the EU Member States to reach energy, environmental and climate goals. In line with the Green Deal Strategy, energy markets will need to transform to enable moving towards a net zero target, and it is important that these objectives can be realised in a non-disruptive and cost-effective manner.

The Swedish Gas Association welcomes an ambitious expansion of infrastructure for electric and hydrogen vehicles, but we believe that biomethane should be addressed with the same level of ambition. This is not the case with the Commission’s proposed regulations, even though biomethane is one of the market’s most sustainable and cost-effective alternative fuels.

Using Biomethane for Transport Improves air quality and can lead to carbon neutrality. In Sweden, the share of Biomethane in Gas used for transport is 94 %. Renewable methane is already produced in incremental revolution in most European countries; The technology is ature and Biomethane Profits derived from the existing natural gas infrastructure in Europe. This means that we do not have to wait for the future.

Filed in Swedish · English published by the European Commission

The Swedish Gas Association welcomes the Commissions efforts to decarbonize the transport sector. To ensure the success of this transition, The Swedish Gas Association stresses the need to implement a revision of the CO2 emission standards for cars and vans regulation that seeks a truly technology-neutral approach.

The Swedish Gas Association – Energigas Sverige – considers the proposal to be basically well-designed and is generally positive about it. We also believe that the proposed rate of reduction of greenhouse gases appears appropriate, in light of the climate targets set up by the EU. We welcome clear rules and requirements because they eliminate doubts and uncertainties.

We strongly welcome the intention of the EC proposal, i.e., to curb the GHG emissions from the heavy-duty road transport segment. However, it is of great concern that the proposal does not provide for a level playing field among technologies and favors a limited number of solutions, regardless of their footprint.

We welcome the initiative to review current CO2 emission standards for heavy-duty vehicles and to set more ambitious emission reduction targets for such vehicles. We also want to stress that EU legislation, including CO2 emissions standards regulation, should be built around research-based well-to-wheel or life-cycle analysis on climate emissions.