ENTSOG

ENTSOG (European Network of Transmission System Operators for Gas) welcomes the European Commission’s legislative proposal COM (2021) 557 on the revision of the Renewable Energy Directive and would like to support the future legislative process with the following comments and proposed changes (please see attached). We hope our contribution will help policymakers better assess available policy options.

ENTSOG is the European Association of Gas Transmission System Operators. With this response we would like to propose amendments to Renewable Energy Directive 2018/2001 (RED II) and, by doing so, advocate for Option 4 of the Inception Impact Assessment which is to ‘amend RED II to translate into legal measures the actions proposed in other energy strategies of the European Green Deal’.

The European Network of Transmission System Operators for Gas (ENTSOG) believes the EU Emissions Trading System (ETS) can give clear price signals to support decarbonisation and to meet the more ambitious climate targets for 2030, recently laid out by the EU Commission. ENTSOG recognises the need to adapt the EU ETS to align with these targets and possibly extend the scope of the EU ETS.

ENTSOG welcomes the European Commission’s publication of the recast Gas Regulation but finds there is need for certain amendments to achieve EU goals. ENTSOG welcomes the EC’s proposal to allow financial transfers between regulated services for gas and hydrogen as one way to finance the hydrogen network. However, there should be some degree of flexibility for Member States in this matter.

ENTSOG welcomes EC’s analysis of hydrogen and gas markets and agrees in principle with the identified problem areas. Key ENTSOG statements: 1. Infrastructure will serve as driver for competitive hydrogen markets 2. Building on similar legislative principles, preferably by integrating hydrogen into the gas legislation, is relevant for current stage of hydrogen development 3.

ENTSOG welcomes the fact that the upcoming package will look at supporting the development of hydrogen and CO2 infrastructure and overcoming barriers to investment. We also agree that the cost-efficiency of the energy transition will worsen if sub-optimal and slow infrastructure development are left unaddressed.

ENTSOG appreciates the opportunity to provide early feedback on the forthcoming Electrification Action Plan. Below we react directly to the assertions in the call for evidence. We recognise the need for further electrification to reach net-zero, as outlined in our joint scenario work with ENTSO-E. However, molecules play a key role for flexibility, stability and affordability.

The European gas grids have contributed to EU energy security, competitiveness and liquidity of EU markets. While sustainability has become a key objective for EU’s energy sector, the objectives related to Internal Market and SoS are still cornerstones in EU energy policy.

Since its foundation in 2009, the European Network of Transmission System Operators for Gas (ENTSOG) contributed to EU’s energy objectives: development of the EU Internal Energy Market and security of energy supply.

ENTSOG amendments to the regulation amending the electricity regulation and directive are focused on specific proposals laid down by the EC in order to: 1/ease the approval process of Capacity Mechanism and make it more permanent, 2/ make clear that electrolysers and gas-fired power plants, in other words, sector integration, are part of the solution to fill the flexibility needs of the power sector, valuating the…

ENTSOG welcomes the European Commission’s publication of the recast Gas Directive but finds there is need for certain amendments to achieve EU goals. The introduction of a system of financial compensation to ensure financing for cross-border hydrogen infrastructure (effectively an ITC mechanism for hydrogen) would be unnecessarily complex and overly burdensome.

ENTSOG was founded in line with Regulation (EC) 715/2009 and has played a key role in facilitating integration of the European gas markets, ensuring technical interoperability, and providing security of supply by gas infrastructure planning.