Naturgy

The development of RES is the key instrument for decarbonising the EU economy. The revision of the Directive 2018/2001 is thus needed to adapt it to the increased emission reduction target. To this extent, the provisions related to the revision of existing targets; the inclusion of new sub-targets (e.g.

The revision of the Directive 2018/2001 should set an opportunity to bring untapped emissions considering that much of the legislation covering the 2021-2030 period is being implemented. Gas systems will be critical to embrace new renewable & decarbonized gases progressively replacing natural gas – which will remain as a key energy source- to facilitate the decarbonization of the economy.

Buildings are a hard-to-abate sector. o Huge heterogeneity (demand, building stock, disposable income, etc…) Multitude of technical, economical, and societal barriers, requiring millions of actions and actors involved. o Today, many inefficient appliances and processes use all kind of fuels.

Naturgy welcomes the opportunity to provide feedback on the inception impact assessment for the Energy Performance of Buildings Directive, within the context of the Renovation Wave. Conventional and new Gaseous solutions should be part of the solutions for decarbonising and increasing efficiency in the EU building sector, which represents 40% of total energy consumption.

Energy efficiency is a critical lever for decarbonizing the EU economy. The revision of the Directive is needed to adapt it to the new headline emission reduction target. Measures to promote energy efficiency should be coherent, proportionate and essentially market-driven, while avoiding policy overlaps. Otherwise it may have unintended consequences and risking undermining cost-effective decarbonisation.

Naturgy welcomes the opportunity to submit feedback to the European Commission's proposal to update the EU Emissions Trading System (ETS). The main takeaways of our response focus on the proposed establishment of an adjacent EU ETS for buildings and road transport: - An ETS for buildings and transport would not achieve its decarbonization goals since the price signals would be insufficient and volatile.

Naturgy welcomes the opportunity to give feedback on the review of the Fluorinated Greenhouse Gas Regulation (F-Gas Regulation, 517/2014) regarding the phase out of SF6. Naturgy Group, which includes its electricity distribution system operator UFD, is fully committed with the emission reduction goals established by the EC. Please find below our considerations regarding this public consultation.

• Overall, the Directive and Regulation proposals are much in line with Naturgy’s observations during the consultation process. • We welcome the increased efforts, targets and instruments announced to ensure an early deployment of renewable hydrogen technologies. Hydrogen will be a critical lever in all LT scenarios.

Our observations: • The introduction of binding renewable/decarbonisation gas targets should be assessed to meet the objectives and policies identified • Renewable gas should be encouraged to enter the system and the gas market, through existing gas infrastructure and platforms.

• Some provisions require further adjustment to ensure the proportionality of the measures and the impact they may entail, namely to gas DSOs. The same solutions don’t fit all cases along the supply chain (upstream, transmission, storage, LNG & distribution) due to different technical specificities.

• Overall, the Directive and Regulation proposals are much in line with Naturgy’s observations during the consultation process. • In the REPower EU, the EC has recently proposed a longstanding request of the EU gas industry by defining a 35bcm biomethane gas target for 2030, together with the strengthening of the renewable hydrogen goals.

We welcome the opportunity to participate in the revision of energy labelling framework and appreciate Commissions effort to assess the technical and environmental aspects of space heaters. While we support the objective of improving consumer transparency and accelerating decarbonisation, we believe the draft needs alignment with the broader regulatory framework established by the Energy Performance of Buildings…