PGNiG S.A.

GENERAL COMMENTS • Increasing the share of renewable energy in the EU's gross final energy consumption may result in administrative, economic as well as technology burdens for energy sector. Therefore, it is of key importance to ensure technology-neutral approach that will enable taking an advantage of more affordable solutions such as low carbon technologies e.g. low-carbon hydrogen and biomethane/biogas.

GENERAL COMMENTS • Reducing emissions in buildings should be carried out in the most cost-effective and technically feasible way possible, without excessive socio-economic burden. It should be ensured that the process of buildings’ renovation takes into account the needs and interests of groups vulnerable to energy poverty, each Member State’s (MS) development level as well as existing infrastructure.

PGNiG S.A. welcomes the opportunity to comment on the European Commission roadmap of Climate Law, which will be proposed by March 2020. We support efforts aimed at reducing emissions of greenhouse gases, however we point out the necessity of addressing climate change in a technology-neutral and cost-efficient way. Especially we find natural gas as the low-hanging fruit in transition towards cleaner energy.

GENERAL COMMENTS • Defining compressed natural gas (CNG) and liquefied natural gas (LNG) as transition phase fuels and limiting infrastructure commitments only to LNG and until 1 January 2025 may result in a time-limited support for these technologies and hamper the development not only of the bioLNG and bioCNG sector, but also projects developed for mixtures of hydrogen and natural gas.

GENERAL COMMENTS • Currently, transport sector accounts for a quarter of the UE’s greenhouse gas (GHG) emissions and this value continues to grow. • Natural gas (LNG/CNG) powered vehicles reduce GHG emissions of approximately 20-22% (sum of CO2, CH4 and N2O) and produce three times less NOx compared to gasoline or diesel vehicles. LNG-fuelled ships emit up to 100% less PM, up to 80% less NOX and up to 100% less SOX.

• TEN-E should continue to support natural gas projects as it could play an important role in delivering clean and affordable energy in the transitional period; • The significant development of clean gases influences future role of the existing natural gas infrastructure as it may be used to transport renewable gases and hydrogen and back-up the variable power generation; • Increase in demand for natural gas should…

• Taking into account stringent obligations set out in Regulation, it is reasonable to set a 5 years deadline for full implementation the provisions of Regulation. • The „measurement” term should be replaced with „quantification” throughout the text of the regulation in order to allow additional instruments for better estimation of methane emissions. • The proposed term "component" in Article 2(8) is not defined.

GENERAL COMMENTS • EU legislation may lead to increased revenues, but also significant costs, for energy companies. However, to assess that, precise cost analyses must be conducted. Cost-efficiency should be at the heart of any policy planning. • All measures related to the reduction of methane emissions should be reasonable but not overly prescriptive to avoid excessive financial and technical burdens.

Acknowledging growing concerns about the distortions caused by foreign subsidies within the Internal Market, the initiative undertaken by the Commission to present proposal of regulation in order to address these interventions generally and also in the specific cases of acquisitions and public procurement is highly welcomed.

GENERAL COMMENTS • Social Climate Fund intends, inter alia, to support the integration of renewable energy sources. However, it is of key importance to ensure technology-neutral approach that will enable taking advantage of more affordable solutions such as low carbon technologies e.g. all types of hydrogen and biomethane/biogas.