RAG Austria AG

RAG Austria welcomes the inclusion of hydrogen in the EU's climate strategy. Nevertheless, we see a need for improvements in the RED III draft in the following areas: • Technology openness: Ambitious targets can only be achieved in the short term if proven, efficient and economical technologies are allowed on an equal footing; • Imports: Europe will be dependent on secure supplies of green energy from third…

Thank you for the opportunity to provide input to this consultation. Please find our detailed comments attached. Below we briefly outline the key points that are essential for the development and implementation of underground hydrogen storage, particularly in depleted gas reservoirs: 1) Ensure regulatory neutrality - Taxonomy eligibility must not depend on a RAB: Taxonomy criteria should not depend on inclusion in a…

Based on our extensive experience in different decarbonization projects, we would like to recommend in the CRM Act not only to consider rare earths and other metals, but also to define early enough other liquid and gaseous resources (in particular methane [CH4], hydrogen [H2], carbon dioxide [CO2] and solid carbon [C]) as critical raw materials and thus to derive and implement measures for their future supply.

Issues to be improved: 1) Use of adequate terminology: Overall, it is important to differentiate between carbon (C) & CO2-removal activities. These terms are frequently not adequately used. Especially as regards CCS, this is usually explained as carbon capture and sequestration (long-term storage), instead it should be explained as CO2 capture & sequestration to better describe the technological procedure.

RAG Austria AG welcomes the opportunity to provide feedback on the Net Zero Industry Act. To contribute to the goals and rapid and cost-effective implementation of the NZIA, we call for the scope of strategic net-zero technologies to still be clarified: 1) Under point 3 "Battery/storage technologies" large-volume underground H2 storage should also be explicitly considered: In view of increasing shares of renewable…

RAG Austria AG welcomes the creation of appropriate framework conditions for the H2 market/infrastructure. Nevertheless, we see considerable need for improvement in the current draft of the gas package: • The role of large-volume seasonal storage is still undervalued and has regulatory gaps: In the ramp-up phase, there should be the possibility of so-called "regulatory sandboxes" similar to those for grids.

RAG Austria welcomes the opportunity to comment on the legislative proposals regarding AFIR/CO2 standards. However, there is need for improvement in the following topics: • Technology openness of the drafts not given: With the focus on e-mobility in the transport sector, the existing potentials regarding rapid CO2 savings through the use of gaseous energy sources are massively misjudged.

RAG Austria AG welcomes the opportunity to provide feedback on the Electrification Action Plan (EAP). While the initiative represents an important step towards decarbonisation, its current approach places too much emphasis on electrification as the sole pathway.

Filed in German · English published by the European Commission

RAG Austria AG proposes the following suggestions for an effective methane Regulation: • A principle of proportionality should be considered. • One type of solution does not fit all cases along the gas supply chain. Flexibility is needed to prioritize actions and ensure cost-effectiveness.

RAG Austria AG welcomes the creation of appropriate framework conditions for the H2 market/infrastructure. Nevertheless, we see considerable need for improvement in the current draft of the gas package: • The role of large-volume seasonal storage is still undervalued and has regulatory gaps: In the ramp-up phase, there should be the possibility of so-called "regulatory sandboxes" similar to those for grids.