Snam S.p.A.

Snam, as Europe's leading multi molecule energy infrastructure operator in transport and storage, welcomes the opportunity to provide feedback on the Industrial Decarbonisation Accelerator Act (IDAA) public consultation.

SNAM’S FEEDBACK ON THE FIT FOR 55 PACKAGE Snam welcomes the Fit for 55 proposals, which overall certainly represent a complex and comprehensive initiative stemming from the Climate Law. In this note, we wish to express some high level comments outlining the most relevant positive elements in the proposals, together with the main areas for development, highlighting where relevant specific aspects across the…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

SNAM welcomes the opportunity to provide feedback to the EC initiative on the review of the EU renewable energy rules (RED II). The revision should proceed consistently with the Energy Sector Integration and H2 Strategies, where the essential role of renewable and low-carbon gases for achieving quicker and more efficiently the net zero emission target by 2050 is clearly defined.

Snam, European leader in energy infrastructure, welcomes the opportunity to contribute to the public consultations on the revision of the Delegated Regulations amending the EU Taxonomy Climate Delegated Act and acknowledges the EU Commissions efforts to enhance the frameworks usability and effectiveness.

(Please find attached a more detailed and comprehensive version of our contribution) - Snam welcomes the ECs review of the Climate and Environmental Delegated Acts of the EU Taxonomy, an important opportunity to improve the clarity, usability and coherence of the TSC and consistency with evolving EU policies.

(Please find attached a more detailed and comprehensive version of our contribution) - Snam welcomes the ECs review of the Climate and Environmental Delegated Acts of the EU Taxonomy, an important opportunity to improve the clarity, usability and coherence of the TSC and consistency with evolving EU policies.

Snam welcomes the opportunity to provide feedback on EC initiative on the revision of the Energy Performance of Buildings Directive, setting the very ambitious goal of decarbonising the EU's building stock by 2050.

Snam welcomes the opportunity to provide feedback on EC initiative on the revision of the EPBD. Higher climate ambitions require a swift implementation of the Renovation Wave initiative: increased building renovation rates and depth play a key role for a cost-effective transition to a net zero economy.

Snam, as Europe's leading energy infrastructure company, welcomes the ECs proposal for the EUs next long-term budget (MFF) and the consultation on competitiveness. We appreciate that the future EU budget will be more strongly focused on the Unions key priorities, including competitiveness and sustainable growth and we support the positive steps toward harmonization and streamlining of EU Funds, which will enhance…

Snam, leading European gas infrastructure operator, welcomes the efforts made to reduce reporting burden even if it stems primarily from an optimisation of the requirements rather than from a real datapoints reduction. We particularly appreciated the strengthening of the top-down approach in the Double materiality assessment, the confirmation of reliefs, without any time limits, and of the omissions.

Snam, as one of the world’s leading energy infrastructure players, welcomes the opportunity to provide a first feedback to the European Climate Law Proposal. Achieving climate neutrality by 2050 represents a great challenge and will require significant efforts.

Open public consultation concerning the review of ETS1 Snam, as Europe’s leading multi-molecule energy infrastructure operator in transport and storage, welcomes the opportunity to provide feedback on the ETS1 Review public consultation. We appreciate the progress achieved by the EU Emissions Trading System in reducing emissions across several sectors so far and the commitment to continuously improving it.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

SNAM’S FEEDBACK ON THE FIT FOR 55 PACKAGE Snam welcomes the Fit for 55 proposals, which overall certainly represent a complex and comprehensive initiative stemming from the Climate Law. In this note, we wish to express some high level comments outlining the most relevant positive elements in the proposals, together with the main areas for development, highlighting where relevant specific aspects across the…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The following points referred to the EC Inception Impact Assessment intend to represent a first SNAM contribution to proposal for a “Carbon Border Adjustment Mechanism” Directive. • European economy competitiveness shall continue to be a key goal for EU policy, being strictly linked to employment levels and, in general, to the overall internal wealth.

SNAM’S FEEDBACK ON THE FIT FOR 55 PACKAGE Snam welcomes the Fit for 55 proposals, which overall certainly represent a complex and comprehensive initiative stemming from the Climate Law. In this note, we wish to express some high level comments outlining the most relevant positive elements in the proposals, together with the main areas for development, highlighting where relevant specific aspects across the…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Snam welcomes the opportunity to provide feedback to the EC initiative on the review of the EED, acknowledging energy efficiency as key for a cost-effective transition to a net zero economy (“Energy Efficiency First” principle). The revision should proceed consistently with the Energy Sector Integration and Renovation Wave initiatives.

Snam welcomes the opportunity to provide feedback to the EC initiative on the review of the EU ETS. The primary objective of the ETS revision should be to ensure that the mechanism will provide clear price signals to support decarbonisation meeting the more ambitious climate targets for 2030, as recently revised by the EC.

The following points referred to the EC Inception Impact Assessment intend to represent a first SNAM contribution to the Energy Taxation Directive revision process. • It is important that natural gas taxation regime in the different sectors is kept at the current levels (or even reduced), taking also into account the increasing percentage of low carbon and green gases (biomethane, blue and green hydrogen) in the…

Snam, a European leader in energy infrastructure, welcomes initiatives aimed at providing certainty to the renewable energy sector for the decade ahead. A pragmatic and technology neutral approach will be crucial in our view to leverage all available solutions and ensuring integration of energy vectors.

L’exigence de la déclaration d’empreinte carbone pour les batteries rechargeables aura un impact modéré sur mon activité : elle nécessite de réaliser ces études avant la date prévue. L’étiquetage pour la performance carbone est peu utile puisque la méthode est connue et standard, et elle peut être contournée (cf Dieselgate).

Snam welcomes the opportunity to provide feedback to the EC initiative on the Amendment of the Regulation setting CO2 emission standards for cars and vans and would like to provide the following comments and suggestions: 1. Transport and future mobility will be a central element of the climate policies for the coming years.

Snam, as Europes leading multi-molecule energy infrastructure operator, welcomes the opportunity to provide feedback on the EU Grids Package and below are our key recommendations. Ensure that the EU Grids Package encompasses all energy infrastructure, not resulting overwhelmingly focussed on electricity and clearly including also H2 and CCUS as essential and complementary elements to an integrated, secure and…

Snam welcomes the opportunity provide feedbacks on the potential AFID revision, being a key instrument for the development of markets for alternative fuels, and would like to provide the following comments and suggestions: 1. A long term and stable regulatory framework as well as a clear long-term plan for each fuel is key to invest in alternative fuels infrastructure. 2.

Please note that Snams response is also available in the attached file, which has been formatted for better readability. Snam welcomes the opportunity to provide feedback on the EC initiative to develop an Electrification Action Plan. Below are our key considerations for an Action Plan delivering a reliable, resilient and affordable decarbonised energy system.

Snam, as leading multi-molecule infrastructure operator active also in CCS projects, welcomes this initiative and would like to provide the following suggestions for the establishment of a well-functioning CO2 internal Market and related Infrastructure. Further elements are provided in the attached Explanatory Note.

Snam, European leader in energy infrastructure, welcomes the initiative to produce technical guidance on applying the do no significant harm (DNSH) principle in the next Multiannual Financial Framework 28-34 (MFF). As a key actor in ongoing energy integration, Snam has a direct interest in ensuring that EU funding frameworks are both environmentally robust and operationally workable.

Snam welcomes the opportunity to provide feedback on the proposed EU Heating and Cooling Strategy. For convenience and improved readability, Snams response is also included in the attached document. Below our key considerations for a Strategy accelerating an affordable and secure heating and cooling sectors decarbonization, via system integration and a technology-neutral approach.

SNAM welcomes this initiative and considering the draft proposal, we would like to provide the following comments: Hydrogen infrastructure The introduction of a H2 category, including transport, storage, regasification and any other essential asset required to H2 system operations, represents an important progress in building an EU-wide H2 infrastructure.

Snam welcomes the opportunity to provide feedbacks to the Proposal for a regulation - Revision of the guidelines for trans-European Energy infrastructure. In view of the future challenges the EU Energy system will have to face it seems appropriate the EC proposal to think how the Regulation can be reviewed to better address EU decarbonisation targets, being in line with the EU Green Deal goals and policies under…

Snam is strongly committed to initiatives that call for the reduction of methane emissions. The company plans to reduce direct and indirect emissions to be net zero by 2040, in line with the OGMP 2.0 and COP26 targets.

Snam welcomes the opportunity to provide feedback to the EC initiative on the rules to prevent methane leakage in the energy sector, based on the recent EU communication on methane strategy. We consider very positive the comprehensive approach of the EC for methane emissions reduction: the EC Strategy takes indeed into consideration all the main involved sectors such as energy, agriculture and waste, paving the…

As Snam, the largest infrastructure operator in Europe, we welcome the European Commissions initiative to review Annexes V and VI of the Renewable Energy Directive (RED). We consider this revision a timely and important step to ensure that the regulatory framework adequately reflects technological developments and supports the effective decarbonisation of the energy system.

Snam, European leader in energy infrastructure, welcomes the EUs efforts to strengthen the governance of the energy transition and highlights that a stable, predictable and investment friendly framework is essential to accelerate the deployment of strategic infrastructure. This is especially relevant in view of the increasing interlinkage between energy vectors .

Snam, as pan-European multi-molecule infrastructure operator, welcomes this initiative and would like to provide the following suggestions for an EU energy security(SoS) framework more resilient to geopolitical, climate-related and other emerging risks factors affecting availability and affordability of energy resources.

Preliminary Snam inputs to the FuelEU Maritime Initiative Snam, as one of the world’s leading energy infrastructure players, welcomes the FuelEU Maritime Initiative and provides the following contributions: 1. The initiative should take a well-to-wake approach, and consider not only the impact of GHG but also of local pollutants.

Snam, a leading European energy infrastructure operator, welcomes the European Commissions initiative to establish a post-2030 climate framework. We believe that a successful climate policy framework should be pragmatic and sensitive to the diverse industrial and economic realities of Member States, including their specific energy infrastructure.

The proposed CO Regulation for Heavy-Duty Vehicles should recognise the decarbonisation potential of sustainable and renewable fuels, through mechanisms (e.g. Carbon Correction Factor, CCF) reflecting the carbon intensity and the share of CO2 Neutral Fuels.

SNAM welcomes the opportunity to provide feedback on extending the scope of traceability of the Union database. We recognize the importance of the platform in ensuring traceability and transparency and acknowledge the need for the Commission to strike the right balance between transparency outcomes and regulatory proportionality, as applied to the decision on whether and to which extent expanding the scope of data…

SNAM welcomes this initiative to set a common methodology to calculate and monitor GHG emissions of transport and logistics. The standard EN 16258 "Methodology for calculation and declaration of energy consumption and greenhouse gas emissions of transport services" provides a standard which, although it is considered insufficiently precise, can be used by freight forwarders in a targeted approach.

Snam welcomes the opportunity to provide feedbacks to the EC Communication on “European vehicle emissions standards – Euro 7 for cars, vans, lorries and buses”, and would like to highlight the following: 1. The overall target to guarantee standard robustness should be always set looking to a fuel and technology neutral approach.

SNAM welcomes the opportunity to provide feedback on the draft act to update the rules for monitoring and reporting emissions: Recognition of the benefits of hydrogen in the emission trading system: -The combustion of hydrogen does not release carbon dioxide.

SNAM welcomes the opportunity to provide feedback on the interim evaluation of the CEF 2021-27. With a view to support potential refinements in the design of future allocation rounds, we provide feedback reflecting our experience gained throughout the submission of project proposals within CEF2 and our thinking relating the future of gas infrastructure.

Snam welcomes the opportunity to provide feedback on the European Regional Development Fund, Cohesion Fund and Just Transition Fund for 2021- 2027 mid-term evaluation. We recall the significant role of renewable and low carbon hydrogen for the energy transition as outlined in the FF55 as well as in the REPower EU, including hydrogen targets to 2030.

Snam welcomes the opportunity to provide feedback to the Roadmap of the public consultation “Ecofriendly investment – EU standard for ‘green bonds” and would like to provide the following contributions. The adoption of an EU Green Bond Standard has the potential to further develop the market of Green Bonds as it provides more clarity for investors and issuers.