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ASOCIACION ESPAÑOLA DEL GAS

SEDIGAS

Since its establishment in 1970, Sedigas has been a driving force in fostering collaboration among all stakeholders to accelerate the energy transition, aiming to strike a balance between environmental sustainability, energy security, economic growth, and consumer well-being.

Lobbying Activity

Response to Revision of the REMIT Implementing Regulation on data reporting

15 Sept 2025

We would like to express our appreciation for the opportunity to provide feedback to European Commission about the revision of data reporting rules under REMIT Regulation. This response incorporates our observations and suggestions based on the draft Commission Implementing Regulation and its Annex published 18th August 2025.
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Response to Commission Regulation on inside information platforms and registered reporting mechanisms under REMIT

15 Sept 2025

We would like to express our appreciation for the opportunity to provide feedback to European Commission about the proposed new Commission Delegated Regulation Supplementing Regulation (EU) No 1227/2011 (REMIT). This response incorporates our observations and suggestions based on the draft Commission Delegated Act and its Annexs published 18th August 2025 (hereafter Draft) both from the perspective of an RRMs and a Market Participant.
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Response to Omnibus Directive Aligning product legislation with the digital age

18 Jul 2025

Comentarios de Sedigas en respuesta a la consulta pública sobre la legislación europea Ómnibus adjunto
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Response to Omnibus Regulation Aligning product legislation with the digital age

18 Jul 2025

Comentarios de Sedigas en respuesta a la consulta pública sobre la legislación europea Ómnibus adjunta
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Response to Revision of the Standardisation Regulation

18 Jul 2025

Comentarios de Sedigas en respuesta al Call for evidence sobre la revisión del Reglamento (UE) del Parlamento Europeo y del Consejo sobre la normalización europea adjuntos
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Meeting with Ruud Kempener (Cabinet of Commissioner Kadri Simson)

19 Sept 2023 · Exploitation of biomethane and renewable gases potential

Response to Interservice consultation on the electricity market design reform - REMIT

22 May 2023

Although we share the objectives of the revision to improve the functioning and transparency of the EU market, the proposal presents some shortcomings. We therefore would like to suggest below a few possible avenues to address the most relevant ones. The proposal includes several amendments to the constitutive elements of REMIT. Hence, some of the issues highlighted may have undesired cascading effects on other parts of the Regulation, potentially leading to a disproportionate increase of administrative burdens, legal uncertainty, additional market barriers, or conflicting requirements. In the attached document you can find the concrete arguments that SEDIGAS has on the project together with concrete proposals to improve the known wording. Best regards,
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Response to Proposal for a legislative act on methane leakage in the energy sector

18 Apr 2022

Some provisions require further adjustment to ensure the proportionality of measures and impact they may entailnamely network operators. Same solutions don’t fit all cases along supply chain due to different technical specificities. Regulation should prioritize tools and tech enabling the highest emissions reduction in shortest time and at lowest cost On the costs of network operators recognized within the scope of regulated activities, a range of references costs should be introduced to reflect variety of costs among the operators of different assets On the IMEO, it should play an impartial and scientifically based role to set policy guidelines in close dialogue w/ international/European Authorities and stakeholders. Double reporting´s risk and double verification should be avoided via the coordination between authorities. OGMP template must be used to report emissions to all parties. It should gather data from independent scientific studies based on data sampling w/ the industry On Inspections and Verifiers, large nº of infrastructure operators implies that readiness and involvement of verifiers wouldn’t be possible on time, nor manageable administrative burden and cost. Regular inspection should be aligned with inspections required by other EU/national legislation. The reliance on accredited internal personal of the operators could set a reasonable and cost-efficient option, ensuring their independence through periodic control of their activities On MRV, key concepts, definitions and reporting requirements (incl. templates) should be aligned with OGMP2.0 standards. At transmission & distribution level, the direct measurements required could often be neither feasible nor lead to a higher data accuracy than engineering or simulating methods. Quantification methods based on empirical studies of emissions’ intensities of real elements of the grid are a reliable, cost efficient and easily implementable tool. Allowing quantification methods emission factors and clear definition of “site” is needed. Reconciliation of bottom-up reporting with the top-down/site-level measurements have many limitations due to the associated uncertainty of the techniques. We recommend not to include obligations on quantification with site-level approach On LDAR, fixed intervals & repair times required, irrespective of the type of asset, will cause disproportionate efforts, with no or very little added value in terms of the methane emissions reduction. The lower the network pressure the less efficient is the proposal. Different regime for LDAR campaigns for TSOs & DSOs is firstly needed. Authorities should join network operators to define the inspections´ frequency and the times for repair based on an analysis at national level On mitigation, to make costs and investments efficient, methane emissions mitigation plans will allow prioritization of the most cost-effective mitigation measures. It is important to ensure a lead time for implementing venting and flaring provisions and grant an exemption when venting is leading to non-material emissions On emissions outside the Union, we support EU climate diplomacy together with international sectorial initiatives to encourage non-EU countries and companies to increase transparency and mitigation measures. However, it’s important to note that energy importers are limited to influence on the level of commitment of the producers, which might also have limited means to implement them. Further requirements to EU energy importing companies may distort internal energy market competition while not leading to any significant reduction of methane emissions outside EU. Imports are usually tied to producing regions based on physical and economic limits with relatively no alternatives supplies. Excessive strict requirements could penalize MS without own gas production or highly integrated suppliers (involved in upstream activities) with limited ability to influence the producers on implementing the mitigation measures
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Meeting with Kadri Simson (Commissioner) and

21 Feb 2022 · Spike of energy prices and EC's toolbox, Fit-for-55 proposals and EU taxonomy.

Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

22 Mar 2021

SEDIGAS 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. Nowadays, gas heating already provides comfort to consumers, decreases energy demand and reduces GHG emissions. Using gas heating instead of coal or oil heating has also contributed clearly to improve air quality. Two main barriers stand in the way of higher renovation rates: on the one hand the low awareness of consumers of the benefits of renovation, on the other, the costs they must face. Gaseous solutions can help consumers overcome these barriers and get access to efficient and affordable heating, and further reduce its emissions with the progressive penetration of decarbonized gases, including biogas (mainly from waste recovery) and hydrogen. The gas sector can progressively decarbonise buildings using existing infrastructure effectively. Moreover, gas grids’ guarantee the security of energy supply, during adverse meteorological events and allowing to address seasonal demand variations, such as demonstrated for instance during a severe cold spell occurred in January in Spain. The transformation of the natural gas sector and its evolution towards the use of modern equipment together with the integration of renewable and decarbonised gases (including hydrogen), will enable fast progress, provide energy savings, and ensure cost-efficiency of the decarbonization of energy consumption in buildings. The mere modernization of existing heating systems and the increase of renewable gases circulating through the energy grids would certainly contribute to reduce emissions in buildings. There are many inefficient appliances using all kind of fuels (e.g. electric heaters and radiators, non-condensing boilers) and many heating systems located in urban areas not connected to the energy grids (such as those using butane gas bottles or oil heating systems). Prioritizing the modernization of equipments and actions on buildings with heating systems not connected to energy grids could bring substantial emission reduction in buildings sector, rather than having to invest heavily in new infrastructures. Impact assessments should cover not only technical energy efficiency, but also economic principles. Cost efficiency, technology neutrality and a holistic view of energy policies are crucial (covering not only energy costs but also energy infrastructure and equipment costs) Like energy grids, it should be noticed that heating devices are neutral in terms of emissions. Similar to the increase of RES in electricity, natural gas is expected to be progressively replaced with renewable and decarbonized energy sources (including blending of hydrogen in urban areas). Many manufacturers are developing innovative systems that can be run with natural gas or hydrogen systems. Additionally, many experts and EU scenarios conclude that a full electrification of the heating sector would be largely inefficient, pointing to the necessity of gaseous fuels (fully gaseous or hybrid electrical-gaseous systems). Thus, it’s very important that the compatibility of new heating systems and equipment with renewable fuels is required, including gaseous energy fuels. Additionally, we support as part of the revision of the Energy Performance of Buildings Directive an update of the framework for Energy Performance Certificates. The increasing share of renewable gases in the energy mix and the compatibility of equipment with new gases such as hydrogen should be taken into account through these certificates.
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Response to Revision of EU rules on Gas

10 Mar 2021

you can read SEDIGAS´ response to European Commission’s consultation on the revision of EU rules on gas market access in the document attached. Please reach us to explain any argument given in the response document.
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Meeting with Joachim Balke (Cabinet of Vice-President Miguel Arias Cañete), Maria Cristina Lobillo Borrero (Cabinet of Vice-President Miguel Arias Cañete)

22 Jan 2019 · Role of gas