Český plynárenský svaz
ČPS
- Legislativa a strategie v plynárenství na evropské a národní úrovni s ohledem na dosažení uhlíkové neutrality - Technická normalizace - příprava technických pravidel a norem vč. technického poradenství - Propagace zemního plynu jako ekologického a udržitelného paliva v kontextu přechodu na zelené plyny - Komplexní příprava energetiky a plynárenství na nové plyny (biometan a vodík) včetně technické normalizace
ID: 248465752944-18
Lobbying Activity
Response to EU taxonomy - Review of the environmental delegated act
28 Nov 2025
CZGA strongly disagree with the PSF's recommendation to lower GHG thresholds for substantial contribution and do no significant harm (DNSH) for all energy activities. Suggested revision lacks a sound scientific basis and doesn´t reflect the best performance achievable under real world conditions. The recommended DNSH criteria, if applicable for activities 4.29 4.31 for electricity generation, heat generation or high efficiency CHP, would make the TSC unachievable and therefore discourage decarbonisation activities. Considering the role of natural gas in the phasing out of coal, we request an extension of the deadlines for temporary admissibility of natural gas in the Taxonomy for transitional use and aligning them with realistic coal phase-out and gas transition timelines. This involves extending the deadline for granting construction permits for new or refurbishment projects with temporary use of natural gas from 2030 to 2035, as well as shifting the latest requirement to obligatorily connect these sources to renewable / low-carbon gases from 2035 to 2045. While we propose extending the deadline for obtaining a building permit until 2035, taking into account the permitting processes, it is also necessary to extend the deadline for operating the facility to at least 10 years. Analogous extension only by 5 years is not sufficient considering the lifespan of the projects. Prolongation till 2045 should create flexibility in absence of the sufficient hydrogen sources, respectively their possible capacity limitations within the deadline for this transition. Moreover, considering the measures to safeguard the security of gas supply based on the Regulation (EU) 2017/1938, temporal acceptability of natural gas should be extended also to gas storage facilities, vital for security of supply in landlocked countries. Transmission and Distribution networks We would like to express strong concerns on behalf of gas transmission and distribution operators with the proposed changes related to the 4.14 activity, in particular with the recommended requirements that newly build pipelines have to be used exclusively for transport of renewable / low-carbon gases. In countries, where the investments in the "coal to gas switch" for power and heat generation are ongoing, the current criteria for activity 4.14 could undermine these efforts. Although natural gas is recognized as a transitional fuel, the rules effectively exclude infrastructure projects that temporarily transport natural gas, even when these assets are fully hydrogen-ready and designed for the future deployment of renewable and low-carbon gases, e.g. new connections and upgrades of low capacity connections to new and refurbished gas heating plants and biomethane plants. Moreover, depending on the evolution of supply chains, pipelines dedicated exclusively to the transmission of renewables may remain unused for unpredictable period of time. Storage of hydrogen CZGA strongly recommends inclusion of H2/CH4 blends into the scope of gas storage activities covered by Taxonomy, at least temporarily. Not only the existing storage facilities need investments enabling hydrogen readiness, to process the hydrogen content expected in the blend. They also represent the key element in safeguarding the security of gas supply, especially in landlocked countries. Therefore, the temporary admissibility of storage activities processing H2/CH4 blend within Taxonomy should be considered as a necessary security measure. District heating and cooling distribution We agree with the view that applying the DNSH criteria for pollution prevention and control is highly challenging, due to the vastness of heating network, making it technically impossible to create an inventory of all equipment. Nevertheless, applying the criteria only to new installations would also be equally problematic, as these will almost always be built only in combination with existing infrastructure.
Read full responseResponse to Revision of the EU’s energy security framework
13 Oct 2025
Czech Gas Association (CGA) is in full support of Commission's intention to revise EU energy security framework to adapt to the new geopolitical, energy and climate situation in order to prepare for a more decarbonised, electrified and integrated energy system. CGA realises that the transition of the energy sector toward a decarbonized system will be characterized by increased electrification, the expansion of renewable energy sources, and the introduction of new energy carriers such as renewable hydrogen and low-carbon hydrogen. Conversely, demand for natural gas is expected to decline, particularly for heating and cooling purposes. However, we would like to emphasise that while overall demand for natural gas may decrease, the required capacity of natural gas infrastructure during cold winter periods will not diminish significantly. This is due to the very limited output of PV in winter and the current technological inability to provide seasonal energy storage of electricity. Batteries and pumped-storage hydropower address short-term storage needs on the scale of hours, while hydrogendespite its very low round-trip efficiency (electricity hydrogen electricity)can provide storage for days or weeks, but only where salt caverns for hydrogen storage can be developed, which is not feasible in much of Central Europe. Similarly, wind conditions in Central Europe are less favorable and unstable, limiting the contribution of wind power to winter energy demand. As a result, CGA stresses that natural gaspotentially combined with CCUSwill remain essential, particularly for cogeneration of heat for district heating systems and electricity for electric heat pumps. The role of gas infrastructure, including natural gas, its blends, hydrogen, and CO2, will become increasingly important in ensuring the security of heat and electricity supply. At the same time, emphasis should be placed on diversifying sources and supply routes for natural gas, hydrogen, and its derivatives, for example by limiting reliance on a single supplier or region as a prerequisite for suppliers and traders Besides the above mentioned, we suggest one particular revision of article 5 (4) of regulation (EU) 2017/1938 to reduce unnecessary administrative burden for operators and regulators. The current regulatory framework under Regulation (EU) 2017/1938, Article 5(4), obliges transmission system operators or Member States to apply for an exemption from establishing permanent bi-directional gas capacity every four years. This obligation applies even when there is clear evidence that there is no market demand for reverse flow capacity. Each exemption request must include a cost-benefit analysis prepared in accordance with the methodology set out in Regulation (EU) No 347/2013. The analysis must cover several elements, including an assessment of market demand, forecasts of demand and supply, the possible economic impact on existing infrastructure, a feasibility study, the costs of building bi-directional capacity, and the benefits for ensuring security of gas supply. This process is highly resource-intensive and repetitive, creating an unnecessary administrative burden. Therefore, a different approach should be considered, i.e. relevant existing documents that work with capacity demand prediction could be used instead. For example, if the Ten-Year Development Plan did not indicate demand for reverse capacity, a mechanism would automatically be set that there is no obligation to process an application for an exemption. The proposal is based on the principle that there is no demand for capacity on the market, so it is relevant that the exemption will be granted (extended) without the preparation and processing of an extensive document that describes that there is no interest in transmission capacity in the considered direction.
Read full responseResponse to Heating and cooling strategy
9 Oct 2025
On behalf of CZGA, we would like to emphasize the need for a pragmatic, affordable, and resilient Heating and Cooling Strategy that supports effective decarbonization goalswithin the limits of available and feasible resources and infrastructure. Such a strategy requires Member States to coordinate and implement the most suitable solutions for each region, ensuring energy remains affordable for both households and industry. In this context, we consider the following aspects particularly important: 1. Regional and Technological Realism in Decarbonization Heating and cooling strategies must reflect local conditions and infrastructure limitations. While electrification and district heating are valuable and relevant, they are not always feasible, notably in older or multi-family buildings. A mix of technologies tailored to regional needs is essential for practical and cost-effective decarbonization. 2. Renewable Gases and Hybrid Systems as Ready and Available Solutions Renewable gases (e.g. biomethane, hydrogen blends) used in high-efficiency condensing boilers offer scalable, infrastructure-compatible decarbonization in the near term. Hybrid systems (gas boiler + heat pump) provide flexibility, reduce peak electricity demand, and are particularly suitable for the existing building stock. Clear rules for hydrogen certification are nevertheless essential to ensure market viability. (For renewable gases, consistent certification is key to enabling effective cross-border trade as the UDB framework evolves). 3. Regulatory Neutrality and Strategic Planning The 2040 reference year under EPBD IV should be viewed as a policy milestonenot a blanket ban on gas technologies. Heating strategies should remain technologically neutral, preserve consumer choice in line with household financial conditions, and be supported by spatial planning that includes cost-benefit analyses and zoning for different energy systems.
Read full responseResponse to Commission Regulation on inside information platforms and registered reporting mechanisms under REMIT
15 Sept 2025
Article 3 (Transactions to be reported on a continuous basis) Article 3(b)(i) and (ii) sets that transactions relating to the transportation of natural gas between entry-exit systems in the Union and between entry-exit systems in the Union and transmission systems outside of the Union shall be reported to the Agency. The explanatory memorandum to Article 3 reads that the amendments to the article are aimed at simplifying the existing legal text, without bringing about any significant changes in substance. The currently applicable Article 3 of the Commission Implementing Regulation (EU) No 1348/2014 (REMIT IR) sets obligation to report contracts relating to the transportation of natural gas in the Union between two or more locations or bidding zones. Entry-exit system has been defined by Article 2(57) of the Directive (EU) 2024/1788. Thus, while according to the REMIT IR contracts relating to the transportation of natural gas concluded both between two or more bidding zones or between the same bidding zone (between two locations within a single entry exit zone) shall be reported, the proposed wording suggests than only transactions relating to the transportation of natural gas between two or more entry-exit systems shall be reported. This is in contradiction to the explanatory memorandum, as per which the amendments do not bring any significant change. We therefore suggest the EU lawmaker clearly specifies in the legal text and its accompanying materials obligation which its addresses shall obey. Article 6 (Exposure reporting) The article 6 of the proposed implementing regulation introduces a provision on exposure reporting according to which market participants should report to the Agency, on a quarterly basis, in particular their forecasted volumes of consumption of electricity or natural gas. The explanatory memorandum to the article explains that as per the new provision market participants' forecasted sales of electricity and natural gas to final customers based on concluded customer contracts shall be reported to the Agency. With respect to this explanation and para. 2(c) of the provision, please make clear that the reporting as per Article 6 applies only to traders and suppliers and that the article shall not be applied to reporting of own consumption of transmission or distribution operators (such as consumption of gas compressor stations), which is driven solely by demand for their transmission or distribution services. Technological consumption of gas transmission operators (and similarly of distribution ones) can be predicted only with low reliability due to the difficulty of predicting flows through the transmission system over a long period of time, the influence of temperature during the winter season, which affects both energy consumption at compressors and at regulating stations and the prevalence of short-term fluctuations in transmission capacity.
Read full responseResponse to European Climate Law amendment
15 Sept 2025
pohled ČPS přikládáme přílohou
Read full responseResponse to Legislative initiative on CO2 transportation infrastructure and markets
9 Sept 2025
The Czech Gas Association fully supports the Commissions intention to establish a framework enabling the emergence of CO infrastructure and a well-functioning market for CO. Please find below the list of principles and mechanisms that the proposal should include. The full version of the feedback from the Czech Gas Association is attached.
Read full responseResponse to European Affordable Housing Plan
4 Jun 2025
Czech Gas Association (CZGA) welcomes the opportunity to contribute to the Commissions initiative on the European affordable housing plan. While the focus of this initiative will be on the affordability and availability of housing for the people living in Europe, CZGA would like to draw the attention to another important aspect: the coverage of households energy needs. Any energy transition must account for local realities - such as housing stock, existing infrastructure, and income levels - to ensure all consumers, particularly the most vulnerable, have access to affordable and reliable energy. This calls for targeted financial support, coordinated local planning, and clear, realistic pathways to cleaner, equitable alternatives. To deliver fair, timely, and socially inclusive decarbonisation, we need a diversified, flexible, and cost-efficient approach. Decisions must be grounded in local data, guided by principles such as affordability, technological neutrality, and consumer choice - and developed through coordinated stakeholder engagement. For example, the Czech Republic is among the countries with the most developed gas infrastructure. Gasification is particularly prominent in the housing sector with gas used in approx. 1,5 mil households. Gas also plays an important role as an energy source that will significantly complement the capacity-variable renewable energy sources and will be indispensable for the transition of the electricity and heating sectors away from coal. Similarly, the gas industry and its robust network are practically irreplaceable in larger towns and cities with dense populations, where there are significant limitations for building parallel or strengthening existing linear energy infrastructure or installing renewable sources, especially heat pumps (HP). The available data shows that the use of HP is not appropriate in about half of the dwellings in the Czech Republic. This category includes mainly smaller flats with individual or individual heating per flat in a bloc of flats (about 15% of flats), prefabricated houses with unsuitable heat distribution systems for switching to low-temperature heating and especially in listed buildings or complexes as well as buildings that have not yet undergone deep renovation. The gradual decarbonisation plan must, therefore, responsibly respect the need to maintain reliable and economically sustainable energy supply here, the role of gas (gradually decarbonised) will be crucial. Integrating renewable and low-carbon gases into building renovations offers a cost-effective route to decarbonise, especially in inefficient or hard-to-upgrade homes. This approach should be, thus, reflected in the upcoming European affordable housing plan as well as in the implementation of Directive (EU/2024/1275) on the Energy Performance of Buildings (EPBD), ensuring openness to all viable renewable energy solutions and reflecting local conditions and pathways. We see here also a connection with national renovation plans according to the EPBD which should be and remain realistic. They should establish an effective and sustainable timeline for building upgrades. Decarbonising the gas grid with renewable gases - particularly biomethane - offers immediate emissions reductions by leveraging existing infrastructure and heating appliances. Biomethane also enables seasonal energy storage, reduces landfill emissions, and supports rural economic development, making it a fast, cost-effective, and scalable renewable energy solution for buildings.
Read full response5 May 2025
CZGA welcomes the opportunity to provide feedback on the implementation of the Energy Performance of Building Directive (EPBD) which provides the regulatory framework for gradual decarbonisation of the building sector in the EU Member States. As a general comment, we understand the EC's interest in obtaining a comprehensive overview of the development of individual energy consumption indicators in the various Member States. However, we question whether all the indicators listed in Article 5 are equally important, as it will not be easy to obtain them. Moreover, some indicators, such as those listed under (e) and (i) in paragraph 1, seem to be quite similar. More specifically, as mentioned in Recital 24 of the EPBD, Europe needs to accelerate its pace to be able to achieve the 2050 goals. Accordingly, it is fundamental that the EU building observatory reflects, therefore, rightly the Member States progress on the use of renewable gases in heating. Besides, their use in the buildings is recognised under Recital 22, and furthermore in the Art.2(14) as well as in Art.11 as effective methods to reduce emissions from the buildings sector, including zero -emission buildings (ZEBs). Renewable fuels (gases) furthermore play an important role in complementing intermittent electricity supply, prioritising cost-effective renewable energy use and managing grid congestions. Therefore, we would like to raise our comment to the proposed content of tables no. 19, 20, 21 in the draft Annex, which implement commitments and options for Member States regarding the inspection of heating systems, ventilation systems, and air conditioning systems with a rated output of more than 70 kW in accordance with Art. 23. Member States have furthermore the option to establish separate systems for the inspection of residential and non-residential systems. According to Article 23(4), the inspection includes a basic assessment of the feasibility of reducing on-site fossil fuel use, for example, by integrating renewable energy sources, changing the energy source, or replacing or modifying existing systems, if relevant. Since renewable gases are included among the permissible renewable sources for on-site use in buildings, it is essential to assess them as a potential option. This includes evaluating the actual use or possibilities of integrating renewable energy (including renewable gases) and reducing fossil fuel use in existing systems or adapting them. Accordingly, we propose the following modifications to tables 19, 20 and 21 in the Annex of the draft act: 1. Biomethane and hydrogen should be also featured among the options for the Main source of energy 2. As regards electricity, which also represents a significant source of heating in Czechia, this one cannot be associated solely with heat pumps, as they still represent only a marginal part of the market. 3. In footnotes 18, 19 and 20 the text should be modified as follows: Hybrid system using both electricity and fuels The latter addition to the footnotes is proposed among others in light of the availability of gas heat pumps in the market or their combination in hybrid systems, which may represent a relevant segment in heating systems especially for buildings (both residential and non-residential) with a rated output of more than 70 kW. We consider these proposed additions important, especially given that the EPBD in the Art. 23(4) stipulates that such inspections can also serve as a basis for assessing the possibilities of reducing fossil fuel use on site and preparing measures to incentivize the replacement of fossil fuels in boilers with renewable alternatives (including gases) in heating, especially in the segment of existing buildings in national renovation plans or their updates.
Read full responseResponse to Taxonomy Delegated Acts – amendments to make reporting simpler and more cost-effective for companies
25 Mar 2025
We welcome the proposed partial revision of the taxonomy rules in connection with the publication of the Omnibus I package. Especially regarding the fact, the current framework demonstrates excessive complexity in application and, at the same time, shows weak interest from the financial sector and investors in its actual use. Specifically, we support the proposed revision set out in Article 2(1c) of the Delegated Regulation 2021/2178 which adds a provision allowing non-financial undertakings not to report on operational expenditures where the cumulative turnover of their eligible activities do not exceed 25% of total turnover. From our perspective, these are welcome changes to simplify the reporting process. Besides, we also support the EC's announced intention to further review all technical screening criteria (TSC), especially the application of the "Do no significant harm" (DNSH) rule, with the aim of simplifying and improving its usability. Here, we would like to draw attention to possible further revision of the DNSH rule in relation to the activities 4.29 - 4.31, namely for the production of electricity, heat, or highly efficient combined heat and power production. Firstly, we would like to strongly oppose the recommendations of the Platform for Sustainable Financing (PSF) as suggested in its January 2025 Report on the revision of TSC, including DNSH. The PSF proposal would effectively make it impossible to achieve TSC, thereby discouraging planned investments in the transition from coal to gas. At the same time, it would hinder the later full deployment of renewable and/or low-carbon gases. On the contrary, given the role of natural gas, which is expected to play in the phase out of the energy sector from coal use, especially in the Czech Republic, we request an extension of the deadlines according to which natural gas is currently temporarily qualified as taxonomically acceptable. Here, it is necessary to align these deadlines with the real timelines and capacities of the manageable process of complete phase out of coal to natural gas in the production of electricity and heat in the Czech Republic. Specifically, this involves extending the latest deadline for granting building permits for new or refurbishment projects with temporary use of natural gas from 2030 to 2035, as well as shifting the latest requirement to obligatorily connect these sources to renewable gases from 2035 to 2040. This should create flexibility for all individual sources in absence of the sufficient capacity for renewable hydrogen sources in a concrete locality, respectively their possible capacity limitations within the deadline for this transition. Also, the existing capacity limitations restrict the effective use of renovations or the construction of new sources, which in the case of replacing coal with natural gas can bring better effects in terms of emission reduction and further increase the capacity of new sources, which can replace and possibly terminate other outdated, unsuitable, and emission-intensive production sources, whose capacity without increase will be insufficient.
Read full responseResponse to Greenhouse gas emissions savings methodology for low-carbon fuels
25 Oct 2024
Czech Gas Association (CGOA) welcomes the EC's commitment to define the necessary rules for certifying GHG emission savings from low carbon fuels (LCF), with the aim of creating a clear regulatory framework. Due to the already achieved maturity of the low carbon hydrogen (LCH) production technology (e.g. SMR, pyrolysis), the partly existing infrastructure and reliable supply sources (only the CCS part is missing), the LCH production can ramp-up faster than RES hydrogen. Moreover, regulatory barriers (additionality, temporal and geographical correlation) imposed on RFNBOs will cause their production to grow more slowly and be more expensive than without these criteria. It is essential to allow the development of low carbon gases that can significantly and swiftly decarbonize the industry, transport, and heating sectors. This will pave the way for the future integration of large volumes of RES hydrogen. LCH production technology is proven and relatively cheap, it enables fast market development and decarbonization, enhancing the competitiveness of European industry in a short time. Beside the cost advantages, LCH will also allow for advanced testing, improved commercial trading, certification rules, or invoicing processes. In this regard, we welcome the ECs intention to link with the RED Union Database to apply the same provisions as for RES gases also to LCH. CGOA further welcomes the ambition to have a single methodology for domestic and imported LCF. Creation of a level playing field is an absolute necessity, as hydrogen will be globally traded, just like natural gas today. We also believe that it is essential to clearly define LCF role in achieving a Net Zero economy. This includes their use in various sectors, such as industry, transport or its integration into district heating solutions with utilizing heat side-production. So far, their use is limited to specific scopes and targets set by EU ETS and RED legislation. Finally, the proposed rules should be stable throughout the lifetime of their investment to ensure legal certainty for projects whose timeframe extends beyond the expected review in 2030 (Article 92 of Directive 2024/1788). The draft regulation does not provide this certainty. In general, this draft act should be simplified to instill confidence in investors. We emphasize the following: Grandfathering should be provided for the lifetime of the investment and/or gas supply to avoid regulatory uncertainty on evolving regulations (methane intensity, hydrogen GHG potential) and so have a stable regulatory framework allowing FIDs for low carbon. Project specific values provision for full or part of the value chain should be enabled for both, electricity and gas. For electricity, dispatchable low-carbon electricity (PPAs) should be allowed, to align the rules with DA RFNBO. Such a ruling will further promote development of clean electricity sources, including nuclear power essential for countries like CZ. For gas value chain, upstream project-specific emission values should be allowed and in the mid-stream, country-specific values should be allowed without any unjustified penalties. Approach to solid carbon as a byproduct of methane pyrolysis accounting should be described more extensively. It is assumed emission-free as no CO2 particles are released into the atmosphere (with no additional infrastructure and related additional costs) and should be, therefore, driven by analogous and specific CCS rules. The Commission should update the Delegated Act on RFNBO alongside the LCH Delegated Act once LCH methodology is adopted, because the LCH methodology has new rules for calculating GHG emissions. Synchronising them will ensure consistency across both regulatory frameworks. Likewise, DA on LCF should be aligned with other existing rules and procedures, e.g. InnovFund methodology for GHG Emissions Avoidance Calculation.
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