Český plynárenský svaz
ČPS
The Czech Gas Association represents companies and experts in the gas industry and advocates for the role of gas in reaching carbon neutrality.
Lobbying Activity
Czech gas association demands carbon credits for renewable fuels
20 May 2023
Topic — The European Commission is reviewing carbon dioxide emission standards for heavy-duty vehicles.
Message — The association requests that the regulation promote renewable and synthetic fuels. They propose keeping incentives and developing a methodology to recognize their benefits.12
Why — This allows the gas industry to protect its market share using existing technologies.3
Impact — Manufacturers lose because current rules make producing gas-powered trucks significantly more difficult.4
Response to Review of cogeneration reference values
30 Dec 2022
Český plynárenský svaz (dále jen ČPS) vítá možnost vyjádřit se v rámci veřejné konzultace k návrhu nařízení Komise v přenesené pravomoci, kterým se mění nařízení Komise v přenesené pravomoci (EU) 2015/2402, kterým se přezkoumávají harmonizované referenční hodnoty účinnosti pro oddělenou výrobu elektřiny a tepla za použití směrnice Evropského parlamentu a Rady 2012/27/EU. Připomínka č.1 ČPS uplatňuje k návrhu připomínku vzhledem k cílům vytýčeným v rámci Sdělení Komise s názvem Plán REPowerEU a vyzývá v této souvislosti Komisi k přehodnocení referenčních hodnot v přílohách k návrhu pro výpočet úspor energie prostřednictvím kombinované výroby tepla a elektřiny v případě kategorie G12 Biogas produced from anaerobic digestion, landfill, and sewage treatment v porovnání s kategorií G 10, která se vztahuje na biomethan. Odůvodnění: ČPS je toho názoru, že pro dosažení cíle zvýšení udržitelné výroby biometanu v rámci EU do roku 2030 na 35 miliard m³ je nutno podpořit konverzi bioplynových stanic na biometanové stanice. Sdělení Komise s názvem Plán REPowerEU z 18. května 2022 uvádí nutnost adresovat hlavní překážky zvýšení udržitelné výroby a využívání biometanu, mezi kterými je mj. poskytování pobídek pro přechod z bioplynu na biometan. Navrhované nastavení výše referenčních hodnot účinnosti mezi bioplynem pro výrobu tepla v kogeneračních jednotkách v kategorii G 12 a biomethanem v kategorii G 10 neodpovídá podle názoru ČPS tomuto cíli. Na základě výše uvedeného se ČPS domnívá, že je zapotřebí adresovat podporu pro bioplynové vysokoúčinné kogenerační jednotky vis-à-vis podpoře pro přechod z bioplynu na biometan. V mnoha případech představuje totiž výroba biometanu a jeho následné využití účinnější způsob využití energie než spalování bioplynu ve vysokoúčinných kogeneračních jednotkách (a to zejména v případech, pokud není u bioplynové vysokoúčinné kogenerační jednotky zajištěno uplatnění užitečného tepla ). Připomínka č.2 ČPS také vyzývá Komisi k přehodnocení referenčních hodnot (ve formě jejich snížení) v přílohách k návrhu pro výpočet úspor energie prostřednictvím kombinované výroby tepla a elektřiny v případě kategorie G11A.
Read full responseCzech Gas Association opposes rigid methane leak repair deadlines
13 Apr 2022
Message — The association requests replacing fixed three-month inspections with flexible schedules based on the technical condition of equipment. They also argue against mandatory one-year repair limits for large pipelines to avoid massive gas venting.12
Why — Avoiding prescriptive rules would save companies millions in compliance costs and operational disruptions.34
Impact — Environmental goals are undermined as small leaks may continue indefinitely until the next maintenance.5
Response to Revision of EU rules on Gas
12 Apr 2022
The Czech Gas Association welcomes the opportunity to comment on the recast Gas Regulation. Below we highlight our key positions, the full assessment of the proposal is attached in the annex.
1) The proposal defines two separate systems. The requirements applicable to one system are, for the most part, different from those applicable to the other. Unfortunately, the differences are of such a nature they prevent a natural gas and hydrogen system from benefitting from their natural synergies.
2) The new rules set out the abolishment of tariffs at the IPs, leading to the need to introduce cross-border inter-HNO compensation mechanisms. We see a real risk that the envisaged complex and for negotiations quite time-consuming compensation schemes might seriously deter investments into cross-border hydrogen infrastructure and hinder the swift development of hydrogen networks in the EU.
Instead, the hydrogen market should take its inspiration from the well-functioning natural gas market. The application of the process established by the NC CAM applicable to natural gas can enable early investments into hydrogen infrastructure. This process can further be optimized by utilizing the mechanism of financial transfers proposed in Article 4.
Besides, abolishing tariffs de facto limits the option of the Member States to impact the level of socialisation of the cross-border infrastructure costs and thus contradicts the principle of subsidiarity.
3) We welcome the option that the Member States may allow financial transfers between regulated services to ensure cost-reflective and stable tariffs for using the gas and hydrogen infrastructure. Support mechanisms via European or national funds may be another option to mitigate the resulting gap in the financing of hydrogen infrastructure in the initial phase. We believe that the NRAs will be best suited to adopt a detailed methodology on transfers between RABs.
4) We suggest that providing a 100% discount at IPs does not present an appropriate solution to support renewable gases. We believe that the appropriate measure to support the uptake of these gases may be market-based incentives (e.g., guarantees of origin or comparable tradeable instrument).
We also disagree with the concept of establishing a mandatory ITC mechanism. We see a real risk that the ITC mechanism process will be too complicated and very long to negotiate.
Besides, the draft Regulation also provides a 75% discount on capacity tariffs for entry points from renewable and low carbon production sites. This entails a significant risk if the bulk of the production in a given Member State would be exported in substantial volumes. This cost compensation will then be borne by domestic consumers.
5) The proposed revision of the Gas Regulation stipulates that TSOs shall accept gas flows with a hydrogen content of up to 5% by volume at IPs in the natural gas system from 1 October 2025. We consider this proposal quite ambitious, yet from the TSO perspective, still achievable. If downstream network operators and users are affected, compatibility of gas devices must be secured.
6) We see no need to create ENNOH and propose adding hydrogen (and also distribution) activities to the current duties of ENTSOG by expanding the current membership to also include all hydrogen network operators and distribution system operators.
Read full responseResponse to Revision of EU rules on Gas
12 Apr 2022
The Czech Gas Association welcomes the opportunity to comment on the recast Gas Directive. Below we highlight our key positions, the full assessment of the proposal is attached in the annex.
1) The proposal defines two separate systems. The requirements applicable to one system are, for the most part, different from those applicable to the other. Unfortunately, the differences are that they prevent a natural gas and hydrogen system from benefitting from their natural synergies.
2) The proposal prevents the existing ITOs from acting as HNOs beyond 2030, although the ITO model has proven to be an effective form of unbundling comparable to OU. At the same time, the ISO model does not represent a realistic alternative – especially not for an emerging hydrogen network.
We believe that imposing the full OU option practically as the only model for a future hydrogen grid may have serious negative consequences for the development of the hydrogen market by disincentivising the development of a hydrogen infrastructure and the repurposing of existing infrastructure as the most cost-efficient way of the transition. Besides, it would infringe on the principle of proportionality. Therefore, we propose to remove the time limitation for the ITO model.
3) Legal unbundling in conjunction with information unbundling and, in the case of gas TSOs, functional unbundling effectively prohibits any meaningful cooperation between TSOs/DSOs and HNOs.
There are no reasons for those restrictions as both the TSOs/DSOs and the HNOs will invest into taxonomy-compliant activities. Thus, access to financing by the HNOs will not be negatively impacted by the TSOs’/DSOs’ activities. Besides, they are/will be subject to regulation, ensuring that they duly respond to market demands and thus should not be viewed as having conflicting interests. Cost reflectivity of the two separate systems can be easily/efficiently ensured by creating separate accounts.
Enabling the TSOs/DSOs to own, operate and invest in hydrogen networks will facilitate the efficient and economic development and operation of the hydrogen grid as the operational expertise will be available, all other natural synergies between the two can be used to the benefit of hydrogen end-users, and no unnecessary administration costs will be incurred.
The repurposing of the existing grid will be demanding from the financial, technical, and organisational perspectives. However, such a transformation cannot be performed without detailed information on a particular end-user appliance (available to the existing TSOs/DSOs only). The new Gas Directive should explicitly recognise that gas TSOs and DSOs can be certified as owners and operators of hydrogen networks (HNOs). It is economically most efficient for both gas TSO and HNO activities to be performed within a single legal entity to create synergy effects.
4) We see a real risk that the envisaged compensation schemes for financing cross-border hydrogen infrastructure will hinder the swift development and deter investments of/in hydrogen networks. We suggest applying tariffs at cross-border points for hydrogen networks and utilising the process established by the NC CAM for the development of incremental (new) capacity.
5) We believe that national hydrogen and natural gas network planning should be created as one single plan as the future hydrogen network will be largely developed by repurposing existing gas assets.
6) Our other concerns also include tools available for infrastructure operators that will be responsible for gas quality management and the proposed certification of renewable and low carbon gases via the mass balance system.
Read full responseResponse to Revision of the Energy Performance of Buildings Directive 2010/31/EU
31 Mar 2022
The Czech Gas Association welcomes the opportunity to comment on the recast of EPBD. Below we highlight our key positions, the full assessment of the proposal is attached in the annex.
In our opinion, the present proposal of the recast of EPBD is an important part of the proposals to meet the EU's ambition to achieve climate neutrality goals by promoting the use of low-emission and zero-emission technologies in the field of heating and reducing the energy intensity of buildings.
Nonetheless, respecting the principle of technological neutrality remains a prerequisite of achieving cost-optimal solutions in case of construction as well as renovation of buildings, especially when it is not technologically feasible or economically affordable to replace current energy supply by electricity.
In this framework, the role of renewable gases in the present proposal in the heating sector should not be disregarded as it has its place also in the decarbonisation scenario of the gas sector with the gradual phasing in of renewable gases. Especially the current gas customers in the heating are the most likely future hydrogen customers and can benefit from reduced stranded costs
Moreover, the existing gas networks provide a flexible decarbonisation pathway for customers as they are well-positioned to distribute and manage varying local blends of molecules and, to a large extent, are ready to convert relatively quickly to adapt 100% hydrogen.
Nevertheless, the proposed zero-emission buildings (ZEB) standards for newly built buildings to meet the requirements of zero emissions means de facto displacement or inadmissibility of technologies using gases for heating in this segment of buildings. This is in contradiction with the Commission’s assumption referred in the Gas Directive proposal that “in the future there will still be household natural gas consumption including increasing volumes of renewable gas” (see Recital 20). We would like to point to the fact the issue of defining conditions emerging from this proposal for the use of technologies enabling the use of renewable resources is, therefore, crucial.
Regulatory conditions and EU policies should thus enable uninterrupted support for technologies and appliances which would be eventually able to use renewable gases and should be reflected in the proposed definitions of ZEB as well as in continuous subsidy rules for boilers (‘a 100% hydrogen-ready appliance’).
Moreover, it is necessary to introduce technological parity in the core principles of this proposal. For example, in case of heat pumps or other RES-based heating energy performance classification, the policy should build on the assumption that gas will be gradually and fully renewable, by 2050 at the latest, as it is assumed for electricity.
The possibility of supporting use of gases as a substitute for coal in households in the conditions of the Czech Republic should be retained with the condition of being ‘hydrogen-ready’, especially in cases where households are already connected to the gas infrastructure or, where there is not an option of their connection to efficient district heating and cooling in terms of its definition included in the Energy Efficiency Directive.
Moreover, installation of technologies enabling the use of zero-emission gaseous fuels in buildings, including those sourced from outside the renewable energy communities and distributed by energy grids should be considered as meeting the conditions for the definition of a zero-emission building and should be a sufficient condition for public funding for these technologies.
Read full responseResponse to Ecodesign requirements for water heaters and tanks (review)
31 Mar 2022
We appreciate the opportunity to provide feedback on relevant issues for the impact assessment and ask to consider attached position of the Czech Gas Association in detail during the impact assessment. We would like to stress out that we welcome the possibility to indicate future H2-ready appliance on the upcoming energy label. With regards to energy transition, the PEF should be based on expected sources in the near future rather than steam reforming with current energy mix. This could lead to significantly lower values and could support the technology.
Read full responseResponse to Proposal for a Regulation on establishing a Climate Action Social Facility
29 Oct 2021
• CGA is of opinion that the establishment of the SCF represents unnecessary transaction costs (setting up Social Climate Plan, its administration etc.) for the Czech Republic, in contrast to the direct national redistribution of finances (e.g., lower income tax, VAT, lump sum transfers), respectively the establishment of a national fund. That is why CGA is against the establishment of the SCF, which disproportionately widens the Member States' redistributive income chain and does not take properly into account the different decarbonization trajectories, the diverse socio-economic situation of the Member States (via allocation key) and the cost-effectiveness of decarbonizing national economies.
Alternatively,
• Following the establishment of the SCF, CGA argues that the technical guidance for the application of the "do not significant harm" principle under the SCF Regulation proposal should recognize bio-CNG and bio-LNG as renewable fuels. European Commission should, therefore, allow support for bio-NGVs within eligible support areas under Art. 5 of SCF Regulation.
• In the European Union as well as in the Czech Republic, biomethane represents untapped potential that will lead to substantial emission reductions in the road transport. However, CGA is of opinion that biomethane has not received adequate support from the European Commission and that adequate incentives must be provided for biomethane production (CapEx/OpEx support) by the European Commission and the Member States as for other renewable energy sources (e.g., RES-E). Therefore, CGA calls for, among other things, a change in the methodology for measuring emissions from “tank-to-wheel” to “well-to-wheel”, which is a technology-neutral approach to the decarbonisation of the transport sector.
• It must be acknowledged by the European Commission that gas mobility can effectively help to decarbonize the transport sector by creating cost-effective synergies with electromobility. Tailpipe emissions from cars that use natural gas as fuel are a lower by 25% compared to gasoline-powered cars. Biomethane de facto reduces emissions by up to 65% or more (depending on feedstock used for production of biomethane) on the “well-to-wheel” basis. In addition, LNG and CNG could also provide a cheap and effective solution to significantly reduce not only CO2 emissions but also local pollutants such as NOx, SOx, PM10 and PM2.5.
• Besides the aforementioned, we would also avoid carbon lock-in effect by initially encouraging LNG and CNG in the transport sector as the relevant infrastructure can subsequently be used by bio-LNG and bio-CNG. As biomethane, in the form of bio-CNG and bio-LNG, is 100% compatible with natural gas technologies: refueling infrastructures and vehicles are ready to switch full biomethane at any time, at zero cost.
• Cost-effective decarbonization of heating and cooling, which will lead to truly integrated and fully resilient energy system is only possible with the continued support for the installation of gas condensing boilers. Therefore, under Art. 5 of the SCF Regulation Member States should be able to support replacement of 1st and 2nd emission class boilers as well as higher emission class boilers (automatic coal-fired boilers) with, inter alia, gas condensing boilers... see attachment
Read full responseResponse to Revision of the CO2 emission standards for cars and vans
29 Oct 2021
• CGA argues for a change in the methodology for environmental impact assessment of vehicles from "tank-to-wheel" approach, i.e. emissions measured on the tailpipe to "well-to-wheel" approach or "life-cycle assessment" with an open cycle taking into account the so-called "end-of-life" of vehicles.
• “Well-to-wheel” approach or “life-cycle assessment” represent technology neutral methodology that can incentivize decarbonization of the transport sector. Moreover, only “well-to-wheel” or “life-cycle assessment” could adequately recognize many of the environmental benefits of biomethane as a transport fuel and in general as well (e.g., emissions reduction from agriculture), which are overlooked due to the current “tank-to-wheel” approach.
• Last year, "EU Strategy on Energy System Integration" announced opportunities for further targeted support for biofuels/biogas production to accelerate the development of the biofuels and biogas market. CGA believes that especially in the Czech Republic, a change in the methodology and a technology-neutral approach to the decarbonization of the transport sector, not only a long-distance transport (focusing on Heavy Duty Vehicles), would enable faster emission reductions. It would represent cost-effective approach of decarbonizing the transport sector and it would also respect climate and geographic conditions of the Czech Republic and its path dependencies.
• If we only take into account only tailpipe emissions (“tank-to-wheel”), in order to measure the impact of transport vehicles on the environment, the development of sustainable biofuels is rather not supported (e.g., tailpipe emissions for biomethane are in principle the same as for natural gas). In addition, the current methodology has not yet led to a reduction in transport emissions. On the contrary, emissions in transport have been growing continuously and their growth is likely to continue without the introduction of a "life-cycle assessment" or a "well-to-wheel" methodology.
• CO2 emission performance standards de facto make it impossible to promote advanced and sustainable biofuels as part of the future transport fuel mix, especially for those Member States that have truly technology-neutral transport policies to promote all types of low-carbon and renewable fuels in transport.
• Tightening of CO2 emissions performance standards for new passenger cars and new light commercial vehicles also limits potential of advanced biofuels in the future transport fuel mix.
• Summary report on the public consultation on the revision of CO2 emission performance standards for cars and vans shows that most of the survey participants were in favor of crediting mechanism for renewable gaseous and liquid fuels, i.e. including biomethane in the CO2 limits of the car manufacturer's production fleet.
• In general, CGA considers further tightening of CO2 emission performance standards for new passenger cars and new light commercial vehicles, without adequate methodological adjustments and a technology-neutral approach, to be a hasty and radical step to increase ambitions that will have a negative impact on the Czech Republic's GDP.
Read full responseResponse to Revision of Alternative Fuels Infrastructure Directive
29 Oct 2021
• The proposal for the revision of Directive (EU) 2014/94 of the European Parliament and of the Council on the deployment of alternative fuels infrastructure under Article 2(3) introduces a new classification of the alternative fuels in sub-paragraphs (a), (b) and (c) on the basis of sub-definitions.
• We do not agree with the sub-definitions of (a) alternative fuels for zero emission vehicles, (b) renewable fuels and (c) alternative fossil fuels for a transitional period.
• Due to the decarbonization of the gas, such sub-definitions of alternative fuels would cause a problem in the context of biomethane injection into the gas grid or in the case of blending of hydrogen with natural gas, where it would not be clear from the proposed sub-definitions what kind of fuel is delivered to the supplier/final customers. We are concerned that this may also lead to some fuels being counted more than once (double counting), or to the indirect exclusion of LNG/CNG from other EU policies.
• In addition, the European Commission recognizes the role of blending, as evidenced by its proposal for revised Guidelines on State Aid for Climate, Energy and the Environment (CEEAG), e.g., in the Clean Mobility section, and in particular in paragraphs 162 and 185.
• We therefore call for a reintroduction of the definition of alternative fuels from the current wording of Directive (EU) 2014/94 - Article 2(1), which is flexible and non-exhaustive enough to address the above-mentioned issues.
• We are also of the opinion that the proposal for a new definition and sub-definitions of the alternative fuels is not in line with the principle of technological neutrality, as it promotes a "tank-to-wheel" methodology as opposed to a "life-cycle assessment" or "well-to-wheel" methodology. At the same time, it makes it impossible to cost-effectively decarbonize the transport sector.
• If we only take into account only tailpipe emissions (“tank-to-wheel”), in order to measure the impact of transport vehicles on the environment, the development of sustainable biofuels is rather not supported (e.g., tailpipe emissions for biomethane are in principle the same as for natural gas). In addition, the current methodology has not yet led to a reduction in transport emissions. On the contrary, emissions in transport have been growing continuously and their growth is likely to continue without the introduction of a "life-cycle assessment" or a "well-to-wheel" methodology.
• We have no reservations concerning the proposed conditions for LNG infrastructure (Art. 8). However, we would like to emphasize the contribution of the LNG / CNG infrastructure to the (future) use of low-emission and renewable fuels.
• When it comes to infrastructure investments, what matters is the fuel carried, which is why infrastructure regulation should be and remain neutral.
Read full responseResponse to Review of Directive 2012/27/EU on energy efficiency
29 Oct 2021
● The proposed target under Article 8 to be applied as of 2024 is perceived as a hardly achievable limit in terms of the capacity of the Czech economy and households. As regards the newly proposed commitment - almost doubled annual cumulative final energy savings for the Member States (i.e. 1.5 pp per year) - we oppose its binding nature and „one-size-fits-all“ approach to Member States. Instead, our preferred approach would be to maintain the possibility to differentiate between individual Member States’ commitments according to their real compliance capacity and specific conditions (to provide for commitments ranging from 0.8% per year for some MS up to the proposed 1.5% for the other states with capacity to meet it).
● We oppose the newly proposed definition of “efficient” district heating and cooling” based on a trajectory of four milestones until 2050 with binding criteria for the share of the use of renewable energy and waste heat in district heating and cooling systems. We request that for reconstructed systems, the required levels of the share of renewable energy and waste heat remain only indicative and be assessed according to the cost-effectiveness principle (EEF).
● We oppose the revision of the proposed regulatory text which limit, as of 2024, the possibility to count energy savings achieved from policy measures using direct combustion fossil fuel technologies. We ask for reconsideration of this limitation so as it would be possible to take into account the savings associated with the installation of gas condensing boilers
● From the technological neutrality point of view, the above-mentioned exclusion is unacceptable because while energy savings resulting from, for example, the promotion of natural gas-based cogeneration would not be eligible, restrictive clauses would not be applicable to indirect uses, such as in which electricity generation involves fossil fuels. However, the energy savings obligations should allow the use of all efficiency solutions across end-uses, focusing on criteria for low-carbon solutions and those being ready for the future use of renewables (green gases).
● Furthermore, we would like to reintroduce the option of counting in of savings achieved in the framework of EU ETS to the draft legislation.
● As regards the "energy efficiency first" principle: Member States should ensure that gas and electricity transmission and distribution network operators apply the "energy efficiency first" principle in accordance with Article 3 of this Directive when planning new networks, network development or investment decisions. At present, there is a process- and professionally efficient solution using the principle of energy labels for buildings (Ecodesign), which is rightly targeted in the preferred manner.
Read full responseResponse to Revision of the Renewable Energy Directive (EU) 2018/2001
29 Oct 2021
Buildings:
CGA considers the nature and the level of the newly proposed binding target for Member States as regards the share of RES in heating and cooling by 1.1 pp/per year as unachievable in the given conditions of the Czech Republic. We are afraid that unrealistic targets would fail reaching even lower, still realistic targets.
Transport:
According to our estimates, the new target assumes approximately doubling the current effort compared to the previous valid target while the exact methodology of its calculation is not in details explained in the proposal and accompanying documents. Due to significant technical obstacles in the implementation of the current goal, it can be expected that the Czech Republic will not be able to meet the new goal either. The newly proposed target of reducing emission intensity in transport by 13% is therefore unrealistic in the conditions of the Czech Republic. For this reason, we oppose the binding nature of this target at national level (together with a minimum sub-target for the share of biofuels (2.2%) and synthetic fuels (2.6%)) by 2030 and rather call for one minimum binding EU-wide target with individual inputs of each Member State. In other words, we support only one mandatory target on the European level with the different commitments of Member State.
Multipliers:
We propose to reintroduce to the draft legislation a system of multipliers in all areas of transport, not just in shipping, so that all modes of transport are put on a level-playing field and simultaneously landlocked countries are not disadvantaged vis-à-vis maritime states. At the same time, urban mobility and its emissions have a major impact on the quality of life and health of citizens, and therefore it makes great sense to support the reduction of its emission footprint with such a "bonus". At the same time, with the proposed binding targets beyond the technological capabilities of individual Member States, it is appropriate to keep in mind such a solution in which the overall system reflects the relative purchasing power of the population and economy of individual countries and thus responds to the expected cumulation of guarantees of origin (not only for biomethane) in richer EU countries.
RES in industry:
Regarding the newly proposed targets on the share of RES in industry (meaning indicative annual increase of 1,1 %), we would like to draw attention to the expected mutual competition and possible overlaps in the accounting of RES in both transport and industry sectors, or the "threat" that available volumes of RES will primarily be used in the transport sector (hypothetical situation when fuel supplier has obligation to account for certain share of RES, but also industry would want to account RES share in its fleet). Moreover, we propose not to explicitly set the share of 50% of green hydrogen in hydrogen consumption in industry in 2030. Other categories of hydrogen will also make a significant contribution to the development of the hydrogen economy in the coming years. Green hydrogen is not competitive yet (due to the high production prices, the absence of the sufficient capacity of electrolysers etc.). Therefore, setting such ambitious RFNBOs target would be costly without prior market ramp-up, which other categories of hydrogen (such as blue and turquoise hydrogen) could ensure. Furthermore, taking into account Hydrogen Backbone project conclusions, the large capacity hydrogen deliveries would be ready in the 30’s so major targets for renewable hydrogen should be directed to that period.
GO:
The scope of the guarantees of origin system should be extended to low-carbon gases in order to achieve a level playing field with other decarbonisation solutions, such as renewable gases. Furthermore, it would contribute to ensuring the supply of larger volumes of decarbonised energy to the market, cross-border trade in decarbonised gases and the overall development of the hydrogen market in the EU.... See attachment.
Read full responseResponse to Revision of the Energy Tax Directive
29 Oct 2021
• Given the recast of Council Directive 2003/96/EC restructuring the Community framework for the taxation of energy products and electricity, Czech Gas Association calls for an optional exemption (in the form of total or partial tax exemptions below the minima as in the current Art. 15h) to be maintained for all low- and middle-income households using natural gas for heating at least until 2033. We deem this optional exemption as justified, as it is in line with a cost-effective decarbonization pathway of the Czech Republic respecting socio-economic challenges associated with Fit for 55 package that the Czech Republic will have to face.
• In the Czech Republic, approximately 290,000 boilers of the 1st and 2nd emission class are still used, but the operation of such boilers will be banned nationally starting in September 2022. It will be necessary to stop operating and replace boilers of a higher emission class (such as automatic coal-fired boilers) by the end of the decade as well. CGA calls for cost-effective energy taxation legislation respecting socio-economic challenges faced by Central and Eastern European Member States. In the light of abovementioned, CGA considers the optional exemption (coupled with existing subsidy schemes) for natural gas intended for use as heating fuel in households, as necessary enabler of the transition from low-efficiency coal-fired boilers to highly-efficient gas condensing boilers and eventually to biomethane/hydrogen-fired boilers.
• Natural gas intended for use as heating fuel benefits from the existing gas infrastructure, which can be used in the future to distribute renewable and low-carbon gases. When the average service life of gas condensing boilers is taken into account, their support through the tax and subsidy policy of the Czech Republic and the European Union does not prevent the achievement of carbon neutrality by 2050 as enshrined in the Climate Law.
• CGA strongly disagrees with the proposed minimum tax rate for natural gas intended for use as motor fuel. The proposed minimum tax rate for natural gas intended for use as motor fuel (7.17 EUR/GJ) represents steep increase in comparison with the current the minimum tax rate, which is 2.6 EUR/GJ.
• Gas mobility can effectively contribute to decarbonization of the transport sector by creating cost-effective synergies with electromobility. Tailpipe emissions from cars that use natural gas as motor fuel are a quarter lower compared to gasoline-powered cars. Biomethane de facto reduces emissions by up to 65%. In addition, LNG and CNG could also provide a cheap and effective solution to significantly reduce not only CO2 emissions but also local pollutants such as NOx, SOx, PM10 and PM2.5.
• What’s more, gas mobility does not create so-called "lock-in" effect. Infrastructure supporting the use of LNG and CNG in the transport sector can be used in the transition to bio-LNG and bio-CNG-powered cars. Biomethane in the form of bio-CNG and bio-LNG is 100% compatible with technologies for the use of natural gas.
• CGA also calls European Commission to clarify definition of ‘sustainable biogas’ and ‘non-sustainable biogas’, which has no legal definition (unlike ‘sustainable food/feed crop biogas’, and ‘advanced sustainable biogas’ which are defined in RED).
Read full response29 Oct 2021
• CGA considers maintaining Effort Sharing Regulation (EU) 2018/842 as a positive step by the European Commission in light of the revision of the 2030 climate & energy framework. Sectors covered by this Regulation (e.g. the buildings sector) do not respond dynamically to market-driven price signals due to low price elasticity of demand and structural barriers. Therefore, there is a need for a different (tailor-made) approach in order to bring about further emission reductions with socially acceptable costs.
• Given the success of national programmes such as New Green Savings, CGA believes that the Czech Republic's national target for reducing emissions in sectors falling under the scope of the Effort Sharing Regulation can be met through implementation of national policies.
• CGA calls for the continued support for the use of highly-efficient gas condensing boilers in the buildings sector in order to realize cost-efficient energy savings and emission reductions. The capacity to reduce emissions under the Effort Sharing Regulation is possible and it is also well demonstrated by the boiler subsidies scheme that has been implemented by the Czech Republic. For example, in the Czech Republic boiler subsidies scheme has led to the replacement of approximately 60,000 of 1st and 2nd emission class boilers so far. At the time of the introduction of the scheme, boiler subsidies were to replace approximately 350,000 boilers of the 1st and 2nd emission class. It can therefore be stated that approx. 290,000 boilers of the 1st and 2nd emission class are still in operation in the Czech Republic and they must be decommissioned and replaced, otherwise users will face fines by operating them after 1 September 2022. With regard to European commitments, it will be also necessary to replace boilers of a higher emission class (automatic coal-fired boilers) by the end of the decade.
• In the European Union as well as in the Czech Republic, biomethane represents untapped potential that will lead to substantial emission reductions in the road transport. However, CGA is of opinion that biomethane has not received adequate support from the European Union and that adequate incentives must be provided for biomethane production (CapEx/OpEx support) by the European Union and the Member States as for other renewable energy sources (e.g., RES-E). Therefore, CGA calls for, among other things, a change in the methodology for measuring emissions from “tank-to-wheel” to “well-to-wheel”, which is a technology-neutral approach to the decarbonisation of the transport sector.
• The National Energy and Climate Plan of the Czech Republic envisages biomethane production of 491 million m3 in 2030.
• To meet the 13% GHG intensity reduction target in the transport sector and reducing emissions under the Effort Sharing Regulation by 26% by 2030, the use of advanced biomethane is necessary for the Czech Republic to comply with these targets.
• It must be acknowledged by the European Commission that gas mobility can effectively help to decarbonize the transport sector by creating cost-effective synergies with electromobility. Tailpipe emissions from cars that use natural gas as fuel are a lower by 25% compared to gasoline-powered cars. Biomethane de facto reduces emissions by up to 65% or more (depending on feedstock used for production of biomethane) on the “well-to-wheel” basis. In addition, LNG and CNG could also provide a cheap and effective solution to significantly reduce not only CO2 emissions but also local pollutants such as NOx, SOx, PM10 and PM2.5.
• Besides the aforementioned, we would also avoid carbon lock-in effect by initially encouraging LNG and CNG in the transport sector as the relevant infrastructure can subsequently be used by bio-LNG and bio-CNG. As biomethane, in the form of bio-CNG and bio-LNG, is 100% compatible with natural gas technologies: refueling infrastructures and vehicles are ready to switch full biomethane at any time, at zero cost.
Read full responseResponse to Updating the EU Emissions Trading System
29 Oct 2021
Removal of the exception for the financing of fossil fuel-fired district heating (DH) in certain Member States from the Modernization Fund may hinder transformation of the DH (the so-called coal-to-gas switch) and is not in line with a cost-effective decarbonization pathway of the Czech Republic, which threatens the fulfillment of the Czech Republic's future climate and energy commitments.
Given the different decarbonization trajectories of the Member States and in the context of the diversity of energy mixes, Central and Eastern European countries (with a high share of coal in their energy mix) should be allowed to finance coal-to-gas switching projects under the Modernization Fund (especially in DH).
Czech Gas Association requests to keep the current amount of the Modernization Fund (i.e. 2% plus allowances relocated by the Czech Republic (from solidarity mechanism and derogation allowances – Art. 10c of the Directive)) and the possibility of supporting the transformation of the DH through the coal-to-gas switching in the Fund’s scope. Otherwise, the problem of retroactivity arises (support schemes are already in place in the Czech Republic) and stable and predictable regulatory environment for investors is jeopardized, especially in the context of future investments in the decarbonization of the DH.
Coal-to-gas switch and the use of natural gas in the DH can ensure smooth and cost-effective decarbonization of heat supply in the DH, which is delivered to 1,6 mil. households (out of roughly 4,5 mil. households in the Czech Republic) and industrial consumers in the Czech Republic, and thus prevent the disintegration of DH.
The extension of the Emissions Trading Scheme (ETS) in a separate form to the buildings sector will have significant negative socio-economic impacts on low-income and middle-income households in the Czech Republic.
Given the structural barriers and the low-price elasticity of demand associated with the buildings sector, Czech Gas Association does not consider the ETS to be an appropriate carbon pricing instrument for the sector.
From the Czech Gas Association perspective, a national solution (e.g. a carbon tax) respecting the socio-economic situation in the Czech Republic is a more appropriate carbon pricing instrument for the buildings sector. Moreover, the national solution will enable to design boiler subsidies in an effective manner, so that they are not devalued due to the high price of the emission allowance.
Number of studies point out that the price of the emission allowances in the separate ETS would have to reach circa. 180€/tCO2 to effectively decarbonize the buildings sector. Notwithstanding, that the European Commission uses carbon price of 40€t/CO2 in 2030 as a benchmark for the separate ETS in its Impact Assessment, which we do not consider as realistic.
Measures in the event of excessive price increases (Art. 30h) or the creation of a new market stability reserve in the context of a separate ETS for the buildings sector do not represent a solution from the customer / household point of view. Measures in the event of excessive price increases do not represent the solution to tackle price spikes of emission allowances in the separate ETS at least as the currently designed under the Art. 30h. Notwithstanding, that the number of EUAs placed in the new MSR and number of EUAs released under Art. 30h in the event of excessive price increases is not addressed (what are the assumptions that led the Commission to propose to put in the new MSR that amount of EUAs?) in the Impact Assessment.
Fuel suppliers tend to reflect the price of the allowance in the price of fuels in full and households have a limited possibility to use hedging to insure the price for a commodity, which serves to meet their essential needs (e.g. heating in winter). Thus, Czech Gas Association is concerned about the negative socio-economic impact that the proposal would have not only on households suffering from energy poverty
Read full responseResponse to Commission Delegated Regulation on taxonomy-alignment of undertakings reporting non-financial information
2 Jun 2021
The Czech Gas Association (hereinafter CGA) is an independent association of companies and experts operating in the gas and related industries. It brings together organizations active in the gas industry, along with research and scientific institutes, and further comprises experts whose specialization corresponds to the focus of the CGA.
CGA would like to express its concern regarding the Taxonomy Delegated Act supplementing Regulation (EU) 2020/852 of the European Parliament and of the Council by specifying the content and presentation of information to be disclosed by undertakings subject to Articles 19a or 29a of Directive 2013/34/EU concerning environmentally sustainable economic activities, and specifying the methodology to comply with that disclosure obligation.
CGA is of an opinion that aforementioned delegated act does not reflect concerns raised in the public consultation on the Taxonomy Climate Delegated Act. There have been 4 types of
criticism:
• Taxonomy is too tight or too loose
• Taxonomy goes beyond existing EU legislation
• More work is needed on the Taxonomy usability
• Taxonomy is too binary in its current design
Delegated Act supplementing Article 8 of the Regulation (EU) 2020/852 only reinforces the criticism of the Taxonomy (notably binary nature of the Taxonomy and tightness). Article 2 of the Delegated Act fails to recognize Conclusions of European Council meeting (10 and 11 December 2020) , which have reiterated role of natural gas as transitional technology:
“The new 2030 target needs to be achieved in a way that preserves the EU’s competitiveness and takes account of Member States’ different starting points and specific national circumstances and emission reduction potential, including those of island Member States and islands, as well as efforts made. The European Council acknowledges the need to ensure interconnections, energy security for all Member States, energy at a price that is affordable for households and companies, and to respect the right of the Member States to decide on their energy mix and to choose the most appropriate technologies to achieve collectively the 2030 climate target, including transitional technologies such as gas.“
To illustrate, labeling cogeneration of heat/cool and power from gaseous and liquid fuels as taxonomy-non-eligible economic activity could distort perception of natural gas as transitional fuel and put it into the same category as power generation activities that use solid fossil fuels, which is stipulated in Art. 19(3) of the Regulation (EU) 2020/852.
CGA is well aware that the European Commission has announced that in the Q4 2021 it will come up with the Complementary Delegated Act specifically covering how certain economic activities, primarily in the energy sector, contribute to decarbonization. However, there is still possibility that the Complementary Delegated Act will not be published/will not enter into force by 1st January 2022 and such a concern should be taken into account. In that regards, entry into force of the supplementing delegated act should be postponed or (ideally) a new category for activities not yet covered by the taxonomy, which would clearly distinguish between taxonomy-non-eligible activities and activities under scrutiny, should be created. This proposal is in line with what Commissioner McGuinness stated: “Taxonomy is a living document. It is not just once off, it will evolve with science and technology and when we review our legislation which will eventually occur.”
Read full responseResponse to Revision of the guidelines for trans-European Energy infrastructure
8 Mar 2021
The Czech Gas Association (CGA) welcomes the Commission's proposed revision of the current TEN-E Regulation to better reflect the new political context and the goals of the European Green Deal. The CGA would like to make some comments and suggestions of substance aimed at improving the effectiveness and functioning of the revised approach.
The TEN-E Regulation represents a key policy instrument for the development of well-integrated European energy infrastructure and for the achievement of decarbonization. It is one of the main tools contributing to the creation of a hybrid energy system, building on the complementarity between electricity and gas, and it may provide the right framework to deliver the Union’s sustainable decarbonisation pathway, both in an environmental and economic sense. Thus, it is necessary it includes all technologies from all energy systems that can contribute towards achieving the EU’s targets.
The TEN-E Regulation should not be targeted only to achieving climate and energy targets but also to contributing to all EU’s objectives including such as market integration, energy security and affordability of energy. Moreover, the revised regulation should be technology neutral, i.e., no technology should be excluded if it contributes to achieving the before-mentioned objectives.
CGA would like to address following issues in its position:
1. Framework for repurposing / retrofitting of existing infrastructure
2. Technology neutrality will lead to hydrogen market ramp-up
3. Traditional gas projects should not be excluded
4. Role of gas TSOs
5. Cross-border criteria
We fully support that assets listed in points 3 (a), (b), (c), and (d) in Annex II may be converted from natural gas dedicated to hydrogen (repurposing gas infrastructure). However we suggest that also retrofitting of existing infrastructure not only for pure hydrogen networks but also to a network able to transport admixtures of methane with hydrogen should be covered by Annex II. In general the proposed TEN-E Regulation does not in CGA’s view fully outline the regulatory framework for the repurposing and retrofitting of existing gas infrastructure to enable the integration of new clean gases, including hydrogen. We suggest to add definitions of repurposing and retrofitting of the existing gas infrastructure to the revised TEN-E regulation. In our view the repurposed / retrofitted infrastructure means physical upgrade of existing natural gas infrastructure for a use with pure hydrogen (repurposing) or with admixtures of methane with hydrogen at a pre-defined level (retrofitting).
Moreover, it should be allowed that the repurposed/retrofitted infrastructure may transport methane for a pre-defined period until there will be a sufficient demand/supply for hydrogen/blends. The repurposing of gas infrastructure for hydrogen/blends must take place in advance so it is available when demand and supply emerge. The readiness of infrastructure might be crucial for any business entity intending to decide whether to invest into hydrogen technologies.
To facilitate achievements of volumes needed, the TEN-E framework should support the various types of renewable and low-carbon hydrogen.
Taking into account that revised TEN-E regulation covers CO2 transport infrastructure, CGA believes that revised TEN-E should cover not only production of green hydrogen in electrolysers but also low-carbon hydrogen production from natural gas. Thus, we are of an opinion to not exclude projects related to production of blue/turquoise hydrogen while using SMR/CCSU or pyrolysis technology as it is currently the most economic way of hydrogen production. Without the economically more attractive blue/turquoise hydrogen production, hydrogen technology might not achieve the needed economies of scale. Transition from blue/turquoise to green hydrogen can be done at a later stage.
Full text of the CGA's position addressing all the abovementioned issues is attached to the feedback.
Read full responseResponse to Revision of EU rules on Gas
8 Mar 2021
The Czech Gas Association (CGA) welcomes the possibility to comment on the inception impact assessment on the revision of the Gas Directive and Gas Regulation and would like to express its opinions on the Hydrogen and Gas markets Decarbonisation Package.
The CGA argues for application of the Internal Energy Market (IEM) rules such as unbundling and Third Party Access outlined in the Gas Directive to the future hydrogen market. Thus, incorporating the rules for hydrogen in the gas legislation would be the most efficient way of ensuring regulatory alignment between the two closely related energy vectors. Nevertheless, the CGA recognizes the need to establish a framework for hydrogen, which is tailored to the specific stage of development of the hydrogen and renewable, decarbonized and low carbon gases market. This may imply some variations from the gas legislation at least for a transitional period.
The CGA believes that blending of natural gas and hydrogen will be instrumental in scaling up hydrogen production and facilitating transport of hydrogen when volumes are not sufficient for dedicated hydrogen system. Therefore, we argue for a recognition of blending in the gas legislation. TSOs should be able to fully recover costs stemming from repurposing/retrofitting of pipelines to accommodate hydrogen blended in the natural gas flows.
The EU gas/hydrogen legislation should explicitly recognise that existing gas TSOs/DSOs/SSOs should be permitted to own and operate of hydrogen infrastructure. Authorising gas TSOs/DSOs/SSOs to carry out activities related to the development, integration and operation of hydrogen infrastructure would facilitate an efficient way forward due to the experience of TSOs/DSOs/SSOs in planning, financing, constructing, operating and maintaining gas infrastructure.
Repurposing/retrofitting of gas pipelines will play crucial role in the development of hydrogen market. Thus, we argue for a clear regulatory framework for the repurposing/retrofitting of existing gas infrastructure, which will enable the uptake of new clean gases, including hydrogen in a cost-effective and timely manner. It should be allowed that the repurposed/retrofitted infrastructure may transport methane for a pre-defined period until there will be a sufficient demand/supply for hydrogen/blends. Costs of repurposing should be recognized by the NRAs. Similarly, costs of retrofitting the network to accommodate hydrogen/gas blends should be appropriately recognized by the NRAs.
We believe that until the market for new clean gases is secure and competitive there should be a lot of flexible solutions created to enable its ramp-up, such as e.g. regulatory sandbox. It would allow R&D activities and innovative projects to be handled under more flexible terms regarding general rules such as state aid, funding access criteria, cost socialisation via regulated assets and based on specific regulatory oversight.
The introduction of incentives for renewable, decarbonised and low-carbon gases production will be essential to realise the EU’s decarbonisation goal. Incentives must be introduced to unlock the full potential these technologies can have in decarbonizing the energy market and to ensure a level playing field between the existing technologies.
Gas legislation should create a framework for system integration between gas and electricity sectors. The sector integration will require coordinated approach to infrastructure planning between gas and electricity sectors. We expect that such a harmonized planning will lead to inclusion of all relevant projects from all energy sectors and thus lead to an affordable and effective creation of a well-integrated energy system.
The question of gas quality, especially connected to production of hydrogen by electricity from intermittent sources of renewable electricity, must be addressed in the gas legislation. Any disruptions caused by possible changes in gas quality that might affect consumers must be prevented.
Read full responseResponse to Proposal for a legislative act on methane leakage in the energy sector
25 Jan 2021
The Czech Gas Association would like to share its experience and views on the topic of methane emissions with special focus on its area of expertise – the gas sector.
From the gas business perspective, methane emissions have been primarily related to security concerns because natural gas leaks could pose a significant safety risk. Therefore, gas companies possess experience and equipment to detect and mitigate them in time. However, the focus has been to measure concentration levels, not the absolute amounts of gas emitted. Gas infrastructure companies keep an account of total gas losses per year including methane emissions, but not necessarily in the detail required by OGMP 2.0 standard. The OGMP 2.0 might be used as a template but the Commission should bear in mind that it has been primarily tailored for upstream companies, i.e. the biggest emitters in their respective value chains and consider the level of detail needed, when extending the standard to the mid- and downstream companies given the limited volume of their emissions. All gas technology is regularly tested for concentration of fugitive emissions on a ppm scale, i.e. how many CH4 parts per million are emitted. Any figure above zero constitutes a possible safety leak and is treated as soon as possible. Continuous measurement and reporting of these occasional small leaks for OGMP 2.0 would be inefficient. Introduction of well-defined minimum levels for reporting paired with best practices for leak detection and repair programmes would be a better way forward.
With regards to reporting, Czech Gas Association suggests that the option 2.C would be the most effective one. This is the only option from the list which explicitly mentions coal. In our view, this is an important factor as coal mines are a source of methane emissions located directly in the European Union. Even though many countries have set a deadline for using coal, it might be as far as 2038, for example in Germany or the Czech Republic (still under discussion). This means that coal will remain one of the key sources of primary energy in our country and continue to generate methane emissions at least for the next 10 years without much change. Should these data be missing, the endeavour to manage methane emissions would be limited.
The mitigation objective focuses on leak detection and repair (LDAR) programmes as well as elimination of venting and flaring. Flaring is not used by gas companies in the Czech Republic, anymore. With regards to venting, it is mostly used before major maintenance or investment actions, but not as a part of routine operation. There is a strong financial incentive to keep methane emissions incl. venting at their minimum because they constitute a loss of a commodity which has to be recovered for customers through a purchase of natural gas at a market price. While we recognize the value of the study by prepared IEA, we would like to pinpoint that its large scope is prone to generalization. The assumption that 40% of emissions can be reduced at no net costs may be correct from the global perspective, but in the EU this is not the case. Therefore, the Commission should ensure that financial support is available to companies willing to invest in further abatement measures in order to contribute to joint mitigation efforts while maintaining their competitiveness. Also, authorities should recognize and create positive incentives for regulated companies to curb methane emissions related to their area of business.
The Czech Gas Association believes that the European Commission should pay a special attention to production of oil, gas and coal, even if located outside of the European Union and find a way to incentivize good practices leading to lower amounts of global methane emissions. Also, the Commission should focus its efforts on major sources of methane emissions within the EU, i.e. agriculture and waste sectors, as the Commission pointed out in its Methane Strategy published in 2020
Read full responseResponse to Climate change mitigation and adaptation taxonomy
17 Dec 2020
Hereinafter, the Czech Gas Association would like to express its initial view on the proposal of the delegated act (DA) presenting technical screening criteria. We believe fit for purpose Technical Screening Criteria (TSC) in the DA will be crucial, in particular for enabling and transitional activities which would facilitate a swift and decisive decarbonization effort towards 2050, while ensuring an overall adequacy of the energy system, affordable energy and a secure energy system.
We welcome the fact that the proposed DA recognizes that TSC should take into account the nature and the scale of the economic activity, including whether it is an enabling activity or whether it is a transitional activity.
We believe that the activities related to gaseous fuels fully respond to these characteristics and should be included in this approach in light of the contribution they bring to the overall security, resilience and sustainability of an integrated energy system. Gas value chain contributes to the energy system in terms of security of supply, storability and flexibility, particularly as a low-carbon alternative to solid fossil fuels and in support to an additional deployment of renewable energy and as an alternative fuel in transport. Moreover, thanks to the gradual replacement of natural gas by renewable, decarbonized and low-carbon gas in the mid/long-term, while in the short term a fuel switching from coal towards gas can ensure substantial emission reductions in the energy sector, as demonstrated by the latest EU carbon market report.
We urge the European Commission to provide a dedicated section for the transitional activities as well as for enabling activities. We also call for a revision of emission thresholds proposed in the Annex I and Annex II to the DA that will respect the emission performance standards associated with the existing technology. This would allow for a regular stock-taking exercise and would ensure a level – playing field on the approach related to best available technologies being used as a benchmark.
Furthermore, all economic activities meeting the quantitative GHG emission values for “green” activities should be considered as significantly contributing to climate change mitigation. Hence once gas assets are 100% greened through the replacement of natural gas by renewable, decarbonized and low carbon gases, such economic activity should no longer be considered as transitional activity but be fully recognized as “green” activity.
The DA should ensure - when setting the TSC for the energy sector - compliance with existing threshold and sustainability requirements already set in the existing EU sector specific legislation. This includes but is not limited to the Energy Efficiency Directive, the Renewable Energy Directive, the Clean Vehicles Directive, the Industrial Emission Directive etc. which will be subject to revision in light of the revised EU climate and energy targets.
Finally, it is inevitable to mention that the DA should pursue a coherent approach to the transition of the energy system by ensuring that both electrons and molecules can contribute to more sustainable and reliable models, as recognized by the most recent EU Energy System Integration Strategy. In practice, the retrofitting and repurposing of existing assets and investments in new assets should also be taxonomy eligible when a substantial improvement can be demonstrated in the field of energy efficiency/environment and/or climate performance of the asset, for example the improvement provided by a fuel switch in the context of National Energy and Climate Plans. In addition, we see that only through the blending of increasing levels of renewable and decarbonized molecules in the gas grid, underpinned by a clear and stable framework supporting sector integration and the energy union objectives, will we be able to achieve the 2050 objective of climate neutrality in a cost-efficient manner.
Read full responseResponse to Revision of the Energy and Environmental Aid Guidelines (EEAG)
8 Dec 2020
The Czech Gas Association (hereinafter CGA) is an independent association of companies and experts operating in the gas and related industries. It brings together organizations active in the gas industry, along with research and scientific institutes, and further comprises experts whose specialization corresponds to the focus of the CGA.
CGA welcomes the possibility to comment on the inception impact assessment on the revised guidelines on the State aid for environmental protection and energy (hereinafter EEAG) and would like to express its opinions on the revision of the guidelines...
Full text of the CGA's position on the revised guidelines on the State aid for environmental protection and energy is attached to this feedback in PDF form.
Read full responseResponse to Revision of the CO2 emission standards for cars and vans
20 Nov 2020
The Czech Gas Association (hereinafter CGA) is an independent association of companies and experts operating in the gas and related industries. It brings together organizations active in the gas industry, along with research and scientific institutes, and further comprises experts whose specialization corresponds to the focus of the CGA.
CGA welcomes the possibility to comment on the inception impact assessment on the revision of CO2 emissions performance standards for cars and vans and would like to express its opinions on the revision.
Although we understand the intention of the Commission, CGA cannot agree with the evident preference given to the e-mobility over the other alternative fuels. Addressing the issue of CO2 emission performance standards for cars and vans, we have to bear in mind that the basic precondition of the clean mobility is the access to the electricity produced from the renewables. However, the availability of the primary energy sources for the production of the electricity is not the same across the Member States and varies from country to country. From that reason, we strongly argue for the whole cycle Well-to-Wheel to be considered as a complex methodology to assess CO2 reduction. We are of the opinion that Tank-to-Wheel cycle methodology is misleading and only gives a limited insight on CO2 emissions when it comes to comparing e-mobility with gas mobility. For example, CO2 tailpipe reduction performance of natural gas is -23% compared to gasoline, while biomethane is de facto driving the reduction up to -35% on a Well to Wheel basis. What’s more, LNG and CNG could as well provide a cheap and effective solution to significantly reduce not only CO2 emissions, but as well harmful local pollutants such as NOx, SOx and PM in the transport sector. Besides the aforementioned, we would also avoid carbon lock-in effect by initially encouraging LNG and CNG in the transport sector as the relevant infrastructure can subsequently be used by bio-LNG and bio-CNG. As biomethane, in the form of bio-CNG and bio-LNG, is 100% compatible with natural gas technologies: refueling infrastructures and vehicles are ready to switch full biomethane at any time, at zero cost.
CGA is a long-term advocate with an unchanging opinion that the overall target should be always based on a fuel and technology neutral approach with maximum use of renewable fuels which are already available and guarantee environmental benefits. Last but not least, we would like to point out that the inception impact assessment is not quite clear where is the dividing line between vans and LDVs´.
Full text of the CGA's position on the revision of the CO2 emissions performance standards for cars and vans is attached to this feedback in PDF form.
Read full response20 Nov 2020
The Czech Gas Association (hereinafter CGA) is an independent association of companies and experts operating in the gas and related industries. It brings together organizations active in the gas industry, along with research and scientific institutes, and further comprises experts whose specialization corresponds to the focus of the CGA.
CGA welcomes the possibility to comment on the inception impact assessment on the review of national emissions reduction targets (Effort Sharing Regulation) based on 2030 climate target plan and would like to express its opinions on the review of the Effort Sharing Regulation.
CGA considers energy taxation as the way of the carbon pricing for non-ETS sectors (especially in building sector, where there is a need to reflect national specificities and energy poverty, hence a need for tailored-made solutions on MS level with some minimum level of EU coordination). Moreover, we are of the opinion that the carbon pricing system based on the energy taxation rather than EU ETS is easier to implement and it has clear advantages in terms of system predictability and stability. Yet, we see that for transport sector, a unified EU-wide approach would be optimal, as individual national solutions might lead to relative comparative disadvantage in the EU market or export emissions from one Member State into other with less strict policies. Thus, CGA argues for differentiated tax rate under the revised Energy Taxation Directive for buildings sector as it respects different socio-economic conditions of EU Member States and is in line with the idea of just transition, while in the transport sector we support unified EU-wide carbon tax rather than extended EU ETS...
Full text of the CGA's position on the review of the Effort Sharing Regulation is attached to this feedback in PDF form.
Read full responseResponse to Updating the EU Emissions Trading System
20 Nov 2020
The Czech Gas Association (hereinafter CGA) is an independent association of companies and experts operating in the gas and related industries. It brings together organizations active in the gas industry, along with research and scientific institutes, and further comprises experts whose specialization corresponds to the focus of the CGA.
CGA welcomes the possibility to comment on the inception impact assessment on the updating the EU emissions trading system (ETS) and would like to express its opinions on the revision of the EU ETS.
CGA considers energy taxation as the way of the carbon pricing for non-ETS sectors (especially in building sector, where there is a need to reflect national specificities and energy poverty, hence a need for tailored-made solutions on MS level with some minimum level of EU coordination). Moreover, we are of the opinion that the carbon pricing system based on the energy taxation rather than EU ETS is easier to implement and it has clear advantages in terms of system predictability and stability. Yet, we see that for transport sector, a unified EU-wide approach would be optimal, as individual national solutions might lead to relative comparative disadvantage in the EU market or export emissions from one Member State into other with less strict policies. Thus, CGA argues for differentiated tax rate under the revised Energy Taxation Directive for buildings sector as it respects different socio-economic conditions of EU Member States and is in line with the idea of just transition, while in the transport sector we support unified EU-wide carbon tax rather than extended EU ETS.
Full text of the CGA's position on the revision of the EU ETS is attached to this feedback in PDF form.
Read full responseResponse to EU Methane Strategy
5 Aug 2020
The Czech Gas Association welcomes the initiative to gradually reduce methane emissions and supports joint efforts to decrease GHG emissions.
However, it must be emphasized that it is necessary to adopt a complex approach and cover all sectors emitting methane. Around 40 % of global CH4 emissions originate from natural sources, the rest, 60 % is caused by human activity. The largest source of anthropogenic CH4 emissions are livestock and other agricultural practices (~24 %), fossil fuels (~20 %), and the decay of organic waste in municipal solid waste landfills (IEA). Methane emissions from the gas sector represent a marginal share in all the methane emissions both in the Czech Republic and in the EU.
Read full responseResponse to Revision of the EU Emission Trading System Monitoring and Reporting Regulation (MRR)
23 Jul 2020
The Czech Gas Association (CGOA) welcomes the opportunity to comment on “Draft Implementing Regulation amending and correcting Implementing Regulation (EU) 2018/2066 on the monitoring and reporting of greenhouse gas emissions pursuant to Directive 2003/87/EC of the European Parliament and of the Council” (MRR revision). CGOA welcomes that MRR revision recognizes role of biofuels and guarantees of origin (GO) in EU ETS monitoring, reporting and verification process and thus pave the way to foster decarbonisation efforts in installations under the EU ETS regime.
Read full responseResponse to A EU hydrogen strategy
8 Jun 2020
The Czech Gas Association (CGOA) finds that the EU Hydrogen Strategy is key to facilitate sector coupling/integration as well as bringing in decarbonisation of energy-intensive industries such are heating sector and long-haul transportation. Furthermore, the EU Hydrogen Strategy should provide the framework for valuing hydrogen contribution to the EU energy system. The incentive structure for market participants to invest in industrial scale of hydrogen production (P2G, SMR, pyrolysis deployment) should be ensured. Also, legal and regulatory frameworks should be updated to reflect production, transport and utilization of hydrogen (both green and blue).
You could find the position paper of the CGOA here attached.
Read full responseResponse to Revision of the guidelines for trans-European Energy infrastructure
8 Jun 2020
The Czech Gas Association (CGOA) welcomes the European Commission’s plan to revise the current TEN-E Regulation, which should support the utilisation of existing gas infrastructure and recognise that gas infrastructures are already capable of transporting new gases and can be progressively developed, adapted or repurposed to further accommodate these gases. The TEN-E Regulation should be non-discriminatory, it should not distort market conditions for different types of fuels and technologies which can equally contribute to achieve decarbonization (biomethane vs. hydrogen).
You could find the position paper of the CGOA here attached.
Read full responseResponse to Strategy for smart sector integration
21 May 2020
The Czech Gas Association would like to highlight, that when analysing energy system integration, the holistic approach should be always taken into account and besides electricity sector, the strategy has to focus equally on heating and cooling, transport and energy use in industry. Otherwise, proposed solutions might be oversimplified and not meeting all the needs of the complex energy systems and needed energy carriers.
Economic costs and technical challenges associated with meeting our climate-energy objectives will be enormous and that is why the whole process and path to reaching energy transition objective must be very well balanced and well-thought through and taking due account of all the tools we have available in the short term, medium term and long term and maximising positive effects they can deliver. For minimising overall economic costs of energy transition it is vital not to prematurely eliminate natural gas-based solutions in the sake of ultimate zero-carbon future solutions while these are still not commercially or technically fully available as half a loaf is better than no bread at all.
EU climate and energy policy should focus not only on the end solution and preferred technologies in 2050 horizon, but it should present a credible short to medium term trajectory based on technologically neutral usage of available technologies and non-discriminatory support of immature technologies. We should avoid ultimate winner or loser-picking and provide all potential solution fair chance of success.
Read full response