DEPA INFRASTRUCTURE S.A.

DEPA INFRA

DEPA INFRASTRUCTURE IS A GREEK HOLDING COMPANY OF THE THREE MAIN GAS DISTRIBUTION COMPANIES ITS GOAL IS TO COORDINATE IN AN EFFICIENT MANNER ITS SUBSIDIARIES MAINLY IN THE GAS (AND NEW GASES) SECTOR

Lobbying Activity

Meeting with Ditte Juul-Joergensen (Director-General Energy) and Shell Companies and

21 Oct 2022 · Commission proposal on measures on energy prices and security of supply. Innogy Česká republika and Bulgargaz also participated.

Response to Revision of EU rules on Gas

9 Mar 2021

DEPA INFRASTRUCTURE S.A. (Greece)welcomes the initiative of the Commission to update the Directive and Regulation on the natural gas market and networks towards the deployment of renewable and low-carbon gases (including hydrogen and biomethane)- “new gases”, while recognizing the significant role of natural gas in the transition towards climate neutrality by 2050.As the existing regulation of EU energy deals, mainly, with the market liberalization that differs from the decarbonization issue, it must integrate the new gases to achieve the Green Deal goals.Our recommendations are: *provide a well-defined framework for all types of new gases through strengthening the role of biomethane and including H2 (blue and green one), *provide technical and regulatory guidance for the integration of new gases in the existing infrastructure to avoid decommissioning issues and an enabling framework to stimulate the deployment of H2 applications and the use of existing gas infrastructure (e.g. certification, guarantees of origin), *Provide clarity on access to infrastructure through a well-defined set of rules about terms and conditions for the new gases’ injection into the gas networks, *Harmonized standards regarding the technical specifications to inject H2 within natural gas infrastructure are needed.A common EU approach about the levels of H2 concentration permitted in the gas network and the relevant gas quality is needed to strengthen H2 production and demand and facilitate the cross-border interoperability.The subject levels should be defined in terms of minimum and maximum H2 capacity allowed through the gas network, while flexibility at national level is necessary on the accomplishment of maximum capacity, *In the short term, injecting directly small volumes of H2 into the natural gas grid without the need for high investments is the more effective way to start the integration of the energy carrier into the system. In the medium to long term, converting part of gas networks to 100% H2 (re-purposing) can be considered, *Provide rules on whether H2 should be blended with natural gas (at least in a transitory period) or should be transported in dedicated infrastructure, *The H2 production and storage are classified at EU level as a hazardous activity and under a strict and complicated legal regime in relation with the licenses, the safety rules, and the environmental impact.Developing a favorable regulatory framework that would support the subject activity, based on less restrictions for land use and simplified procedures for environmental permits, but without compromising on health, safety, and protection of environment, is needed and contributes to the decrease of the relevant cost, *Enhance DSOs’ role as decentralized production of new gases requires them to undertake the activity of gas quality control.A set of technical rules and limitations for harmonized quality standards at a regional or EU level is also needed, while quality management at the DSO level requires sufficient level of information, and clarity on responsibilities between producers-DSOs-TSOs and on cost allocation, *Provide for an increased interaction between the DSO and the TSO systems, through an active DSOs’ involvement in the TSOs Development Plans, since the decentralization will have an impact on the operation and planning of the TSO system (counterflow), *Consider the residential heating sector and that many industries are connected with the distribution network through a more holistic approach, *Regarding cost allocation and recovery for network operators, provide the suitable financial tools (linked to new economic and environmental indicators, relevant to the promotion of new gases) in the Tariff Regulations to minimize the expected increase on tariffs to the end users, *Sufficient integration between energy sectors mainly in relation with a coordinated network planning & operation, *Ensure the alignment of the new framework with the GDPR & NIS Directive
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