Elengy
Elengy operates 3 LNG terminals in France.
ID: 470504137940-01
Lobbying Activity
29 Jul 2024
ELENGY feedback on the review of the EU ETS Monitoring and Reporting Regulation ELENGY is promoting two CCS projects, GO CO2 in our Montoir-de-Bretagne terminal, and Rhône CO2 in our Fos terminal. ELENGY welcomes the opportunity to comment on the Commissions draft proposal to update the EU ETS Monitoring and Reporting Rules. Overall, ELENGY supports the changes introduced by the Commission in particular those that build on existing EU legislation, such as the reliance on the provisions of the Renewable Energy Directive (RED) for EU ETS MRR purposes. In particular, we support the link to the Union Database/national database for proof of compliance with the RED GHG savings and/or sustainability requirements and/or other requirements. A simple and harmonized interpretation applicable in all Member States is an absolute must. In addition, compliance with the criteria must be considered demonstrated (shall instead of may be) once the operator provides the required evidence. In Article 39a.5, reference should be made to the interconnected gas infrastructure instead of the interconnected gas grid to reflect regulation 2022/996. We also would like to address two issues regarding : - CO2 in transit after 31st of January - Accounting of transport emissions of zero-rated CO2 Amendment 25c.7 concerning Article 49 of the EU MRR proposes that CO2 transport infrastructure operators can subtract CO2 still in transit on 31st of December from their emissions report for that year if it is transferred to a storage site or another EU ETS installation by 31st of January of the following year. Though, in the case of CO2 shipping, constraints linked to shipping logistics mean that the delay between the initial injection of the CO2 in the terminal tanks and its delivery to a storage site could take more than a month, especially if there is a specific constraint on the 31st of January than can create congestion. Therefore, any CO2 that is still in transit after 31st of January of the following year, and that has not been vented or leaked, should be accounted for in the in-transit reporting of the following year, thus allowing for an opening balance to be transferred. In addition, there should be an alignment with the EU ETS reporting schedule. Amendment 25c.6 concerning Article 49 of the EU MRR introduces a new provision stating that emitted zero-rated CO2 should be considered as if they were fossil emissions within the boundary of CO2 transport infrastructure. As most transported CO2 will be fossil, and as fossil and zero-rated CO2 are to be managed indifferently in the same transport installation, operators such as terminal operators are already incited to minimize CO2 emissions whether or not zero-rated. This provision will not generate any emission reduction. On the other hand, it will negatively impact the economy of zero-rated CO2, an economy that is already less obvious than the fossil CO2. This provision would therefore only generate a risk of less CO2 captured.
Read full responseResponse to Review of the CO2 emission standards for heavy-duty vehicles
19 May 2023
Elengy position Regulation on CO2 standards for heavy duty vehicles Elengy fully supports the objective of a regulation aiming at accelerating the decarbonization of heavy duty transport. Though, Elengy considers that the current Commission proposal is making the underlying assumption that electricity and in the future hydrogen are the only solutions to reduce heavy duty transport carbon intensity, irrespective of the extremely diverse use cases, other efficient decarbonization options, and without properly considering the implementation risks associated which such a scenario. Obviously, electricity has a major role to play, and its development must be fully supported. But electricity will face its own challenges, notably with charging infrastructure deployment, with additional pressure on an already constrained electricity system, with operational performance for long haul transport. In particular, for long haul heavy transport, neither the long haul heavy trucks, nor the truck charging stations are already available. Standards must still be defined. Land must be made available along the highways to multiply charging points. Moreover, this deployment will add a significant electricity demand : up to 65 GW of charging capacity, and up to 39 GW of Megawatt Charging Systems for a 50% reduction objective according to ACEA. Introducing demand side management of charging equipment would further constrain transport operations. This significant additional demand will weigh on an already constrained electricity system, that will have to cope with the variability of renewable production, with increased seasonal demand linked to the deployment of heat pumps if they are not hybrid, with electrification of hydrogen production for industry, and with the decommissioning of coal production. Betting exclusively on electricity is therefore a risky path, all the more since other solutions exist. For instance, biomethane is an already available solution, allowing a lifecycle analysis greenhouse gases reduction on par with fully electric vehicles even running on very low carbon content electricity, with very little local pollutants, with reduced noise, relying on existing infrastructure, that is operationally as performant as current diesel vehicles for long haul usages. Not allowing these solutions to take their share of the decarbonization along with electricity will lead to a cubanisation of European transport : if for insufficient operational usage performance, and / or for insufficient availability / standardisation of MCS, and / or for lack of competitive long haul heavy electric trucks offers, electricity cannot be deployed sufficiently rapidly or in every segment, and OEMs are barred from proposing any internal combustion engine trucks, transporters will continue to use their existing diesel trucks longer and longer. Therefore, Elengy advocates for the introduction of a carbon correction factor, recognizing, e.g. in the case of NGV vehicles the share of RED certified bioNGV delivered in EU NGV fuelling stations. This is a very simple measure to implement, creating coherent incentives between RED incorporation objectives and the CO2 standards. To complement the carbon correction factor, and further accelerate the transition, technical devices similar to the ones used to ensure trucks are effectively using ADBlue could be included to create RED fuels-only vehicles, that can be only refueled at pumps serving 100% RED certified fuels, and would be prevented to access to regular pumps. This mechanism can still rely on existing infrastructure (the fueling station are kept the same, just an additional connecting device is added to distinguish regular pumps, that can already serve biomethane, from 100% RED pumps).
Read full response17 Jun 2022
Please find herewith attached Elengy's contribution.
Read full responseResponse to Proposal for a legislative act on methane leakage in the energy sector
15 Apr 2022
see attached document
Read full responseMeeting with Jens Gieseke (Member of the European Parliament, Shadow rapporteur) and European Biogas Association
9 Mar 2022 · Austausch zur EU-Verkehrspolitik