OpenLobby.EU
Explore

Enagás S.A.

Enagás is Spain's certified independent gas transmission system operator, managing over 12,000 km of pipelines, LNG facilities, and hydrogen infrastructure development across seven countries.

Lobbying Activity

Meeting with Joachim Balke (Head of Unit Energy) and NaTran and Teréga

24 Oct 2025 · The participants presented the state of play and next steps in the development of the the South-West Hydrogen Corridor.

Spanish gas operator Enagás calls for regional flexibility in EU energy security rules

13 Oct 2025
Topic — EU proposal to revise energy security framework for gas, electricity and hydrogen systems.
Message — Enagás requests that storage obligations reflect national specificities, particularly Spain's reliance on LNG rather than underground storage. They want infrastructure planning to account for limited interconnection capacity and seek explicit interconnection targets for hydrogen-compatible infrastructure.123
Why — This would preserve Spain's existing user-based strategic reserve model and avoid cost-sharing distortions from inaccessible EU-wide storage.45
Impact — Other member states lose unified crisis response capacity due to fragmented national approaches to storage.
Read full response

Meeting with Mechthild Woersdoerfer (Deputy Director-General Energy)

1 Oct 2025 · Hydrogen policy

Enagás Calls for Hydrogen Infrastructure Recognition in 2040 Climate Framework

17 Sept 2025
Topic — EU regulation setting a 90% greenhouse gas reduction target by 2040.
Message — Enagás requests that the legislative framework recognize hydrogen infrastructure as strategically important and provide stable conditions for investment. They emphasize the need to leverage existing assets like LNG terminals for hydrogen derivatives and carbon management.12
Why — This would enable them to repurpose existing LNG terminals and maximize infrastructure value while reducing greenfield investment needs.3
Read full response

Enagás Urges Reporting Exemptions for Energy Infrastructure Operators

16 Sept 2025
Topic — This consultation reviews data reporting rules for wholesale energy market transparency and integrity.
Message — Enagás proposes an explicit exemption for infrastructure operators from exposure reporting regardless of their energy volumes. They also recommend excluding auctions with no bids from reporting and maintaining flexibility for lifecycle event channels.123
Why — These changes would reduce administrative costs and prevent conflicts of interest for operators.45
Impact — EU regulators lose forward-looking data intended to detect market mismatches and manipulation.6
Read full response

Enagás urges simplified authorization and longer reporting transition periods

16 Sept 2025
Topic — Rules for authorizing and supervising energy market data reporting platforms.
Message — Enagás requests a simplified fast-track authorization and reduced documentation for reporting entities. They also propose extending the provider substitution deadline to three months.12
Why — These changes would lower administrative costs and prevent unnecessary operational disruptions.3
Impact — Energy regulators might have reduced access to detailed corporate group structures.4
Read full response

Enagás urges EU to let gas operators lead CO2 networks

11 Sept 2025
Topic — Legislative initiative to establish competitive markets and transport infrastructure for carbon dioxide.
Message — The organization argues that natural gas network operators are best positioned to manage CO2 infrastructure due to their existing expertise. They recommend a flexible, hub-based planning approach that avoids imposing uniform regulatory models too early. Additionally, dedicated financing instruments are needed to reduce investment risks for industrial decarbonisation.123
Why — Enagás would secure its market position by repurposing gas assets for CO2.45
Impact — Industrial investors face delays if the EU imposes rigid regulatory frameworks.67
Read full response

Enagás urges EU to prioritize hydrogen and bioLNG funding

4 Sept 2025
Topic — This initiative establishes a strategic framework for investing in sustainable transport fuels.
Message — Enagás requests a technology-neutral strategy focusing on hydrogen and renewable fuels. They propose using carbon contracts for difference to bridge operational funding gaps.123
Why — These investments would help Enagás expand its hydrogen network and maritime bunkering services.45
Read full response

Enagás urges EU to transform LNG terminals into energy hubs

28 Jul 2025
Topic — The European Commission is developing a strategy to address challenges facing European ports.
Message — Enagás calls for transforming LNG terminals into multi-fuel platforms for hydrogen and carbon capture. They advocate for bioLNG incentives and coordinated planning to ensure efficient infrastructure development.12
Why — This approach enables Enagás to repurpose existing gas infrastructure for new energy markets.3
Read full response

Enagás Urges Faster Approval and More Funding for Hydrogen

28 Jul 2025
Topic — A consultation on measures to accelerate the expansion of European energy grid infrastructure.
Message — Enagás proposes a simplified renewal process for infrastructure projects to reduce administrative burdens. They want earlier access to funding and a legal framework for repurposing gas pipelines. The organization also advocates for a significantly increased budget for clean energy grids.123
Why — Streamlined regulations and expanded subsidies would decrease development timelines and financial risks.45
Impact — Foreign energy exporters would face reduced demand as the EU prioritizes domestic hydrogen production.6
Read full response

Enagás urges more funding for hydrogen and CO2 infrastructure

8 Jul 2025
Topic — EU initiative to accelerate industrial decarbonisation and stimulate investments in energy-intensive sectors.
Message — Enagás calls for a substantial increase in funding for energy infrastructure. They argue transport and storage infrastructure must link production with consumption points.12
Why — This funding would support Enagás's strategic shift toward hydrogen and CO2 transmission.3
Read full response

Meeting with Teresa Ribera Rodríguez (Executive Vice-President) and

24 Jun 2025 · Hydrogen Infrastructure Development

Response to Interim evaluation of the Strategic Technologies for Europe Platform (2024-2025)

10 Apr 2025

Enagás is the natural gas transmission system operator and provisional hydrogen transmission network operator in Spain. Additionally, Enagás is actively engaged in Carbon Capture, Utilization, and Storage (CCUS) projects, particularly focusing on CO2 transmission. Notably, our TarraCO2 transmission project was awarded the STEP Seal following its participation in the Innovation Fund 2023 call. As a holder of the STEP Seal, Enagás has already established contact with the Spanish contact point. While the structure and process appear to be sound, there has not been sufficient time to form a well-considered opinion on their efficacy, as we have not yet received comprehensive information about any opportunity for financing. Consequently, we remain uncertain about the effectiveness of the STEP Seal, most likely because it is a new initiative. Furthermore, the recent Communication from the Commission, titled Clean Industrial Deal, articulates that the Commission will explore ways to facilitate additional financing options to scale up support for the Innovation Fund selected projects that have received a Sovereignty Seal under the STEP Regulation. It further states that the Commission will seek to further align funding criteria for the Innovation Fund and national financing, which will accelerate State aid approval for Member States wanting to support projects with a STEP seal. This will clarify the process and give Member States an incentive to allocate more national resources. We fully endorse the provision of additional funding for such projects and strongly advocate for the inclusion of comments regarding this matter in the Interim evaluation, to ensure full compliance with the Clean Industrial Deal. In our opinion, this interim evaluation comes too soon. The novelty of the initiative means that there has not been enough time to gather practical insights or feedback. We believe that a more extended period of observation and interaction is necessary to accurately assess the effectiveness of the STEP Seal and its ability to provide valuable information on financial opportunities.
Read full response

Enagás backs EU plans to simplify taxonomy reporting burdens

26 Mar 2025
Topic — The initiative aims to make EU Taxonomy reporting simpler and more cost-effective for companies.
Message — Enagás supports reducing data points and associated qualitative information to ensure better comparability. They advocate for materiality thresholds to exclude activities representing less than 10% of revenue from reporting. They also favor allowing partial alignment reporting to manage smaller volumes of information.123
Why — The company would significantly reduce its administrative costs and focus resources on core activities.45
Impact — Investors and environmental groups lose comprehensive data on secondary business activities and impacts.6
Read full response

Response to Implementing Act for guidelines on strategic projects

18 Feb 2025

Enagás is the natural gas transmission system operator and provisional hydrogen transmission network operator in Spain. Additionally, Enagás is one of the promoters of the project Pyrenean CO2 Abatement through Sustainable Sequestration Operation (PYCASSO), CO2 candidate project for the PCI status, and is also involved in other CO2 capture and transport projects, such as the Mosusol netCO2 Project and CO2necta Project. Enagás welcomes the Commission's work on the implementation of the NZIA Regulation, particularly in proposing guidelines for the implementation of certain selection criteria for net-zero strategic projects. For all industrial decarbonisation applications, the most optimal technology must be applied to achieve climate neutrality, and Carbon Capture and Storage (CCS) will play an essential role in this sustainable transition. Since CO2 transport is an integral part of CCS value chain, without an efficient and secure transport system, the capture and storage of CO2 cannot be effectively realised. As set out in the NZIA Regulation, in order to facilitate the achievement of the objective of at least 50 million tonnes of CO2 injection capacity, the Union shall make all reasonable efforts to develop the necessary CO2 transport infrastructure, including cross-border infrastructure. To ensure a complete and efficient CCS value chain, it is crucial to start investing in the development of a CO2 transport infrastructure now. Without this investment, there is a significant risk that the necessary infrastructure will not be ready when needed by the EU industry to decarbonise. Another major risk is failing to meet the required deadlines due to delays in the processing of permits. Consequently, considering CO2 transport by pipeline projects as strategic within the framework of the NZIA Regulation will ensure a complete and functional value chain, which is essential for achieving net-zero emission targets. Additionally, faster and more efficient permitting procedures are necessary to guarantee the success of the strategic projects.
Read full response

Response to Implementing Act on non-price criteria in renewable energy auctions

18 Feb 2025

Enagás welcomes the draft of the Implementing Act on non-price criteria that broadens the scope and definition of renewable energy auctions by specifically mentioning electrolysers and any other net-zero technologies falling under the scope of Article 26 of Regulation (EU) 2024/1735 as potential element of renewable energy projects. As, such the current draft recognizes the need to view renewable energy auctions in the much wider scope of integrated energy system transition. By identifying energy system integration as important non-price criteria for the sustainability assessment (Article 15), the Commissions draft aligns with our main criticism that was presented as feedback to the Design elements of renewable energy auctions (guidance) consultation, submitted on March 1, 2024 (https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14122-Design-elements-of-renewable-energy-auctions-guidance-/F3456710_en). Unfortunately, the aforementioned Article 15 in the proposed draft legislation remains rather vague and unspecific for evaluating the system integration of a renewable energy project across various coupled energy systems. The entire Article 15 seems be formulated by having primarily electricity system integration in mind and not multiple different grid infrastructures, as would be the case for electrolysers projects operating at the interface of electricity and hydrogen infrastructure. For example, instead of one grid connection point (Article 15, Paragraph 3), such projects would have at least two connections (electricity and hydrogen). Acknowledging the potential role of renewable energy projects at the interface between various energy carriers should also be reflected in the required flexibility assessment (Article 15, Paragraph 2). Here, the value of the hydrogen grid as flexibility resource for the electricity grid, when operating, for example, electrolysers, must be assessable. The capacity to transfer renewable energy from one energy carrier to another (Article 15, Paragraph 4) as potential assessment criterium remains too vague and ignores that many of the benefits of system integration are beyond energy transfer. Services provided by the hydrogen system that ensure security of supply, meeting flexibility and balancing needs, might be of greater value when assessing the impact of renewable energy projects on both energy systems.
Read full response

Response to Standards for wireless recharging, electric road system and vehicle-to grid-communication of recharging infrastructure

27 Dec 2024

Enagás is the natural gas transmission system operator and provisional hydrogen transmission network operator in Spain. Scale Gas, a company 100% owned by Enagás offers, among others, infrastructure solutions in hydrogen as a fuel in transport mobility. Scale Gas currently operates a 700bar hydrogen refuelling station located in Madrid and aims to invest in the deployment of the national network according to AFIR. Enagás welcomes the adoption of European standards in support of Regulation (EU) 2023/1804 on the deployment of alternative fuels infrastructure and wants to give some feedback regarding the application of EN 17127:2024 standard. Enagás has identified a potential interaction between EN 17127:2024, Outdoor hydrogen refuelling points dispensing gaseous hydrogen and incorporating filling protocols, with ISO 19880-1:2022, Gaseous hydrogen Fuelling stations Part 1: General requirements, since both standards, EN 17127 and ISO 19880-1, encompass very similar aspects, but they are not identical. Specifically, in Spain, there could be indeterminacy regarding the applicable regulations (or an excess, if both are applied), since ISO 19880-1 is also prescribed as mandatory in Royal Decree 919/2006* for the design, construction and operation of hydrogen refuelling stations. Therefore, these standards could create uncertainty regarding which will be legally applicable and some confusion that could impact the legalization of installations. Enagás asks for a clarification within the delegated regulation about the mentioned potential interaction between EN 17127 and ISO 19880-1 standards. *Real Decreto 919/2006, de 28 de julio, por el que se aprueba el Reglamento técnico de distribución y utilización de combustibles gaseosos y sus instrucciones técnicas complementarias ICG 01 a 11
Read full response

Enagás Urges Level Playing Field for Low-Carbon Fuel Certification

25 Oct 2024
Topic — The consultation defines a lifecycle methodology for calculating greenhouse gas savings from low-carbon fuels.
Message — Enagás supports a lifecycle methodology to ensure a level playing field across fuel technologies. They request that financial tools like the Hydrogen Bank remain exclusive to renewable fuels. The company also advocates for integrating national databases to improve certification traceability.123
Why — Integrating its Spanish database would streamline certification processes and reduce administrative costs.4
Impact — Renewable energy developers could lose vital financial support to competing low-carbon fuel projects.5
Read full response

Enagás urges infrastructure alignment in renewable energy auctions

1 Mar 2024
Topic — EU guidance on designing objective and transparent criteria for renewable energy auctions.
Message — Enagás requests non-price criteria supporting aligned renewable and infrastructure development. They argue price-only auctions are unsuitable for grid-connected capacities and need criteria reflecting infrastructure access.123
Why — This approach would provide the infrastructure operator with significantly greater planning security.4
Impact — Developers of low-cost projects in remote locations may struggle against infrastructure-aligned bidders.5
Read full response

Meeting with Maroš Šefčovič (Executive Vice-President) and

5 Feb 2024 · High-Level roundtable with Suppliers

Meeting with Maroš Šefčovič (Executive Vice-President)

31 Jan 2024 · Hydrogen

Meeting with Maroš Šefčovič (Executive Vice-President) and

10 Oct 2023 · Hydrogen

Enagás urges EU to let gas operators manage CO2 networks

31 Aug 2023
Topic — EU initiative on the deployment of carbon capture, utilisation, and storage technologies.
Message — Enagás requests a flexible framework for gas operators to repurpose carbon pipelines. They propose expanding gas network governance to include carbon dioxide infrastructure.12
Why — This would protect current investments by repurposing gas assets and securing revenue guarantees.3
Impact — Consumers and taxpayers may lose if infrastructure costs are shifted to guaranteed revenue schemes.45
Read full response

Enagás Urges Linking Hydrogen Valleys to European Pipeline Network

13 Aug 2023
Topic — This roadmap outlines strategic actions to double EU Hydrogen Valleys by 2025.
Message — Enagás requests a European hydrogen network consisting of pipelines and storage. This infrastructure is essential for meeting the 2030 decarbonisation targets.12
Why — The development of pipeline infrastructure allows Enagás to leverage its expertise in energy networks.34
Read full response

Meeting with Kadri Simson (Commissioner) and

4 Jul 2023 · Latest state of play of H2MED project; development of hydrogen demand, supply and infrastructure.

Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans) and NaTran and

4 Jul 2023 · H2Med corridor

Enagás urges EU to include biomethane and CCU as strategic

27 Jun 2023
Topic — The consultation addresses the Net Zero Industry Act to upscale EU industrial capabilities.
Message — Enagás requests recognizing biomethane and carbon capture as strategic net-zero technologies. They also support codifying biomethane production targets and improving the investment environment through risk mitigation.123
Why — This would secure public support and investment for the company's gas and CO2 infrastructure projects.45
Read full response

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

22 May 2023

Enagas welcomes the European Commissions proposal to amending Regulation (EU) 1227/2011 and Regulation (EU) 2019/942, as part of the revision of the electricity Market Design. As a general overview, Enagás point of view is that: - some of the amendments proposed to REMIT revision are not directly linked to the Electricity market Design, and should not be linked to it; - some of the amendments proposed comes from the market Abuse Regulation and the competition law, and may not be adequate for the energy market; - the definition of PPAT should be remain as it is in the current regulation; - data accuracy, completeness, and publication should be Market Participants responsibility, as owner of the data; - the publication of the inside information should be kept out from REMIT fees. As there is no clear threshold to define inside information, sometimes MPs publish information that is not clearly defined as Inside Information. If inside information is included within REMIT fees, it could make the MPs to reduce the publication of the data, that could have negative effect on the transparency of the energy markets; The European Commission should also have in mind that the application of the amendments should need an implementing period, not included in the proposed amendments. The detailed amendments are included in the attached PDF.
Read full response

Meeting with Stefano Grassi (Cabinet of Commissioner Kadri Simson), Tatiana Marquez Uriarte (Cabinet of Commissioner Kadri Simson)

12 Jan 2023 · H2Med project and other hydrogen-related developments

Meeting with Susana Solís Pérez (Member of the European Parliament)

11 Nov 2022 · Gas Package

Meeting with Pedro Serrano De Haro (Cabinet of High Representative Josep Borrell Fontelles)

11 Oct 2022 · Ms Natalia Latorre was in Brussels and she would like to give a short presentation to HoC on the recent development linked to the geopolitics of natural gas, renewable gases and the security of gas supply in the EU from her company perspective.

Enagás Urges Faster Permitting for Hydrogen and Gas Infrastructure

27 Jul 2022
Topic — European Commission guidance on accelerating permitting for renewable energy and power agreements.
Message — The company wants streamlined environmental authorization procedures for hydrogen electrolysis projects. They propose simplified administrative schemes for small-scale and emission-free hydrogen production. Enagás argues against restrictive rules like additionality that artificially increase hydrogen costs.123
Why — This would lower development costs and accelerate the deployment of hydrogen networks.4
Impact — Groups advocating for strict environmental oversight may oppose simplified licensing regimes.5
Read full response

Enagás urges inclusion of electrolytic hydrogen in renewable methodology

20 Jul 2022
Topic — The Commission is defining how to calculate renewable energy shares in co-processed fuels.
Message — Enagás requests extending the methodology to include renewable hydrogen from sources like electrolysis. They also want clarification on whether synthetic fuels will be treated similarly.12
Why — This expansion would allow Enagás to market electrolytic hydrogen as a renewable fuel.3
Impact — Producers of biological hydrogen lose the competitive advantage of their exclusive regulatory status.4
Read full response

Enagás advocates for carbon circularity in new EU fuel methodology

17 Jun 2022
Topic — The EU is defining a greenhouse gas savings methodology for renewable and recycled fuels.
Message — Enagás suggests sharing emission responsibility between fuel users and capture facilities. They want to exempt gas grid operations from strict emission tracing requirements. The group also supports using yearly correlation to reduce production costs.123
Why — This would reduce administrative burdens and lower capital costs for synthetic fuel production.4
Impact — The EU Emissions Trading System loses revenue if carbon capture facilities are granted exemptions.5
Read full response

Enagás advocates for carbon removal standards supporting synthetic gas infrastructure

1 May 2022
Topic — Establishing a regulatory framework to monitor and certify high-quality carbon removals across Europe.
Message — The EU should create a common standard that interacts with the ETS and renewable gas certificates. The scheme must recognize industrial carbon capture and utilization from fossil fuel sources. Certificates should help lower prices for synthetic fuels like e-methane to aid industrial decarbonization.123
Why — This would allow Enagás to utilize its existing gas storage and infrastructure for new fuels.4
Impact — Environmental groups lose if carbon reuse from fossil fuels is certified as permanent removal.5
Read full response

Meeting with Maria Inmaculada Lopez Martinez (Cabinet of High Representative Josep Borrell Fontelles), Pedro Serrano De Haro (Cabinet of High Representative Josep Borrell Fontelles)

27 Apr 2022 · The Enagás CEO, Arturo Gonzalo was in Brussels for other meetings and he asked to meet the HoC, as HR/VP was on mission. The point of discussion was: the strategic implications of gas networks in Europe.

Meeting with Stefano Grassi (Cabinet of Commissioner Kadri Simson), Tatiana Marquez Uriarte (Cabinet of Commissioner Kadri Simson)

27 Apr 2022 · Introductory meeting and information from Enagás on their strategic plans and projects in terms of security of supply and decarbonisation

Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans), Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans)

27 Apr 2022 · REPowerEU

Enagás Urges Flexible Storage Targets and Fast-Track Project Approval

20 Apr 2022
Topic — The consultation addresses new EU regulations for mandatory gas storage filling levels.
Message — Enagás requests flexible filling targets and a fast-track category for security projects. They also propose tariff discounts and exemptions for regions with low interconnection.123
Why — Enagás would secure faster permitting and potential European funding for its infrastructure developments.45
Impact — Central European nations might face higher costs if isolated regions are exempted from sharing.6
Read full response

Enagás urges flexible methane rules to limit administrative burden

18 Apr 2022
Topic — EU legislative proposal targeting methane emission monitoring and reduction in the energy sector.
Message — Enagás requests flexibility in choosing technologies and alignment with existing reporting standards. They propose annual leak detection campaigns and transition periods for new venting rules. They also recommend against mandatory site-level technology quantification.123
Why — Aligning with current standards would minimize administrative burdens and avoid high technology costs.45
Impact — Environmental groups lose from less frequent leak inspections and potentially slower repair timelines.67
Read full response

Response to Revision of EU rules on Gas

12 Apr 2022

Enagás welcomes the Commision's legislative proposal. Please find below our comments (amendments attached): 1. Vertical unbundling: the ownership unbundling model should be favoured … since it is the most effective one and entailing less regulatory monitoring efforts. Enagás supports the proposal for HNOs and encourages to foresee a transition for gas TSOs to OU by 31 Dec 2030. Unbundling rules must be applied with proportionality. 2. Tolling schemes for operating renewable gases facilities should be compatible with the OU model The ownership and operation under tolling schemes by HNOs/TSOs of conversion facilities contributing to decarbonisation and enabling sectoral integration, such as P2G and biomethane plants, should be fully compatible with unbundling as long as operators do not engage in trading or supply of energy (electricity, gas, hydrogen). 3. Horizontal unbundling: no legal unbundling requites should be established between TSOs and HNOs … since they are unnecessary, disproportionate and counterproductive. Combined operators (network, storage and terminal activities for gas and H2), subject to accounting unbundling under regulatory supervision, should be explicitly allowed to: • Enable the full attainment of synergies between the two grids • Set correct incentives for operators in the context of retrofitting, repurposing and integrated system planning 4. Expand ENTSOG role to H2 activities … like TYNDP and Network Codes, rather than creating the ENNOH. The latter would be up and running no sooner than 2025 and would increase costs and complexity in the EU dialogue. 5. rTPA should be the default regime for H2 networks, while the possibility of nTPA should be limited in time and subject to further predictability requisites at the time of opting for it The application of two different regimes, negotiated and regulated, to a single asset during its useful life creates investment barriers if enough visibility on the methodology to move from one regime to the other is not provided. 6. Financing H2 networks: temporary financial transfers between natural gas and H2 networks should be allowed for a longer period, no shorter than 10 years … collecting the proposed dedicated charge only at exit points to final customers located within the same Member State. 7. Retrofitting and repurposing costs should be allowed by NRAs, establishing EU-level principles. 8. Tariff discounts for renewable and low-carbon gases support the uptake of the hydrogen market and should not privilege imports from outside the EU vs. EU production. The 75% discount at entry points from renewable and low carbon production facilities should be increased to 100%. 9. A rapid development of an EU H2 network and infrastructures is key to meet REPowerEU goals ... and in general for escalating hydrogen production and achieving an internal market for hydrogen, ensuring competitiveness and security of supply. 10. Integrated and harmonised planning requirements should be established More ambition is required as regards integrated system planning, which in the proposal is limited to joint scenarios. Similar planning requirements on all TSOs would ensure consistency at national and EU level. 11. Anchor in EU legislation quotas for renewable gases … in the present Package or in the RED II review, aimed at arriving at competitive prices as soon as possible, is key to reach production targets set in the REPowerEU Communication. This must be underpinned by adequate policy support mechanisms. 12. Gas (GQ) and hydrogen quality (HQ) management responsibilities of network operators should be defined in accordance with the tools at their disposal Provisions on GQ and HQ handling are essential for the internal market , and their related costs must be allowed by the regulatory framework. 13. Blending: the acceptance of gas flows with a 5% H2 content at IPs is essential to support the hydrogen market uptake, and coordination procedures leadtimes should be halved
Read full response

Response to Evaluation of the LIFE Programme 2014-2020

12 Apr 2022

LIFE programme 2014-2020 proved to be a very valuable financing tool to catalyse innovative solutions that contribute to the protection of the environment and climate. From Enagás, we value the Commission initiative to evaluate the impact of the programme, in order to help a more effective implementation of the phase 2021-2027. We believe LIFE programme shall further prioritise projects on clean energy transition, climate mitigation and circular economy, facilitating the evolution towards a neutral, resilient and more efficient energy system. In the context of accelerating climate change, LIFE programme can more effectivelly support European climate change policies (Fit-for-55) by overcoming the market-barriers of key technologies for environmental protection, on real applications. Among the actions in support of higher shares of renewable power in final consumption, the production of renewable and low carbon gases like biomethane, hydrogen and e-methane is key to facilitate the further integration of gas and electricity networks, hence enhancing the resiliency of the whole European energy system under increasingly variable power supply and external events. The progress towards a circular economy and more sustainable waste management (e.g. municipal, agricultural) also finds important synergies with the pursuit of local renewable energy resources. This chiefly includes the production of valuable renewable vectors, like biomethane, indeed increasingly important in the light of the EU energy security of supply perspective and for the decarbonisation of key sectors. Furthermore, sustainable waste management can provide short-term powerful gains on the race against climate change by tackling the effects of methane emissions coming from waste sector. Enagás participated in last year LIFE programme call with a comprehensive project for the “Conversion Of Non-Recyclable Waste Into Clean Renewable Fuel”, in the Balearic island of Menorca. Islands often face additional constrains to their options for waste management and energy supply, such as land limitations (including due to biosphere protection), reduced interconnections, dependences from imports from the continent and often very strong seasonal fluctuations following tourism activity. Those conditions prevent a substantial roll-out of wind and solar generation and make the islands highly dependent on oil imports. The solution developed under LIFE framework is a novel and modular waste-to-biomethane plant that can meet simultaneously waste management and clean energy supply challenges, and is perfectly scalable. It can achieve a 98% biomethane purity as output and a waste-to-energy conversion of 60%. Thinking on the LIFE programme 2021-2027, we believe it is critical to increase the size of the projects like the one above in order to amplify the impact of the solutions, particularly for those closely related with energy and waste management. The demonstratation of these initiatives in a sort of industrial scale is particularly important for those technogies that are also to support the decarbonisation efforts of the EU towards 2030. In our opinion, projects in the order of 10MEUR can create a substantial impact. Not less importantly, last year the LIFE programme already started financing the whole value of assets comprising a project, instead of just the amortisation corresponding to the period the project is in place. We believe this is a suitable approach that shall be kept on the implementation of phase 2021-2027, as it can help to provide the needed security and spur innovation while searching for optimal and impactful solutions. Lately, it is important that LIFE programme continues improving its resolution procedures, in order that the whole process becomes more agile. Most pioneering projects often struggle to find alternative resources to implement innovative solutions, and it is crucial that financial resources from the programme arrive soon to final destination.
Read full response

Response to Revision of EU rules on Gas

12 Apr 2022

Enagás welcomes the Commision's legislative proposal. Please find below comments (amendments in pdf attached): 1. Vertical unbundling: the ownership unbundling model should be favoured … since it is the most effective one and entailing less regulatory monitoring efforts. Enagás supports the proposal for HNOs and encourages to foresee a transition for gas TSOs to OU by 31 Dec 2030. Unbundling rules must be applied with proportionality. 2. Tolling schemes for operating renewable gases facilities should be compatible with the OU model The ownership and operation under tolling schemes by HNOs/TSOs of conversion facilities contributing to decarbonisation and enabling sectoral integration, such as P2G and biomethane plants, should be fully compatible with unbundling as long as operators do not engage in trading or supply of energy (electricity, gas, hydrogen). 3. Horizontal unbundling: no legal unbundling requites should be established between TSOs and HNOs … since they are unnecessary, disproportionate and counterproductive. Combined operators (network, storage and terminal activities for gas and H2), subject to accounting unbundling under regulatory supervision, should be explicitly allowed to: • Enable the full attainment of synergies between the two grids • Set correct incentives for operators in the context of retrofitting, repurposing and integrated system planning 4. Expand ENTSOG role to H2 activities … like TYNDP and Network Codes, rather than creating the ENNOH. The latter would be up and running no sooner than 2025 and would increase costs and complexity in the EU dialogue. 5. rTPA should be the default regime for H2 networks, while the possibility of nTPA should be limited in time and subject to further predictability requisites at the time of opting for it The application of two different regimes, negotiated and regulated, to a single asset during its useful life creates investment barriers if enough visibility on the methodology to move from one regime to the other is not provided. 6. Financing H2 networks: temporary financial transfers between natural gas and H2 networks should be allowed for a longer period, no shorter than 10 years … collecting the proposed dedicated charge only at exit points to final customers located within the same Member State. 7. Retrofitting and repurposing costs should be allowed by NRAs, establishing EU-level principles. 8. Tariff discounts for renewable and low-carbon gases support the uptake of the hydrogen market and should not privilege imports from outside the EU vs. EU production. The 75% discount at entry points from renewable and low carbon production facilities should be increased to 100%. 9. A rapid development of an EU H2 network and infrastructures is key to meet REPowerEU goals ... and in general for escalating hydrogen production and achieving an internal market for hydrogen, ensuring competitiveness and security of supply. 10. Integrated and harmonised planning requirements should be established More ambition is required as regards integrated system planning, which in the proposal is limited to joint scenarios. Similar planning requirements on all TSOs would ensure consistency at national and EU level. 11. Anchor in EU legislation quotas for renewable gases … in the present Package or in the RED II review, aimed at arriving at competitive prices as soon as possible, is key to reach production targets set in the REPowerEU Communication. This must be underpinned by adequate policy support mechanisms. 12. Gas (GQ) and hydrogen quality (HQ) management responsibilities of network operators should be defined in accordance with the tools at their disposal Provisions on GQ and HQ handling are essential for the internal market , and their related costs must be allowed by the regulatory framework. 13. Blending: the acceptance of gas flows with a 5% H2 content at IPs is essential to support the hydrogen market uptake, and coordination procedures leadtimes should be halved
Read full response

Meeting with Tatiana Marquez Uriarte (Cabinet of Commissioner Kadri Simson)

25 Mar 2022 · interconnections and REPower EU

Meeting with Kadri Simson (Commissioner) and

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

Response to European Strategy on international energy engagement

20 Dec 2021

1. Putting more emphasis on the Euro Mediterranean Region Enagás advocates for strengthening the EU energy diplomacy and relationships with the Southern Neighbourhood covering the Euro Mediterranean Region, and more concretely with the main energy actors in the Maghreb region (Algeria and Morocco). Results will not be obtained simply by pushing through and intensifying some of the positive elements of existing policies; rather it could be necessary to develop a new enhanced Euro Mediterranean (Green) Deal. 2. Helping neighbouring countries to accomplish their energy transition The EU should accompany and support its neighbours’ energy transition by offering appealing alternatives and by working together in a coordinated manner, developing joint energy transition pathways, enhancing trade integration, deploying climate finance for both adaptation and mitigation strategies, etc. 3. An EU Energy Diplomacy with concrete goals and based on a sound public-private cooperation When it comes to Energy Diplomacy and engagement, the coordination of public and private sector is of utmost importance. In terms of the energy transition and the future role of natural gas, Enagás believes that the EU Strategy should cover concrete actions related to methane emissions, renewable gases, evolution of energy markets and sustainable finance, among others. 4. Leaving no one behind and ensuring a holistic view in the EU External Relations The EU should run a coordinated effort with its neighbourhood to jointly decarbonise their economies. The EU should help traditional gas exporters (e.g. Algeria) to accomplish its transition away from oil and gas and become a supplier of renewable and low-carbon energy to the EU. The EU should engage somehow in those political disputes between third countries located in the EU neighbourhood which could derive into an energy security risk for the EU. 5. Drawing more benefits from the Euro Mediterranean Region In view of the “Draft UfM Ministerial Declaration on Energy” published in June 2021, Enagás believes that the EU should strengthen the regional energy cooperation by reinforcing the Union for the Mediterranean (UfM). More concretely, the UfM Gas Platform has been developing a good work in the last years, but it requires additional resources and efforts to amplify its role and achieve a successful gas cooperation and coordination in the Euro-Mediterranean region. Its official scope should cover, on a more prominent way, not only natural gas but also renewable gases (biomethane and hydrogen). Moreover, the identification and selection of projects of Euro-Mediterranean interest (PEMIs), would be an advisable measure. 6. A stronger focus on the Western Maghreb Area (Algeria and Morocco) Based on the above, the EU should aim to: - update and revitalise the EU-Algeria strategic partnership on energy signed in 2015, starting again the organisation of the EU-Algeria Energy Business Forum with an annual frequency. - build upon the recently signed EU-Morocco Green Partnership on energy, climate and environment to enhance further and concrete cooperation actions on natural gas, renewable and low carbon gases (biomethane and hydrogen). - enhance the regional cooperation by setting up a Regional Energy Cooperation Platform between Portugal, Spain, Algeria and Morocco. This Platform, chaired by the EC would discuss energy topics (electricity, gas, hydrogen, LNG, security and diversification of energy supply, energy transition scenarios, etc.) of regional interest for advancing together towards a sustainable and climate neutral economy.
Read full response

Response to Count your transport emissions: CountEmissions EU

17 Dec 2021

While the “Sustainable and Smart Mobility Strategy" reveals the main guidelines towards a neutral emission mobility in the forthcoming decades, a transparent and common European methodology is still needed. “CountEmissions EU” is a largely expected initiative that can contribute to the transparent and widespread comparability of GHG emissions. • “CountEmissions EU” methodology should implement a technology neutral approach, allowing a clear comparison between energy vectors and transport modes, from manufacturing and production to end use. It shall substitute the "zero-tailpipe emissions" approach that prevail in some previous legislative pieces. Several regulations proposed in the wake of the Green Deal fail to facilitate the effective contribution of different technologies to a carbon neutral mobility, for example “CO2 emissions for cars and vans”. This piece is based on a purely “zero tailpipe emission” concept, restricting all available solutions to just EVs without further considerations about its real sustainability, for instance against carbon-neutral fuels. Instead, a technically-sound methodology shall transparently implement a Well-to-Wake emission accountability and also incorporate standardized Life-Cyle Assessments (LCA), in line with concerns about the recyclability and extraction of raw materials overseas, increasingly used on mobility solutions. • A transparent methodology will favour the development of renewable and low carbon gases, and effectively contribute to the decarbonisation of large shares of the transport sector. This is particularly the case of vessels and heavy duty vehicles fleets. A transparent comparability would account for the real emission savings of all available technologies, as they thrive where found to be more effective. This is, to minimize abatement costs and to prevent closing the door to growing and effective alternatives. E.g. hydrogen, biogas and e-methane. Following such approach would be particularly effective for maritime and road freighting, as well as for air transportation, where alternatives to high-dense energy carriers barely exist. Renewable and low carbon gases would help to reduce the total cost of ownership of decarbonising assets, provided that an easy access to the gas grid will further lessen renewable energy supply costs. • A common and widespread emission accountability will favour the development of synergies and environmentally sound logistics, leading to a closer integration between energy and transport networks. The extension of GHG accountability and recognized practices will facilitate the convergence of logistic operators and favour major decarbonisation investments in ports and transport nodes. Member States shall support initiatives that profit from combined transportation. A particularly effective synergy is a closer coupling between TEN-T and TEN-E networks. In a context of increasing penetration of renewable energy, renewable and low carbon gases will progressively blend into current gas infrastructure, bringing sustainable energy to transport fleets. • The new methodology arising from “CountEmission EU” shall be simple and fully compatible with international initiatives and other EU schemes, such as Guarantees of Origin and ETS. A critical question for an effective “CountEmission EU” derived methodology is to be simple and easy to implement across Member States. A "CountEmissions EU" regulation may be hence a reasonable instrument to set basic rules so to facilitate the convergence with international standards (e.g. ICAO and potentially IMO), whereas national adjustments might be needed to address local conditions. There is special need to guarantee the complementarity of “CountEmissions EU” with a renewable energy tracking system based on Guarantees of Origin, as proposed on the Renewable Energy Directive. The new methodology shall also facilitate ETS compliance .
Read full response

Response to Review of Directive 2012/27/EU on energy efficiency

19 Nov 2021

Energy efficiency improvement is a key lever of the European transition towards a neutral economy. However, measures should be coherent and guided by cost-efficiency so to do not jeopardize energy supply and consumers bills. Enagás would like to stress the following ideas: • The application of the Energy Efficiency Principle requires using the right cost-benefit analysis methodology in the search of synergies and reduced infrastructure costs. That is, to set realistic targets for all sectors in order to support 2024 and 2030 energy efficiency milestones. • Targets on businesses and productive sectors shall be flexible, and framed within Member States ultimate responsibility to draw right and cost-effective strategies, to unlock private investment. In particular, energy efficiency solutions related to energy network investment programmes and operation practices are dependent on local conditions and should be tailored as such. They are also closely related to the regulatory treatment, which is established at national level. Therefore Energy efficiency solutions are best captured using National Network Development Plans, which can be customized to suit that country’s needs, and designing them according to the allowed revenues system in place to offer appropriate incentives for operators. Best practises can be shared at EU level, e.g. through the production of non-binding guidelines. If a common methodology on the application of the ‘Energy Efficiency First’ principle was developed, it should have to be designed to specific circumstances and assessed on a case-by-case basis. Implementing general solutions would likely not be compatible with local differences in the conditions of facilities and costs. A common methodology would also need harmonised and comparable data to be collected and analysed before any general standards could apply. Striving for the best environmental outcome combined with the least burdensome energy efficiency process should be the guiding approach. • Energy efficiency policies should take into account the cycles of economic decline, stagnation and growth, including while setting energy consumption reference years (e.g. Covid19 lockdowns during 2020). • Gas infrastructures (transmission, distribution, storage & LNG terminals) can continue making a significant contribution to energy efficiency. They lay the ground for increasing the penetration of renewable energy, not only as electricity but also in the shape of renewable and low carbon gases (hydrogen, biogas and e-methane), that can be stored and help reducing the consumption of primary energy. Therefore, energy savings must keep on being promoted in the long term also in the gas sector, preferably through incentive mechanisms and incorporating in the RAB energy efficiency capex spending. • Enagás welcomes the EU methane reduction strategy’s stance and that the Commission will promote the recognition by NRAs of Leak Detection and Repair (LDAR) and methane reduction investments as allowed costs for regulated entities in transmission, distribution, storage and distribution, including through possible guidance to regulators. This is a promising first step, also in terms of energy efficiency, but needs to be followed up by concrete proposals by the NRAs. • Energy efficiency involves the search of synergies, as efficient cogeneration and district heating and cooling (DHC), which sometimes require the participation of public authorities to set common infrastructure. We welcome the clear and stepped support for increasing shares of renewable energy until 2050, as well as the recognition of the decarbonizing role that natural gas (and renewable and low carbon gases on the future) can play on refurbished DHCs. • High efficient cogeneration can be favoured by the issuance of Guarantees of Origin (GOs). It sets the basis of an effective market-based mechanism to identify the most resource and cost-efficient solutions meeting power, heating and cooling needs.
Read full response

Response to ReFuelEU Aviation - Sustainable Aviation Fuels

18 Nov 2021

Air transportation is an increasingly growing industry; it became a backbone of citizen’s mobility across borders and central asset for local businesses like tourism, from which several regions depend upon. With the coming of just-in-time logistics, aviation now also plays a key role on agile supply chains across the globe. Aviation currently contributes to the order of 2.4% of global emissions [1][2]. The pathway towards 2050 carbon neutrality shall necessarily take into account the deployment of renewable and low carbon fuels. Enagás considers the following aspects to be essential: • Sustainable Aviation Fuels (SAF) are a critical technology to push for carbon-neutral aviation, meeting the strict power requirements on flight of a highly dense energy carrier and power converters, which can only be currently meet with fossil kerosene. Fuelled jet engines are the better positioned technology on the field, while concepts based on alternative options still need very substantial research before they can successfully take off. Sustainable Aviation Fuels (SAFs) are chemically-similar substitutes to fossil kerosene, based on organic feedstocks or on hydrogen-derived hydrocarbons. They offer a smooth decarbonisation pathway, provided that much of the technology available on current aircrafts remains the same. • SAF production is a costly technology, and a scale-up of production is needed to drive costs down. It becomes advantageous to make use of renewable and low carbon gases as building blocks for further dense, sustainable hydrocarbons. Green hydrogen, biogas and e-methane are expected progressively penetrate on the gas supply at lowering prices, giving direct access to renewable energy for aviation fuel suppliers, wherever more strategically placed. It would be helpful to include a recital so to mention the potential role of renewable and low carbon gases, and the potential to support further ambition in this regulation. • Coherence with other pieces of Fit-for-55 is critical, particularly REDIII regarding the certification of sustainable fuels. This is a central aspect in order to guarantee the renewable origin of the energy consumed on the production process, and of the carbon (CO2) used to build up energy-dense renewable hydrocarbons. In fact, SAFs consumed on aviation shall also be registered on the Union Database as proposed on REDIII. • Decarbonisation of airports is a critical step towards green aviation. As authorities are already planning its next steps, a technology neutral approach backed by carbon intensity tracing (Guarantess of Origin) shall be developed, so that land and aircraft activities together can profit from synergies and increasing shares of renewable and low carbon gases, driving abatement costs down. On current proposal, the role of ‘aviation fuel suppliers’ is key in terms of bearing responsibilities. The definition of ‘aviation fuel suppliers’ shall be clarified in order to determine if that is the role of energy providers (hydrocarbon/gas commercial companies) or of airport operators. • Convergence between EU regulation and global standards of the International Civil Aviation Organization (ICAO) shall be pursued on a globalized industry such aviation. Aviation is one of the most cross-border businesses, and European action to reshape the sector may risk to jeopardize the air traffic across the continent if not carefully designed, rather than to effectively drive emissions down. Compatibility with global standards is critical; only then effective decarbonisation can advance without much distortion and increased prices for users. References [1] M Klöwer et al, Environ. Res. Lett. 16, Quantifying aviation’s contribution to global warming (2021). [2] CAN & ICSA, CONTRIBUTION OF THE GLOBAL AVIATION SECTOR TO ACHIEVING PARIS AGREEMENT CLIMATE OBJECTIVES (2018).
Read full response

Response to Revision of Alternative Fuels Infrastructure Directive

18 Nov 2021

Fuelling infrastructure plays a critical role on the decarbonisation pathway of the transportation sector. Further emission reduction will require a decisive participation of all technologies from today towards 2050, where renewable and low-carbon fuels are called to play an increasingly relevant role. Supply infrastructure for these new vectors should be ready by then, for the transition to be smooth and cost-effective. Enagás considers the following aspects to be essential: • Technology neutrality shall be a core principle of this regulation, to achieve a synergic share of effective technologies. AFIR should embrace Well-to-Wheel & Well-to-Wake approaches so to transparently account for the real emission savings of all available technologies, as they thrive where found to be more effective. This is, to minimize abatement costs and to prevent closing the door to growing and effective alternatives, such as renewable and low carbon gases. • AFIR shall coherently support other pieces of the Fit-for-55 package. There is need to change the confusing definition of alternative fuels on Article 2 and align it with REDII/REDIII, easing the compatibility with a system based on Guarantees of Origin. Additionally, RED framework is robust enough for tracing the origin of renewable gases coming from multiple sources, as the e-methane. • The achievement of a critical mass of users is a central aspect to determine AFIR’s success. This includes to grow a market case for renewable and low carbon gases, which will progressively flow through current gas infrastructure and will bring sustainable energy to large shares of the transportation and industry sectors. • On the decarbonisation of waterborne transportation, LNG is the most cost-efficient tool to reduce emissions of fleets today, characterizing by the need of highly energy dense carriers across very long distances. LNG fleets have already realized greenhouse emission savings up to 10%, on a complete Well-to-Wake approach [1]. Shipping sector is increasingly thinking on LNG and LNG-dual fuel engines as a flexible assets, where LNG infrastructure on ports lays the ground for the progressive roll-out of renewable and low carbon gases at a minimum cost. Enagás recommends to opt for technology neutrality on Article 9, including a mandatory sustainability tracking of the energy supplied on port. • On the decarbonisation of inland transportation, support for LNG and CNG engines should not be prematurely phased out. Gas engines are a demonstrated technology that can account for 10%-20% emission savings [2] by of today. However, support on AFIR targets is still needed to achieve a meshed network of supply points. Future comes though increasing blends of renewable and low carbon gases, progressively reducing the CO2 footprint per km in a cost-effective way. Analogous reasoning applies to rail transportation in several EU countries. • Combined transportation has the potential to generate important emission savings, looking for synergies in an effective coupling of TEN-T and TEN-E networks. In this scenario, ports and urban crossroads are important logistic and industrial hubs, so the positive externalities of renewable and low carbon gases can easily cascade though the supply chains, driving emissions down. Furthermore, harbours commonly find strong synergies with heavy industry, where energy needs can only be meet with highly calorific fuels. On the future, hydrogen and other renewable gases can successfully substitute natural gas and coal at lowering costs. References [1] Lindstad et al., MDPI Sustainability 12(21), Decarbonizing Maritime Transport: The Importance of Engine Technology and Regulations for LNG to Serve as a Transition Fuel (2020) [2] Frontier Economics, CO2 emission Abatement Costs of Gas Mobility and Other Transport Options (2021) – Report for NGVA
Read full response

Response to Revision of the Renewable Energy Directive (EU) 2018/2001

18 Nov 2021

Enagás welcomes EC’s ambition to increase the overall target for renewable energy to 40%, as well as introducing/adjusting several sector-specific sub-targets. The new Directive (REDIII) represents an opportunity to develop renewable and low carbon gases in order to achieve carbon neutrality on a cost-efficient way. Targets The sector-specific sub-targets included to incentivise the use of renewable gases, such as hydrogen (H2) and biomethane, are needed and deserve further support. Low-carbon Hydrogen All types of renewable and low-carbon H2 should be enabled to meet EU’s decarbonisation goals. If the REDIII is not going to address low-carbon gases, the upcoming Gas/H2 Decarbonisation Package could complement REDIII, either by allowing for low-carbon H2 to meet the targets set out in the REDIII, or by establishing a complementary and well-aligned incentives for low-carbon H2. Definitions There needs to be an explicit definition and nomenclature for renewable and low-carbon H2, renewable and low-carbon fuels which includes bioLNG and synthetic LNG (e-LNG), etc. These definitions should be consistent with the EU Taxonomy and implemented coherently across the Fit for 55 Package. Furthermore, some definitions included in the legislative proposal deserve further clarification. Guarantees of Origin (GOs) Enagás suggests the following changes: - The GOs system should be fully compatible with EU ETS mechanism in terms of monitoring and reporting. It should cover all energy carriers, and the GOs should be issued for renewable and low carbon gases (including H2), applying also to the liquefied forms. - The possibility for Member States to withhold GOs for producers of energy from renewable sources benefitting from financial support (art. 19, 2) should be removed. - GOs and sustainability certification systems should be integrated, adding the carbon footprint, based on a LCA, and sustainability information to the minimum list of information recorded on a GOs. - The European interconnected gas system should be recognised as a “single logistical facility” for the purpose of mass balance including the sustainability certification. - The GOs should be recognised as a tool to prove renewable origin of H2 for target compliance. - European standardisation process should be enhanced to ensure cross-border interchangeability of GOs. Union Database and Coherence with FuelEU Maritime proposal The FuelEU Maritime proposal aims to incentivise a shift to renewable and low-carbon fuels, including bioLNG and synthetic LNG in international maritime transportation. However, this objective risks being undermined by the EU Commission’s proposal to track individual transactions within a single mass-balanced system in the Union Database. The tracking of transaction information for gaseous fuels is inconsistent with the mass balance approach and incompatible with the current gas market architecture. RED III should clearly propose a GOs system resulting in certificates that could be traded separately from the physical gas molecules – across all EU Member States - as soon as the renewable gas is either transported and stored in liquefied form or injected into the gas grid. RFNBO: Additionality and temporal/geographical correlation The current approach to additionality and geographical and temporal correlation criteria should be reconsidered. Instead, the GOs should be recognised as a tool to prove renewable origin of H2. Biomethane feedstocks Annex IX, listing feedstocks that can be used for the production of biogas for transport and advanced biofuels, should broaden the scope of feedstocks able to be used. Fuels for Transport Enagás supports the proposed increased targets in the transport sector combined with the deletion of multipliers for advanced biofuels and renewable electricity. Moreover, the proposed credit mechanism for renewable transport fuels can benefit to all fuel suppliers and apply to all fuels under REDIII scope.
Read full response

Response to Revision of the CO2 emission standards for cars and vans

8 Nov 2021

Enhanced ambition regarding road transport emissions is one of the key levers towards carbon neutrality of the EU. They represent almost 20% of total EU GHG emissions, and have significantly increased since 1990. Further emission reduction as stated on the Green Deal will require the contribution of all technologies in the forthcoming years, and particularly a decisive roll-out of renewable and low-carbon fuels, both of biological and non-biological origin. Enagás considers that current formulation may act as a technological deadend if the regulation does not shifts towards technology neutrality, and allow the possibility to choose the most efficient pathways towards decarbonisation. Enagas considers the following aspects to be key, detailed in the document attached: • Renewable and low-carbon fuels are called to play a decisive role towards decarbonisation of the EU. • Technology neutrality shall be a central criteria of this regulation, so the need to substitute purely tailpipe emissions measurements of current regulation with a life-cycle assessment of vehicles and fuels. The Union Methodology suggested on Art 7 (10) may be an ideal tool. • Urgency to take into account real emissions of cars and vans when powered by renewable and low-carbon fuels. • A Crediting system should support the uptake of renewable and low-carbon fuels. • The concept of “Innovative Technology Packages” proposed on Article 11 should be clarified, and particularly whether renewable and low-carbon fuels can be accounted as such. • A coherent Alternative Fuel Infrastructure Regulation is critical to unlock the potential of renewable and low-carbon fuels, so to help cars and vans to meet increasing ambition on CO2 emissions targets.
Read full response

Response to FuelEU Maritime

8 Nov 2021

The "FuelEU Maritime" initiative is an excellent opportunity to promote the use of alternative fuels, thus allowing to help the decarbonization of maritime transport in line with the objectives of IMO (International Maritime Organization) and the EU. Enagas considers the following aspects to be key, detailed in the document attached: • Competitiveness of European companies and ports, to avoid the relocation of commercial traffic to non-EU ports and to less efficient means of transport. • Technological neutrality for an effective decarbonisation, where natural gas and biogas represent significant savings in emissions reduction. • Interdependence and consistency with Directive 2014/94/EU (AFID) as well as with the new regulation proposal on Alternative Fuel Infrastructure (AFIR), to enable the completion of ongoing infrastructure developments. • Achieve zero port emissions targets through the use of biogas and alternative fuels. • LNG as a mature and effective solution for fleet decarbonization. • Consistency with Directive 2018/2001 (REDII) in the calculation of greenhouse gas emission intensity.
Read full response

Meeting with Kadri Simson (Commissioner) and

8 Nov 2021 · Gas market and security of supply framework.

Response to Revision of Combined Transport Directive

16 Sept 2021

Enagás welcomes the revision of the Combined Transport Directive; combined freighting offers a unique opportunity to cut down emissions through the reduction of duplicated and scattered means of transport that cannot easily scale. At the same time, this effort can drive down transport costs per ton substantially. Furthermore, rail, inland water and maritime transport already offer important decarbonisation opportunities while making use of more efficient fuels, particularly where electrification is not possible. A common solution on both sectors is diesel engine repurposing to use natural gas, either in its gaseous (CNG) or liquid form (LNG). For instance, shifting from road to dual diesel-LNG fuelled rail may account up to 23% reduction on CO2 emissions; changing from diesel to gas on inland water and maritime transport can also represent similar emission reductions. Both rail and water transport can benefit from already available gas infrastructure, especially while considering that these means typically organize in logistic clusters. Regarding road freighting, it currently accounts for the most important share of land transportation in the EU. While thinking on combined transport strategies, lorries will retain the last mile and can also provide further flexibility to rail and vessels. The new proposal of an Alternative Fuel Infrastructure Regulation recognizes the role of CNG and LNG as a decarbonisation mean for Heavy Duty Vehicles, mandating the development of refuelling infrastructure at least on a transitory step. Lorries refuelling points may also find synergies with rail and water transportation nodes, further coupling TEN-T infrastructure. Enagás believes gas can help to reduce CO2 emissions ahead on time in a cost-efficient way. Gas infrastructure is an essential asset on the EU decarbonisation strategy: renewable and low carbon gases are called to play a critical role providing storage capacity for peak renewable energy production, and they will progressively have a greater share of the gas flowing to end consumers, including transportation. Renewable and low carbon gases are also the solely effective emission reduction pathway for industrial sectors with highly dense energy demand (steelmaking, cement, chemical production). These sectors already find strong synergies with transport networks, particularly with rail.
Read full response

Response to Enhancement of European policy on critical infrastructure protection

8 Apr 2021

En lo que se refiere a la Directiva, a Enagás le gustaría trasladar los siguientes mensajes: • "Para verificar el cumplimiento de la Directiva se establecerán mecanismos de control (inspecciones, supervisión, auditorías, solicitud de información...)" -> La certificación en ciertas normativas internacionales afines a la resiliencia deberían tenerse en cuenta, como prueba de este cumplimiento, para reducir la carga administrativa sobre las empresas. • "Deberán notificarse incidentes que perturben o puedan perturbar de forma significativa las operaciones de las entidades críticas" -> Hará falta concretar los umbrales, tipo de información a transmitir y tiempos/periodicidad de la comunicación en estas circunstancias para no sobrecargar a la empresa afectada. • En los antecedentes de la normativa se habla de las interdependencias entre sectores y el mayor riesgo de sufrir efectos en cascada como consecuencia de un incidente, lo que constituiría un análisis de valor, sobre todo al permitir visualizar dependencias de segundo y tercer nivel que pueden pasar desapercibidas. Sin embargo, en el cuerpo de la normativa, no se menciona de quién es responsabilidad llevar a cabo este análisis ni la metodología empleada para ello. • Existen dudas sobre la capacidad de los EE.MM. para ejercer una supervisión efectiva; necesidad de que se definan directrices y KPIs adecuados desde la CE para guiar a los EE.MM. • Se pone énfasis en la importancia del análisis y evaluación de riesgos (naturales y de origen humano) por parte de las entidades críticas y de los EE.MM. En este aspecto, se visualiza una oportunidad para enriquecer los análisis de riesgos de la empresa con información de ciertos riesgos sobre los que los EE.MM. ejercen mayor seguimiento (terrorismo, inteligencia, económicos, etc.). Por último, Enagás participó en 2020 en la respuesta al cuestionario sobre "Cost of CEIP", realizado por JRC. Es necesario reiterar que a las empresas reguladas, tales como los operadores de infraestructuras gasistas de transporte, GNL y almacenamiento, debe permitírseles recuperar a través de su retribución regulada los extracostes debidos a la protección de infraestructuras críticas, siempre que estos se consideren prudentemente incurridos, y en todo caso si son consecuencia del cumplimiento de la Directiva. Enagás propone que la Comisión Europea incorpore este principio dentro del Artículo 18, "Implementation and enforcement". Se propone la siguiente redacción, dentro de un nuevo párrafo dentro del artículo 18: "Member States shall ensure that the competent authorities allow all prudenty incurred costs by regulated entities that they identified as critical entities pursuant to Article 5, insofar those costs are related to the compliance with the obligations pursuant to this Directive" En el ámbito español, por ejemplo, las condiciones establecidas por el regulador para el reconocimiento de ciertos costes no recurrentes, conocidos como “Gastos de explotación activados” o COPEX, se han endurecido desde 2020, dificultando aún más el cumplimiento con la Directiva.
Read full response

Response to Revision of EU rules on Gas

10 Mar 2021

1. Application of Internal Energy Market principles to the future H2 market Regulatory intervention for H2 networks is justified on economic grounds. Incorporating the rules for H2 in the gas legislation would be the most efficient way of ensuring regulatory alignment between H2 and CH4. 2. Enabling combined network operators The EU legislation should explicitly recognise that gas TSOs can own and operate H2 networks through the concept of combined operator. 3. Electrolysers as energy conversion facilities Electrolysers should be classified as energy conversion facilities, allowing gas TSOs to own and operate them under tolling/TPA regimes. Allow entry tariffs discounts for renewable gases production. 4. Common, clear terminology A common EU terminology via clear, accurate and science-based definition of renewable, decarbonised and low-carbon gases is urgently required. 5. Hydrogen Target Model with limited exemptions A H2 Target Model should be defined to guide MSs in developing regulation aligned with the EU framework which does not hamper the later interconnection of the H2 system. Exemptions should be granted only in limited and duly justified cases, and should be ceased as soon as the relevant criteria are no longer met or at a sunset date. 6. Regulatory sandbox at EU level The revised legislation should allow for the implementation of regulatory sandboxes at EU level establishing a level-playing field for the participation of TSOs in pilot projects. 7. Recognition of cost for retrofitting and repurposing gas networks EU-level principles should be established to ensure that retrofitting and repurposing and costs are allowed by NRAs. 8. Financing the development of the H2 networks A clear regulatory framework is required to enable financing mechanisms. Maintaining a levelised cost (similar unit cost) between users of CH4 and H2 could be convenient during the transition period. A stricter cost-reflectivity should be considered once the transition from CH4 to H2 is completed. New legislation should be Taxonomy-aligned, including the retrofitting of gas transmission networks to allow the blend of H2. 9. Core H2 network The development of a future EU core hydrogen network (backbone) is key for escalating hydrogen production and achieving an internal market for hydrogen, ensuring competitiveness and security of supply. ENTSOG is ideally placed to assess investment needs at EU level. This exercise would be carried out best within the existing TYNDP framework. 10. ENTSOG scope should be expanded to H2 Given that the majority of the future H2 network will be comprised of repurposed gas pipelines, and that access rules and management of the H2 network will be very similar to those of the gas network, it makes sense that ENTSOG expands its scope to H2. 11. Blending as an enabler of H2 rollout H2 admixtures in the gas network should be properly recognised within the EU energy regulatory framework in order to enable the H2 rollout. 12. Harmonisation with wide gas quality range GQ standards for H2 networks should be harmonised. However, GQ should not impose unnecessary burdens. A wide range of GQ will facilitate the trade of renewable and low carbon gases and the establishment of a core hydrogen network at EU level. 13. Encouraging H2 production - EU quotas for renewable gases The EC should fix policy actions aimed at arriving to H2 competitive prices as soon as possible to be able to reach the installing capacity levels and costs of the EU Hydrogen Strategy. The introduction of EU quotas for renewable gases, underpinned by adequate policy support mechanisms, deserves further consideration. A number of proposals for sector–specific/concrete targets have been presented by EU stakeholders (e.g. Eurogas, Gas for Climate and GD4S). 14. Harmonisation of planning requirements All certified TSOs should be subject to similar requirements as regards the submission to the NRA of a TYNDP.
Read full response

Response to Proposal for a legislative act on methane leakage in the energy sector

26 Jan 2021

Enagás acknowledges the opportunity to provide feedback on this inception impact assessment. We fully support the EC efforts to accelerate methane emissions reduction from all sectors to contribute to the EU’s greater climate ambition for 2030 and its 2050 climate neutrality objective. Enagás recognises the potential benefits of the holistic approach of the recent EU Strategy on methane emissions to cover energy, agriculture and waste sectors, which will contribute to achieve the synergies and to help avoiding emissions. From 2013 until 2019, Enagás has implemented several mitigation measures getting a reduction of methane emissions from fugitives of 47% and from vents of 61%. In 2019, we also committed to reduce methane emissions from our activity by 45% in 2025 and 60% in 2030 with respect to 2015 figures (absolute target) according to the United Nations Global Methane Alliance initiative. Previous efforts of the industry who took early action in implementing mitigation measures should be recognised and fairly accounted for, as it is not technically and economically viable to keep the same emission reduction speed during the target path (incrementally higher investments are needed to get relatively lower reduction after implementing the first mitigation measures). Regarding the MRV system, Enagás supports the translation of the OGMP framework into EU legislation to be applicable to the full energy value chains. In addition, we recommend to explore if other sectors could also fit under the OGMP framework and if all the GHG emissions could be covered. In November 2020 Enagás already joint the OGMP initiative. In parallel to the improvement of the accuracy of the methane emissions data, the industry as a whole should undertake additional steps to accelerate further reductions of methane emissions along the entire gas value chain. We believe that the improvement of Leak Detection and Repair (LDAR) programmes and the reduction of flaring and venting will be key to contribute to this aim. Nevertheless, it is important to take into account the diversity of assets, operations, markets, national regulations and levels of maturity. Therefore some flexibility should be given to the industry (to invest on those mitigation measures which contribute to a higher reduction of methane emissions at the lowest costs). GIE and MARCOGAZ activities on methane emissions constitute valuable tools for the European gas mid-downstream segments. Mid and downstream segments are mainly regulated activities. Therefore, the investments on MRV, LDAR and mitigation measures should be recognised within the scope of regulated activities by the regulatory authorities. We stand ready to support the EC in tackling this important challenge with its expertise, knowledge and case studies.
Read full response

Response to EU Methane Strategy

4 Aug 2020

Enagás acknowledges EU’s ambition to establish an integrated methane emissions strategy to contribute to cost effective GHG reduction across the EU in the context of increased climate ambition for 2030 and the target of climate-neutrality by 2050. Managing and reducing methane emissions are part of the culture of the company, at all levels. Since 2013, we have voluntarily calculated and verified the annual carbon footprint, including methane emissions. Thanks to the mitigation measures implemented, methane emissions have been reduced by 60% from this year. Enagás supports the Global Methane Alliance initiative, which is sponsored by the UNEP and CCAC. Through this initiative, we have committed to methane emission reductions of 45% by 2025 and 60% by 2030 compared to 2015. At European level, Enagás, in close cooperation with GIE and MARCOGAZ, has contributed to a better understanding of the emissions in the gas sector as well as to build a culture towards net zero methane emission through dissemination activities and training sessions and the development of best practice guides. We have shared our case studies on how to detect, quantify and mitigate methane emissions. The goal of the strategy should focus on the implementation of measures to effectively reduce methane emissions and on the improvement of the accuracy of the data along the gas value chain to define the long-term abatement strategy. We would like to propose the following points to be considered for the EU Methane Strategy roadmap: • Involvement of the gas industry in the European initiatives to ensure that proposed measures are workable and effective. • Gas industry should have enough flexibility to apply the mitigation measures that allow to achieve the highest reductions in a cost reflective way. • Vents and flaring should be reduced as much as possible. LDAR campaigns should be mandatory. • Costs efficiently incurred by regulated entities related to the improvement of MRV and to the implementation of mitigation measures should be allowed and accordingly incentivised by the Regulatory Authorities. • To set up a reliable and cost effective methodology to quantify methane emissions. In this sense, MARCOGAZ has developed the ‘Assessment of methane emissions for gas Transmission and Distribution System Operators’ (future CEN technical report). • To put in place a well-structured and robust MRV system. Enagás thanks the EC and UNEP for allowing us in the early involvement to develop a common reporting framework covering the complete gas value chain. • We support the proposal of creating an international methane emissions mechanism aimed at improving credibility and transparency to the data. The scope should be aligned with the EU methane strategy covering the areas of energy, agriculture and waste. This initiative should be funded, scoped and managed only by Governments and IGOs. A level playing field should be ensured for the rest of the stakeholders. These should contribute to improve the accuracy of the National Inventory Reports, but avoiding duplication of reporting. • Gas companies should set their own emission reduction targets as soon as possible. • European gas infrastructure operators should only be responsible for the verification, reporting and costs related to methane emissions from the assets under their control. • We support the R&D programs and efforts focused on technologies and R&D activities to improve and harmonise detection, reporting and mitigation along the value chain. • Collaboration with non-EU countries is key as this is a global issue. Final consumers should not be negatively impacted. The security of supply of the EU should not be endangered. Therefore, we fully supports that the EC continues with its active involvement in the international initiatives on reducing methane emissions. • To exploit the synergies between sectors, we fully support that the Strategy will cover, in addition to the energy sector, agriculture and waste.
Read full response

Response to Strategy for smart sector integration

8 Jun 2020

Renewable, decarbonised and low-carbon gases (Clean Gases) are essential for achieving the 2050 decarbonisation targets Acknowledging that only a certain level of electrification of the EU economy is possible, the decarbonization of the different sectors will be achieved by a combination of renewable electricity and Clean Gases. There are sectors in which direct electrification is not possible or rather expensive, in those sectors Clean Gases can cover that gap The Clean Gases should be allowed to compete on a level-playing field, since they can be the most efficient solution in many industries Natural gas has a key role in enabling variable renewable energy integration, and further decarbonising different sectors of our economy. When coupled with CCUS, natural gas should also be considered as a possible solution for the long-term in order to achieve carbon-neutrality by 2050 and beyond Current gas infrastructures are an advantage for the development of Clean Gases. The gas infrastructures are a backbone of the EU energy system which serves to achieve the EU energy and climate goals by transporting, distributing and storing vast amounts of energy in a very cost-efficient way compared to electricity. By using the existing gas infrastructure in combination with the Clean Gases, the whole energy system is optimized, avoiding unnecessary and costly investments on the electricity side, and decarbonising the EU in a cost-efficient manner In the context of natural gas and gas blends with Clean Gases, it should be ensured that gas systems remain interoperable, avoiding market fragmentation and ensuring a fully integrated gas market; One European gas market is the vision Enagás calls to set up a regulatory framework which encourages gas infrastructure operators to engage in decarbonisation activities aimed at increasing the potential and actual quantities of renewable and low-carbon gases, developing, operating and owning innovative technology facilities and supporting their scaling-up, in a way that does not distort competition and secures third party access to maximise societal benefits An integrated sector coupling approach would facilitate the cost-optimal development of the electricity system, since it would capture the value generated by the gas infrastructures. Without coordinated planning of key infrastructures across electricity and gas, there is a substantial risk of inefficient investments The large storage capacity provided by LNG terminals and gas underground storages allows for the cost-efficient integration of variable renewable electricity sources (i.e. wind and solar) It is important to adapt and develop the regulatory framework to facilitate the deployment and growth of power to gas, renewable gases and sector coupling/energy sectoral integration: TEN-E should be amended to include Energy Transition projects and TAR NC should be amended in order to allow for discounts at entry points from renewable gases production The regulatory framework of P2G is still missing. It is important to adapt and develop the current regulatory framework to facilitate the deployment and growth of P2G, renewable gases and sector coupling/energy sectoral integration An EU-wide trading system for Guarantees of Origin, both for renewable and non-renewable (low carbon/decarbonized) gases is needed A common terminology via clear, accurate and science-based definition of renewable and low-carbon gases is urgently required LNG can help to further decarbonise the transport sector allowing in the long-term to switch to LBM and LSM achieving almost 100% GHG emissions reduction A regulatory sandbox allows innovators to trial new products, services and business models facing a regulatory barrier in a real-world environment without some of the usual rules applying. The exception to rules is temporary and limited in scope
Read full response

Response to A EU hydrogen strategy

8 Jun 2020

The EU is aiming at carbon neutrality by 2050. Since full electrification is not possible, the decarbonisation of the different sectors will be achieved by a combination of renewable electricity and Clean Gases (renewable, decarbonised and low-carbon) The role of Clean Gases, in particular Clean Hydrogen, should not only be seen as subsidiary, but they should be allowed to compete on a level-playing field, since they can be the most efficient solution in the long term in some industries Development of Clean Gases should start from key industries and smart-transport, though in the long-term a full Energy System Integration is key for the decarbonisation of the economy at a reasonable cost. There is an urgent need to start scaling-up the technologies; thus, the EC should fix policy actions at enabling Clean Gases to be price-competitive asap Hydrogen is one of the enablers for decarbonizing key industries like the chemical industry (in particular refineries), the steel industry, cement industry and fertilizers. The EU should take advantage of these investment needs to recover from COVID-19 crisis. The acceleration of these investments will increase sector’s turnover and create jobs Common terminology via clear, accurate and science-based definition of renewable, decarbonised and low-carbon gases is urgently required Binding targets should be considered for final consumption through sector-specific quotas (industry or smart-transport), and for clean hydrogen in the gas grid. Blending should be considered in order to offer a suitable pathway for peripheral Member States The lack of a clear regulatory framework to enable hydrogen, and the absence of incentives to support the process, are the main barriers. An EU framework to support hydrogen, establishing a common set of rules for all Member States, is needed. • Hydrogen networks are a natural monopoly and therefore they should be regulated. The most cost-efficient solution would be a single stakeholder in charge of the construction of the network, ensuring its optimal planning and operation. Some requirements of 2009 Gas Directive should also be applicable to hydrogen networks: rTPA, transparency, tariffs, CMP, CAM… • It is important to adapt and develop the current regulatory framework to facilitate the deployment of P2G, renewable gases and sector coupling/energy sectoral integration. Regulatory sandboxes should be promoted TSOs can play a positive, cost-effective and essential role kick-starting the necessary developments by being able to perform R&D, to invest in pilot projects and also by being part of the scaling-up and maturity phase, on a case by-case basis. Due to the nature of their business, gas infrastructure operators are willing, and well-placed, to invest in the decarbonisation of the gas. Gas infrastructure operators could own, operate and roll-out these technologies which could bring renewable and low-carbon gases to enable the energy sectoral integration and the accomplishment of the EU energy and climate goals Guarantees of origin are a fundamental element of the business model. A more detailed clarification of the criteria is needed as well as an EU-wide trading system for GOs, for all Clean Gases. Cross-border trade of GOs for renewable gas should be supported by ensuring “interoperability” of different GOs. In this sense, “different GOs” stand for different energy carriers (e.g. gas, electricity) and different issuing bodies Enagás supports all funding instruments for the development of hydrogen: Horizon Europe, IPCEI, TEN-E (CEF), Innovation Fund, InvestEU, Structural Funds and others. In particular, In order to allow for the transport of pure hydrogen, TEN-E could support the repurposing of existing natural gas pipelines or the construction of dedicated hydrogen infrastructure/pipelines Without coordinated planning of key infrastructures across electricity and gas, there is a substantial risk of inefficient investments
Read full response

Response to Development of Euro 7 emission standards for cars, vans, lorries and buses

24 Apr 2020

Enagás' feedback is aligned with the responses of NGVA & GASNAM. Air quality, especially in urban areas, is one of the key objectives to ensure health protection and reduce social costs. In this road transport sector has an important role to play together with other parallel actions to reduce traffic congestion and optimize freight logistics and personal mobility models In view of the revision of the current emissions standards, as Enagás we would like to highlight the following: 1. Any future emissions standard should be based on an exhaustive assessment of the implementation of the most recent Euro6/VI standards. In the recent years we have seen a fast implementation of different sublevel of standards, both in the LD and HD areas. These have been fundamentally conceived to guarantee the robustness of the systems under Real Driving Emissions, introducing PEMS measurement, and they set very stringent targets already today. 2. In parallel with the progressive penetration of tailpipe zero-emissions solutions, the role of clean fuels such as natural gas is key for several reasons: • Moving into a smaller granularity in the evaluation of the exhaust emissions, as proposed in the text when mentioning non regulated pollutants, will benefit in highlight the intrinsic properties of natural gas, a completely aromatic free fuel, with very low NMHC emissions, translating into a very low attitude in forming ground-level ozone that is detrimental to the respiratory tract and for acidification.[1] • Due to its gaseous nature natural gas provides homogeneous air-fuel mixture with near-to-zero particle matter emissions. With regard to PN emissions, recent experiences have demonstrated full compliancy of dedicated NG engines, even in the domain below 23nm diameter.[2] • After-systems systems conceived for NG applications are very robust and simple; over the efficiency in converting pollutants, they are also effective in converting unburnt methane hydrocarbons. Current impact from CH4 emissions from dedicated NG engines at the exhaust is as worst case around 1-2% once converted in CO2 equivalent.[3] • As it is mentioned to address also the GHG dimension looking to CO2 equivalent emissions, it must be reminded that bio & synthetic methane, that are fully compatible with NG technologies, is very effective way also to address GHG emission reduction at Well to Wheel level. Today in Europe NG vehicles are already using a blend containing 17% of bio & synthetic methane distributed as CNG. • Looking to the future and the potential utilisation of natural gas-hydrogen blends, this has been demonstrated to lead to a more complete combustion process, further lowering pollutant emissions.[4] • Looking to the timeline needed for the renewal of the EU vehicles fleet, natural gas is also a cost-effective solution when used in dedicated retrofit systems to upgrade the emissions level from older vehicles. • Compared to Diesel propulsion, NG engines halve the acoustic emissions, offering also ideal solutions for city overnight operations. 3. When reference to the simplification objective, we fully support the creation of simple standards that can last for a certain amount of time. This would avoid continuous updating, difficult to understand also by the end-user. However, because of the deep difference between the two markets, the merging of Light Duty and Heavy Duty regulation is not the correct way to achieve simplification. For further info see GASNAM position: https://gasnam.es/wp-content/uploads/2020/04/Argumentario-El-uso-del-gas-natural-como-combustible_VF.pdf [1] https://www.iet.hsr.ch/fileadmin/user_upload/iet.hsr.ch/Power-to-as/Kurzberichte/Berichte_Ueberarbeitet/EMPA-Bericht_CNG-Mobility.pdf [2] http://www.gason.eu/documents/get_doc/1166 [3] https://www.sustainablegasinstitute.org/wp-content/uploads/2019/02/SGI-can-natural-gas-reduce-emissions-from-transport-WP4.pdf [4] https://publications.jrc.ec.europa.eu/repository/handle/JRC80268
Read full response

Response to FuelEU Maritime

24 Apr 2020

The "FuelEU Maritime" initiative is an opportunity to further develop LNG as an alternative fuel, in order to achieve Green Deal objectives in maritime transport and port areas. Regarding the analyzed barriers, LNG is part of the solution, based on: PREDICTABILITY & INVESTMENTS Investment risk exists for any fuel, so shipowners need certainty about which fuels they can use and which are available in ports at a competitive price, throughout the ship’s life For years, LNG has been a clean, available, flexible, safe, sustainable and competitive option and a vector for the entry of renewable gases(RG) that will allow the achievement of decarbonisation objectives It is demonstrated in the Study(Ref-1) for various types of ships that despite the initial investment, the payback is around 5 years depending on the type of ship, well below the useful life of the ship TECHNOLOGY & PRICE LNG and RG eliminate all SOx and PM and 95% NOx, which is a benefit for human health. As for GHGs, they should be considered in relation to the life cycle, LNG reduces up to 21%, depending on the type of engine(Ref-2) and up to 100% if RG are used compared to conventional fuels(CF). Methane slips are different depending on the engine and its operating profile. The manufacturers of low pressure engines(Ref-3) are committed to reducing them as much as possible in the coming years and in high pressure engines they are practically zero(Ref-4), this type of engine is used by 33% of the fleet using CF which represents 84% of the capacity of maritime transport The use of LNG and its potential mixture with RG will favour the technical-economic development of technologies associated with H2, these mixtures will be a greater contribution to decarbonisation The price of LNG is more competitive than other available fuels and with greater stability. At present, it can be available in any Spanish port and in a large number of EU ports, including the main bunkering ports, and in many cases with small investments, taking advantage of existing infrastructures and in others where demand is slow to develop, support is needed in the initial phase. When demand is consolidated, logistics costs will be competitive with CF with infrastructure already amortised INTERDEPENDENCE The current demand for alternative fuels is not yet what is expected since the infrastructure, which comes from Directive 2014/94/EU and which had to be completed in the next few years, is in the development phase. Therefore, these new regulatory initiatives should not be an obstacle to their development, they should be an opportunity for their consolidation during the coming years. In Spain, through public-private initiatives and European funds (CEF), LNG supply infrastructures are being developed for the maritime sector, through the institutional strategy LNGHIVE2 These regulatory initiatives must take into account the continuity of these projects in order to meet the objectives of decarbonisation in the short medium term Investments in gas infrastructure are fully compatible for the transport of RG and to some extent for H2 GOALS In order to achieve the decarbonisation objectives, it will be necessary to favour the reduction of the use of CF, increase transport capacity, improve efficiency and the use of biofuels, LNG and RG LNG and RG will help to further decarbonise the maritime sector with the use of liquid biomethane (LBM) and liquid synthetic methane (LSM) which reduce GHGs by almost 100% and with zero net emissions. The study(Ref-5) indicates that LBM and LSM are scalable solutions for the maritime sector and could become competitive with other zero carbon fuels CURRENT STATUS COVID-19 Studies(Ref-6) show a link between air pollution that damages human health and the higher rate of deaths from this disease in the most polluted areas. In addition, particles may be involved in the spread of the virus through the air. In this aspect, LNG contributes to eliminate these pollutants
Read full response

Meeting with Kadri Simson (Commissioner) and

30 Jan 2020 · European Green Deal; decarbonisation of gas, hydrogen and reduction of methane emissions

Response to European Partnership for Clean Hydrogen

27 Aug 2019

The hydrogen sector in Europe is still in a pre-deployment stage and massive cost reductions across the entire supply chain are still necessary to enable mass commercialization to meet EU climate and energy targets. Enagas very much welcomes the proposal to establish the European Partnerships for Clean Hydrogen under the Horizon Europe Programme. This new partnership should build on the progress made by the FCH 2 JU (“Fuel Cells and Hydrogen 2 Joint Undertaking) during the last decade. Therefore Enagas encourages the establishment of a Clean Hydrogen Partnership, under the option 2, i.e., using an Institutionalised European Partnership (IEP), based on Article 187 TFEU. This new partnership will help to create a strong, innovative and competitive European clean hydrogen sector, fully capable of underpinning Europe’s energy transition by accelerating the market entry of technologies based on renewable and low-carbon hydrogen and delivering a wide range of socio-economic benefits. Gas infrastructure provides the flexibility needed to integrate an increasing share of variable renewables into the energy system, whilst guaranteeing secure and resilient electricity, storage, heat and mobility for the EU consumers. Through power-to-gas and other technologies, and together with the optimisation of links between gas and electricity markets, gas infrastructure offers huge storage capabilities to accommodate, transport and store increasing volumes of hydrogen into the gas infrastructure system. In this sense, any new partnership should take into account the necessary role of gas infrastructure to connect hydrogen production and consumption centres. The new partnership should also establish closer links with other European initiatives such as the Important Projects for Common European Interest (IPCEI) and the TEN-E programme. It would be also desirable that the new governance of the new partnership includes representation from the gas infrastructure industry. Enagas looks forward to participating in the open public consultation envisaged from mid-2019 which will cover all the potential institutionalized partnerships.
Read full response

Meeting with Joachim Balke (Cabinet of Vice-President Miguel Arias Cañete), Maria Cristina Lobillo Borrero (Cabinet of Vice-President Miguel Arias Cañete), Miguel Angel Sagredo Fernandez (Cabinet of Vice-President Miguel Arias Cañete)

23 Jul 2019 · National Developments and EU Energy Market

Response to Revising the rules for free allocation in the EU Emissions Trading System

4 Jul 2019

Enagás welcomes the opportunity to provide feedback on the draft Commission Implementing Regulation (EU) laying down rules for the application of Directive 2003/87/EC of the European Parliament and of the Council as regards further arrangements for the adjustments to free allocation of emission allowances due to activity level changes. Enagás' feedback is included in the attached file.
Read full response

Response to EMAS Sectoral Reference Document in the Waste Management Sector

9 Apr 2019

Enagás welcomes the opportunity to provide feedback on this initiative. Our proposals are: - Page 33 - Section 3.3.3. Incineration is only one way for recovering energy from MSW. There are other ways as anaerobic digestion that should be taken into account. - Page 34 To add the new section 3.3.8 Energy recovery from biowaste: KPI: Biowaste treated by anaerobic digestión (kg/capita/year)
Read full response

Response to Evaluation of the Alternative Fuels Infrastructure Directive

20 Mar 2019

Enagás welcomes the opportunity to provide feedback on the evaluation roadmap of the 2014 Alternative Fuels Infrastructure Directive. Natural gas will have an important role in the future to contribute to the decarbonisation of the transport sector. CNG/LNG in the transport sector is already a reality as well as its high availability, flexibility and scalability. During the last years, in the Iberian Peninsula some projects and studies on the feasibility of LNG as a marine fuel have been carried out (CleanPort project, Costa project, Pelikan-Gas, the current Core LNGas Hive), allowing us to gain lot of experience in this field. Core LNGas Hive is coordinated by Enagás and funded by CEF funds 2014-2020. This project has contribute to comply with the obligations pointed by the European Directive on alternative fuels infrastructure. Its transposition through the National Action Framework requires Spanish ports to have enough infrastructure for supplying LNG in 2025. Thanks to the developments of the Core LNGas Hive, this infrastructure will be ready 5 years before the deadline. This will contribute to minimise additional investment and to the optimization of the utilisation of existing capacity. However, there must be some support for the development of infrastructure for renewable energy and decarbonisation/development of island areas. Regarding the rail transport, the UIC "Low Carbon Rail Challenge" has set demanding targets in the horizon 2030 and 2050 both for reducing emissions and improving the "Modal Share" of the railway. The basic electrification strategies, very demanding from the point of view of the required investment, must be complemented with the use of alternative fuels that ensure a sustainable and competitive energy transition to diesel engines, which in the short term present serious limitations in the face of increasingly demanding environmental requirements. Natural gas is the alternative fuel best positioned to initiate a transition in the railway sector. On the other hand, the use of railway logistics implies different improvements with respect to current logistics such as cisterns, as they are 10 times more efficient, 45 times safer and a more sustainable means of transport. The railway provides additional intermodality in ports so that all LNG logistics, both maritime and land, will converge there, the ports being a logistical node and a change of land and sea transport. Likewise, the railway provides an optimal, safe and integral solution for transport between European corridors. Enagás is promoting, both through the Core LNGas Hive project and its particular "railway route map" (a project under development since 2014 in consortium with Renfe and Naturgy for the development of practical experiences that allow the commercial application of LNG as an alternative fuel in all segments of railway traction), the development of practical experiences that allow progress towards a sufficiently competitive commercial development of the solution. Gas and its infrastructure will play an essential role in the future decarbonised energy system along with electricity infrastructure. Enagás supports the transition to a long-term energy system in which renewable gases will play an important role in an intelligent combination with renewable electricity, while recognising that hydrogen can accelerate decarbonisation efforts in the coming decades. In addition, the utilisation of gas infrastructure will continue in the future with H2 and renewable gases, which would take advantage of the investments made for the development of the infrastructures. For all these reasons, Enagás encourages to continue recognising the technological neutrality of the infrastructure and to maintain CNG and LNG in the definition of alternative fuels.
Read full response

Meeting with Joachim Balke (Cabinet of Vice-President Miguel Arias Cañete)

7 Feb 2019 · TSO Certificate

Meeting with Miguel Arias Cañete (Commissioner)

18 Jan 2019 · Latest developments in the Energy sector in Spain and Europe

Response to Heavy Duty Vehicles CO2 emission standards

16 Oct 2018

Enagás welcomes this Commission’s initiative and its invitation to provide our opinion on the proposal for a Regulation of the European Parliament and of the Council setting CO2 emission performance standards for new heavy-duty vehicles. Enagás appreciates the inclusion of LNG as an alternative fuel in the document. However, the document does not cover the relevant role that renewable gases (bio-LNG, synthetic natural gas, green hydrogen) will play in the future in this sector. Blending natural gas with renewable gases will contribute to further reduce the GHG emissions and to enhance the circular economy. Enagás fully supports the implementation of a Carbon Correction Factor (CCF) in this Regulation, as it will contribute to a pragmatic transparent way towards a Well-to-Wheel approach. This approach needs to be implemented in order to be in measure to assess the GHG emissions from future combinations of vehicle technologies and fuels.
Read full response

Response to Institutional investors' and asset managers' duties regarding sustainability

20 Aug 2018

Enagás welcomes this Commission’s initiative and its invitation to provide our opinion on the proposal for a Regulation of the European Parliament and of the Council amending Regulation (EU) 2016/1011 on low carbon benchmarks and positive carbon impact benchmarks. In general Enagás supports the amendments and the text inserted. The only concern that Enagás has is related to the Annex “Low-carbon and positive carbon impact benchmarks – Methodology for low carbon benchmarks”, in particular to the point 1.h). The current text propose to include scope 1 (emissions from sources that are controlled by the company), scope 2 (emissions from the consumption of purchased electricity, steam, or other sources of energy generated upstream from the company;) and scope 3 (emissions that are a consequence of the operations of a company but that are not directly controlled by the company) emissions as input data used for the calculation of low carbon benchmark. However from Enagás point of view, only scope 1 and 2 emissions should be included in calculations as they are the ones directly controlled by the company, well identified and bounded and often verified. In our opinion, scope 3 emissions should be left out of the calculations as they are not under companies control and their calculation/estimation entails greater uncertainty since primary data are not always available for upstream or downstream sources. Scope 3 emissions are not comparable between companies and including them could penalise those companies taking into consideration, on voluntary basis, a wider definition of those scope 3 emissions.
Read full response

Response to Multiannual Financial Framework: Specific Programme implementing the 9th Framework Programme for Research and Innovation

4 Aug 2018

Please find in attached Enagás’ comments on the proposal for a Decision of the European Parliament and of the Council on establishing the specific programme implementing Horizon Europe – the Framework Programme for Research and Innovation, in particular on the following Clusters: • Cluster 'Digital and Industry' • Cluster 'Climate, Energy and Mobility'
Read full response

Response to Multiannual Financial Framework: Connecting Europe Facility 2021-2027

27 Jul 2018

Please attached a PDF document with comments from Enagás on the Multiannual Financial Framework: Connecting Europe Facility 2021-2027.
Read full response

Response to Update of the 2012 Bioeconomy Strategy

20 Mar 2018

Enagás welcomes the European Commission’s Roadmap on the update of the Bioeconomy strategy and thanks for the opportunity to provide feedback. In our opinion updating the 2012 Bioeconomy Strategy will contribute to achieving the EU 2030 climate and energy goals and to better address the priorities linked to the Sustainable Development Goals. Natural gas and gas infrastructure can play a key role in the establishment of the bioeconomy strategy, as these infrastructures deliver high storage and transmission capacity for renewable gases and are critical for RES integration while limiting the cost of the energy transition. Renewable gases can be produced through several processes and can be created using many different sources of energy. In the case of biogas, it can be produced from sewage, waste and residues, contributing to the circular economy and not competing with food production. If biogas is upgraded to biomethane, it can be injected into the gas grid and blended and/or to be used as a transport fuel. In the case of “renewable” hydrogen, it can be produced from renewable electricity, which can be injected to a certain extent directly into the gas grid or transformed into synthetic natural gas. Power-to-gas and Power-to-methane projects provide a means to handle periods of excess of green electricity that cannot be absorbed by the electricity grid. Enagás is involved in some projects related to biogas, power-to-gas and R&D activities. Enagás is of the opinion that national and EU institutions should foster a sound regulatory framework aiming at supporting this kind of projects and initiatives to allow technology deployment.
Read full response

Meeting with Miguel Arias Cañete (Commissioner) and Snam S.p.A. and Fluxys SA

30 Jan 2018 · Trans-Adriatic Pipeline

Meeting with Joachim Balke (Cabinet of Vice-President Miguel Arias Cañete), Maria Cristina Lobillo Borrero (Cabinet of Vice-President Miguel Arias Cañete)

11 Jan 2018 · European funds for STEP

Meeting with Dominique Ristori (Director-General Energy)

17 Nov 2017 · Energy policy

Meeting with Miguel Arias Cañete (Commissioner)

17 Jul 2017 · European Gas Markets

Meeting with Maroš Šefčovič (Vice-President) and

27 Apr 2017 · State of play TAP

Response to Network Code on the Allocation Mechanisms of incremental capacity in Gas Transmission Systems

27 Jul 2016

Art 12. The annual quarterly capacity auction should remain to be held once a year because both TSOs and capacity booking platforms have already incurred costs to develop IT systems in order to correctly implement the auction mechanism proposed by the Regulation (EU) 984/2013. In addition to that, the current framework of annual quarterly auctions is both efficient and effective. Art 20. The suggested Art. 20 is totally out of the scope of the Regulation (EU) 984/2013. The Art. 1 of the Regulation states that the scope of the network code is to set up standardized capacity allocation mechanisms in gas transmission systems by including an auction procedure for relevant interconnection points and standard cross-border capacity products to be offered and allocated. However, the general terms and conditions of the transmission contracts include additional rules not covered by the scope of the Regulation as, for example, specific rules to allocate the capacity, third party registration processes, congestion management procedures, other products and services offered, force majeure and dispute resolution. Enagás understanding is that the potential Art. 20 is not compatible with the principles of proportionality and subsidiarity and its application would not be possible as far as it would contradict several national laws. Most of the transmission contracts keep obligations to the TSOs originated from both the national civil laws and the national commercial laws which are not the same in every European country. The harmonization of such general terms and conditions would presuppose the harmonization of those national laws too which is out of the scope of the Regulation EC 715/2009. The current proposal is assuming the existence of several and different transmission contracts as it just would force the harmonization of the ones for bundled capacity products and it would not apply to the contracts which had an entry into force before the application of the new code. From Enagás point of view the proposal, far from being a coordinating one would hamper the spirit of the European harmonization as it would divide the contracts in “old contracts and new contracts” and “bundled capacity contracts and unbundled capacity ones”. On the other hand, the harmonization of the general terms and conditions for bundled capacity products would bring about huge administrative burdens not only to the TSOs but to the public administrations too. In this context, in Spain a new standard contract for the IPs was already developed in February 2014 by the NRA in cooperation with Enagás. In addition to that, Enagás is of the opinion that such proposals have not been either deeply analyzed neither the consequences of their implementation. A proper analysis of the proposal and the consequences of the implementation should be carried before deciding to include such provisions into a European Regulation. In any case, if the EC would finally decide to develop the analysis mentioned above, it should create the proper scope to do it and not to use the amendment of the Capacity Network Code as it was already raised on the Public Consultation on the preliminary scoping on potential Framework Guidelines on Rules for Trading who took place in April 2014. Art 31. The order in which interruptions shall be performed, if the total of nominations exceeds the quantity of gas that can flow at a certain interconnection point shall not be based on the contractual timestamp of the respective transport contracts but on the duration of the standard capacity product that is booked. In addition to that, the sequence of the interruption of the within day capacity products should be based on the timestamp of the auction where the capacity was booked. This should be mainly done in order to avoid confusions through the Capacity Network Code as far as there is no reference to the contractual timestamps but the standard capacity products and its duration are well defined.
Read full response

Response to Network Code on the Transparency of Transmission Tariff Structures for Gas

26 Jul 2016

Art. 10. Enagás, as owner and operator of the largest number of LNG terminals in Europe, does not support the inclusion of discounts at entry points from LNG facilities. LNG terminals have a completely different nature than underground storages, compared to storage facilities, access to LNG facilities does not imply the flow of gas through entry points and exit points twice, so there are no technical reasons to warrant discounts for LNG points. Besides, the reasons for applying discounts at entry points from LNG facilities are not clearly detailed in the document, this would create tailor-made solutions leading to distortions and unfair competitiveness between LNG terminals. It is worth noting that the text resulting after the 1st comitology meeting has been changed: discounts are allowed from all type of entry points, not only LNG terminals. Enagás also disagrees with this text proposal. Tariffs at entry points should be the result of the application of a tariff methodology and not be set arbitrary. This proposal could totally distort the initial goal of the TAR NC fostering destructive competition between national transmission systems to attract supplies disregarding the economic fundamentals that should be regarded for tariff design. If the reasoning behind this new text is supported by Security of Supply reasons, then specific rules should be set under SoS Regulation 994/2010 and not in the TAR NC. Art. 9. Enagás considers that this article is against the principles of Regulation 715/2009 where it is clearly stated that tariffs should not be dependent on the transport route. The tariff set for one or more entry points should therefore not be related to the tariff set for one or more exit points, and vice versa. All entry and exit points should be subject to a price methodology independently of their nature. Although this article has been deleted after the 1st comitology meeting, some exceptions to the reference price methodology have been introduced in order to recognize the different nature of assets dedicated to domestic used from those dedicated to transit. Enagás would like to reiterate its position against this distinction. Art. 35 The economic test should be applied to each TSO individual project. If the economic test is passed by all TSOs involved in the project then the incremental project will be triggered. This favours market integration by establishing an automatic process to trigger market-based investments. If the test is not passed by all TSOs, the project will not be triggered. In this case, NRAs and TSOs might start discussions for a cost sharing process. For the cost sharing discussion there is already a specific regulation (Regulation 347/2013) which is designed for those projects which cannot be triggered through market based mechanisms but creates net benefits impacts in the adjacent countries. The cost sharing discussion may include a debate on revenue schemes and efficiently incurred costs in each system; a clear monitorisation of investments by TSOs and NRAs will be expected. Besides, it will be inevitably necessary to carry on a CBA in order to identify the benefits for the system that might have to pay the investment in the other side of the IP. Neither TSOs nor NRAs will agree on a costs sharing scheme if there are not proved benefits for their system. Thus, TSOs will need to carry on a CBA to assess the benefits of the project in the adjacent country, in words of ACER there is no CBCA (cross border cost allocation) without a proper CBA. Thus, Enagás considers that article 35.5 point a) should be deleted.
Read full response

Meeting with Miguel Arias Cañete (Commissioner) and EPIA SolarPower Europe and

24 May 2016 · Business Forum EU-ALGERIA

Meeting with Miguel Arias Cañete (Commissioner)

12 Feb 2016 · Security of Supply and interconnections

Meeting with Gonzalo De Mendoza Asensi (Cabinet of Vice-President Miguel Arias Cañete)

15 Jan 2016 · Update on Gas quality issues

Meeting with Gonzalo De Mendoza Asensi (Cabinet of Vice-President Miguel Arias Cañete)

10 Sept 2015 · Interconnection, gas

Meeting with Dominique Ristori (Director-General Energy) and TotalEnergies SE and

4 Sept 2015 · gas and oil

Meeting with Miguel Arias Cañete (Commissioner) and

4 Sept 2015 · Security of supply and Energy diversification