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Ervia Limited

Ervia

Ervia is a commercial semi-state company with responsibility for the delivery of gas infrastructure and services in Ireland.

Lobbying Activity

Meeting with Kadri Simson (Commissioner) and Ibec and

2 Jun 2022 · REPowerEU Plan; EU Energy Platform

Response to Offshore renewable energy strategy

10 Aug 2020

Gas Networks Ireland and Ervia welcome the opportunity to provide feedback on the ‘Offshore renewable energy strategy’ roadmap consultation. In particular, we welcome that the strategy “will investigate how to best leverage the huge potential of offshore renewable energy deployment in a sustainable way” and “the potential of using offshore renewable energy to produce renewable hydrogen via electrolysers”. The European Green Deal and the recently published strategies for Hydrogen and Energy System Integration, clearly outline that together decarbonised electricity and gas networks are both required to achieve net-zero carbon emissions. They must therefore be developed in parallel with the overall objective to reach net-zero greenhouse gas emissions by 2050 in a manner that is smart, sustainable and cost effective. The EU have recognised that “linking sectors will allow the optimisation of the energy system as a whole, rather than decarbonising and making separate efficiency gains in each sector independently”. Smart grid integration will take the current interdependency between the gas and electricity networks to a new level. The Offshore renewable strategy will result in a significant increase in variable renewable electricity generation capacity. To mitigate curtailment of offshore energy, excess renewable electricity can be utilised to produce hydrogen which will decarbonise the natural gas grid and provide a zero emission energy source for use in difficult to decarbonise sectors such as transport and industry. We believe that the future EU energy system should maximise the utilisation of existing electricity and gas assets wherever possible, and deliver a decarbonised energy system at least cost and with least disruption to end users. It should provide security of supply and flexibility and allow energy to be conveyed via multiple carriers in an optimised manner. The upcoming revised TEN-E Regulation and strong co-ordination by both ENTSO-E and ENTSO-G of the PCI project evaluation process should ensure that the future energy system will be planned, designed and operated in an integrated manner. We agree with the consultation “that the current offshore wind and renewable development pace is far too slow and constrained”, however we believe that this only addresses the electricity sector and not the energy system as a whole. We believe that binding targets should be set for offshore wind, networked biomethane and hydrogen. This is a crucial step in developing these nascent clean energy technologies. It will provide project financiers and developers the certainty needed to invest in such technologies and will also encourage the relevant supply chains to develop. Ireland is a small island nation unable to as easily avail of the energy interconnection options across continental Europe and with limited indigenous energy sources. However, there is the potential with the EU Hydrogen Strategy and the Energy Sector Integration to take the current interdependency between the Irish gas network and the electricity grid to a new level and develop Ireland as a ‘Hydrogen Valley’ The future Irish energy system could operate as a zero carbon circuit where power-to-gas technology using renewable electricity could be a source of networked green hydrogen for clean dispatchable power generation and for other sectors including transport, heating, marine, aviation and certain industrial processes. This could realise significant energy security benefits for Ireland. Ireland’s recent NECP 2021-2030 submission highlighted the “significant potential for production of electricity from renewable sources (such as onshore wind, offshore wind and solar)” and the role for hydrogen “Ireland supports further exploration of hydrogen to support the integration of variable renewable electricity generation in particular for electrically isolated regions and in order to mitigate curtailment of wind energy.“
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Response to Revision of the EU Emission Trading System Monitoring and Reporting Regulation (MRR)

23 Jul 2020

Introduction Ervia and Gas Networks Ireland support and welcome the European Commission’s revision of the Implementation Regulation (EU) 2018/2066 on the monitoring and reporting (MRR) of greenhouse gas emissions. We suggest that the revision of MRR should be considered as an opportunity to introduce additional tools to incentivise and speed up decarbonisation of the ETS sectors of the economy, e.g. energy sector, in a cost-efficient manner and in line with the Green Deal objectives. This could be achieved via recognition of the climate value of renewable, decarbonised, low-carbon gases in the ETS and establishment of a robust market-oriented methodology for accounting their use. We believe that the EU ETS should enable the use of the green value of renewable and low-carbon gases certified by GOs for compliance with emission reduction obligations, along with the purchase of emission allowances and long-term investment in abatement technologies such as Carbon Capture and Storage (CCS). To facilitate this, and based on the current MRR draft, Ervia and Gas Networks Ireland call for the following: • A single harmonised market-oriented methodology to determine the biomass fraction of mixed fuels delivered by gas infrastructure across the European Union to the ETS operators. The adverse effect of diversified methodologies may be that differences in national rules would create market distortions with a negative impact over the willingness of investors to make long-term investments for the production of renewable and low-carbon gases such as biomethane and hydrogen compared to other types of energy (for instance, solid biomass) for which Member States rely only on one methodology. • The use of purchase records of biogas as the preferred methodology to determine biomass fraction needs further clarification. It is not clear which documents could be qualified to serve this purpose. We recommend using guarantees of origin (GOs) introduced in Article 19 of the Renewable Energy Directive (EU) 2018/2001 as part of the relevant documentation. GOs, as a market-based disclosure instrument tradable across Member States’ borders, could perfectly fit this purpose while preventing against possible risks of double incentives for energy production or double counting in its consumption. • Clarifications on the ways that the compliance of biogas with the sustainability and GHG emission saving criteria of REDII could be verified by ETS operators. GOs, when upgraded with a sustainability and GHG emissions attribute as confirmed by voluntary sustainability schemes according to Articles 30 and 31 of REDII, will be ideally placed to document ETS operators on the compliance of their consumed biomass with these criteria. • The extension of the scope of MRR to all renewable and low-carbon gases and fuels. Given their important contribution to achieving climate neutrality by 2050, especially in the EU ETS sectors, all renewable and low-carbon gases (hydrogen, biomethane etc) should be recognised for the purpose of emissions monitoring and accounting and their fraction in the burnt fuel should be identified and confirmed according to the same principles as for biogas. This proposal, in particular, relates to gases injected into gas networks and would help an ETS Operator burning a blend of hydrogen and methane to document the hydrogen share in its fuel. Burning pure hydrogen may not need to be covered by MRR as it does not emit CO2. In the future, unabated natural gas will be gradually replaced by renewable and low-carbon gases and fuels. As noted above, a methodology which counts and considers the contribution of these gases and fuels to the avoided CO2 emissions in the ETS sectors is needed in order to create the right market conditions for scaling up their production.
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Response to EU Strategy on Adaptation to Climate Change

30 Jun 2020

Ervia welcomes the opportunity to respond to the European Green Deal Strategy for Adaptation to Climate Change. Ervia is a commercial semi-state company with responsibility for the delivery of gas and water infrastructure and services in Ireland, through Gas Networks Ireland and Irish Water. Ervia notes that the Strategy highlights ‘even stopping all greenhouse gas emissions would not stop the climate impacts that are already occurring, and which are likely to continue for decades.’ Our vision for a net zero carbon gas network will help address the climate impacts that are occurring. In 2019, Ervia and GNI published ‘Vision 2050’ (A net zero carbon network for Ireland). Vision 2050 outlines a pathway to achieve a net zero carbon gas network by 2050 via the introduction of biomethane and hydrogen into the gas network and by abating natural gas CO2 emissions using Carbon Capture and Storage (CCS). Vision 2050 can deliver at least 18.7Mt/annum of CO2 emissions savings by 2050, equating to savings of circa one third of all of Ireland’s emissions as the benefits of a decarbonised gas network will extend beyond the energy (gas and electricity) sector to help decarbonise the more difficult sectors of heat, transport and agriculture also. Ireland’s gas network is a valuable national asset which will play a major role in achieving a clean energy future in a least cost, safe and secure manner. Working with government and policy makers across all sectors, the contribution this asset owned by the people of Ireland can make to help reduce emissions at least cost. We also note that the Adaptation objectives call to reinforce planning and climate risk management and to accelerate action with a focus on solutions. Across Europe, as seen in the EU’s Green Deal, the EU’s Energy Sector Integration Strategy and the emerging EU Hydrogen Strategy, it is becoming clear that decarbonised electricity and gas networks are firstly, both required to achieve net-zero, and secondly, developed in parallel. The increasing requirement for the electricity and gas networks to work together, in a hybrid system, will achieve the overall objective to reach net-zero greenhouse gas emissions by 2050 in a manner that is smart, sustainable and cost effective. Integration of the gas and electricity systems will increase finance and economic resilience. Europe’s gas network is a proven as a reliable, secure and critical piece of economic and social infrastructure. It is essential that a move towards climate proofing investments does not happen at the expense of our energy security. Gas networks offer a solution for delivery of the EU Green Deal, as gas networks can switch from more carbon-intensive energy carriers to low-carbon and renewable gases, such as biomethane or green hydrogen, without extensive network investment for the benefit of society. Notably, renewable gases provide essential back-up to intermittent renewables such as wind and solar energy, by providing flexibility to respond to changing weather patterns. Converting the gas networks to biomethane and hydrogen would realise a number of significant benefits: - a sustainable zero carbon source of scale, dispatchable energy; - the full realisation of Europe’s renewable electricity potential; - an interdependent energy system with power to gas enduringly enabling gas to power; - decarbonisation of significant energy consumption at least cost and least disruption to gas consumers; - the repurposing and continued / maximised utilisation of valuable existing energy assets, and that, - biomethane production has potential to sustain “100,000 – 150,000 direct jobs in agriculture and forestry” in the EU, while also providing efficiencies in land use, and supporting the development of a circular economy. (Navigant Gas for Climate - Job creation by scaling up renewable gas in Europe)
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Response to A EU hydrogen strategy

5 Jun 2020

Ervia welcomes the opportunity to respond to the EU Hydrogen Strategy Roadmap consultation which highlights the importance of hydrogen in contributing to the fundamental transformation of Europe’s economy. The consultation highlights the importance of reviewing and scaling up the whole hydrogen value chain; the role of collaboration and coordination with all stakeholders and the requirement for a pan European approach. In Ireland, the potential to generate electricity from renewable sources affords the opportunity to operate a green hydrogen (renewable electrolysis sourced) only gas network. This could realise significant energy security benefits for Ireland - a small island nation unable to easily avail of the energy interconnection options across Europe and with limited indigenous energy sources. We do note that there is a focus on mobility and industry and recommend that the critical role of hydrogen in decarbonising the heating and electricity sectors should be highlighted. We recommend the following for inclusion: 1. A binding target for hydrogen across all energy sectors for 2030, with a clear indication that this target increase after 2030, would create the conditions necessary to scale-up blue and green hydrogen. In particular, the development of a support scheme which incentivises the production of renewable gases for grid injection is now essential. Such a support scheme (underpinned by binding targets) will provide a clear route to market for hydrogen to decarbonise the industry, mobility, generation and heating sectors. 2. Member states’ gas and electricity system operators should be encouraged and incentivised to kick-start the necessary developments to realise greater network integration. They should work together to create inter-network conditions to enable decarbonisation technologies and energy sources to be deployed and operationalised so they can become commercial and scale up for national impact. This will enable full realisation of the broader concept of sector coupling between gas and electricity grids, whereby the gas grid can be used to store excess renewable energy, hydrogen, for later use when intermittent energy sources are not available. Gas and electricity infrastructure should be planned, designed and operated in an integrated manner. It is crucial that the development of the gas networks and electricity networks are effectively coordinated to optimise their respective contributions to national energy systems and maximise their combined contribution to realising networks interdependence and mutual support. TSOs should work together, and with industry, to identify the optimum number and location of key hydrogen injection sites (entry points) for the gas network. 3. Adapt the EU regulatory framework for a fully integrated energy system to enable green and blue hydrogen and CCS fulfil their potential in decarbonising the mobility, industry, electricity generation and build sectors • Carbon pricing must be broadened and strengthened across the economy. Increasing the EU ETS scheme and/or carbon taxes will ensure accelerated decarbonisation in energy demand sectors • A technology neutral approach to carbon emissions reduction should move policy support away from renewable technologies and towards carbon reduction technologies • A Total Systems Cost approach should be adopted whereby competing energy decarbonisation technologies are compared on the basis of the sum total of all associated costs. • Countries should develop and submit national plans for their integrated energy systems with targets to achieve these • Ensure that appropriate incentives are applied to electricity exit tariffs and gas entry tariffs to promote sector coupling and hydrogen production and remove barriers such as the double charging of gas and electricity tariffs • Develop an EU wide Guarantees of Origin framework, establishing a clear classification and recognition system for renewable, decarbonised and low carbon gases
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Response to Strategy for smart sector integration

28 May 2020

Ervia welcomes the opportunity to respond to An EU Smart Sector Integration Strategy The strategy recognises that there is an increasing requirement for the electricity and gas networks to work together, in a hybrid system, with the overall objective to reach net-zero greenhouse gas emissions. Across Europe, Power-to-Gas and Gas-to-Power are emerging as the building blocks of our future clean energy system. We therefore recommend the following for inclusion: 1. Set binding targets for networked biomethane and hydrogen Similar to how renewable electricity generation has benefited by mandatory targets, renewable and zero-carbon gas targets will increase certainty for industry and investors and will create the context to realise cost competitiveness in these energy sources and the technologies that produce them. A binding target for renewable gas for 2030, with a clear indication that this target would be increased after 2030, would create the conditions necessary to scale-up biomethane and green hydrogen. In particular, the development of a support scheme which incentivises the production of renewable gases for grid injection is now essential. Such a support scheme (underpinned by binding targets) will provide a clear route to market for biomethane and for green hydrogen helping to decarbonise the energy, industry, transport and agriculture sectors. 2. Direct member states’ gas and electricity system operators to work together to identify optimum locations for hydrogen production. Gas and electricity infrastructure should be planned, designed and operated in an integrated manner. For smart grid integration to be fully realised it will be crucial that the development of the gas network and electricity network are effectively coordinated to optimise their respective contributions to national energy systems and maximise their combined contribution to realising networks interdependence and mutual support. Ervia recommend that both TSOs work together, and with industry, to identify the optimum number and location of key hydrogen injection sites (entry points) for the gas network. Proximity to gas and electricity infrastructure, proximity to renewable electricity generation sources, space for hydrogen production and storage plant (both blue and green), the space for and capacity of electrical infrastructure and the potential for gas import (supplementary hydrogen) or export (CO2) are key aspects of developing a Smart Sector Integration. 3. Adapt the EU regulatory framework for a fully integrated energy system To enable biomethane, green and blue hydrogen and CCS fulfil their potential in decarbonising the heat, transport, industry and electricity generation sectors, Ervia proposes: • Carbon pricing must be broadened and strengthened across the economy. Increasing the EU ETS scheme and/or carbon taxes will ensure accelerated decarbonisation in energy demand sectors. • A technology neutral approach to carbon emissions reduction should move policy support away from renewable technologies and towards carbon reduction technologies. • A Total Systems Cost approach should be adopted whereby competing energy decarbonisation technologies are compared on the basis of the sum total of all associated costs. 4. Support national level interoperability targets for electricity and gas system operators TSO’s and DSO’s should be encouraged and incentivised to kick-start the necessary developments to realise greater network integration. They should be mandated to facilitate each other and work together to create inter-network conditions to enable decarbonisation technologies and energy sources to be deployed and operationalised so that they can become commercial and scale up for national impact. This will enable full realisation of the broader concept of sector coupling between gas and electricity grids, whereby the gas grid can be used to store excess renewable energy for later use when intermittent energy sources are not available.
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