EUROGAS

Eurogas

Eurogas is the association representing the gaseous energy sector in Europe.

Lobbying Activity

Eurogas urges realistic emission thresholds in EU Taxonomy review

5 Dec 2025
Message — Eurogas seeks to ensure that the Taxonomy is pragmatic, proportionate and technically robust. They argue that the GHG emission-intensity thresholds are too stringent. The group also recommends that dual-purpose infrastructure should remain eligible for financing.123
Why — This would lower compliance costs and help secure financing for gas projects.45
Impact — Environmental groups lose if the framework allows more investment in fossil gas.6

Meeting with Mechthild Woersdoerfer (Deputy Director-General Energy) and

3 Dec 2025 · Implementation of the Methane Regulation 2024/1787 (EUMR)

Meeting with Maroš Šefčovič (Commissioner) and

11 Nov 2025 · EU-US-China Relations in the Gas and Energy Sector

Meeting with Kitti Nyitrai (Head of Unit Energy) and FuelsEurope and

3 Nov 2025 · EU Methane regulation import requirements

Meeting with Andreas Glück (Member of the European Parliament) and Statkraft AS

30 Oct 2025 · Climate and Energy Policy

Gas industry warns mandatory phone support risks eliminating affordable digital offers

24 Oct 2025
Message — Eurogas requests a gradual approach distinguishing between digital-only and assisted offers, and between standard and vulnerable customers. They oppose mandatory telephone support across all offers and want no-reply email bans replaced with requirements for clear redirection and escalation paths.123
Why — This would allow them to maintain low-cost digital-only service options without mandatory phone support costs.45
Impact — Vulnerable consumers lose if digital literacy programs replace direct telephone support requirements.6

Gas Industry Urges Market-Based EU Energy Security Framework

13 Oct 2025
Message — Eurogas requests the EU recognize gas-electricity complementarity, use range-based demand scenarios, promote market-based supply diversification, streamline reporting requirements, and clarify crisis management rules. They oppose new regulatory burdens like methane import obligations and advocate exhausting market measures before crisis interventions.12345
Why — This would reduce compliance costs and preserve commercial flexibility for gas importers.678
Impact — Energy consumers face higher costs from storage obligations and reduced market competition.910

Eurogas urges EU to include gas in electrification strategy

9 Oct 2025
Message — Eurogas calls for continued support for efficient gas-powered boilers and hybrid heat pumps to help manage peak electricity demand. They also propose a legally binding production target for renewable biomethane to ensure a steady supply of green gas.12
Why — This would protect the gas industry's infrastructure and market share from being fully replaced by electricity.3
Impact — Pure electrification advocates lose if investment is diverted from electric grids to maintain existing gas networks.4

Eurogas Urges Technological Neutrality in EU Heating Strategy

9 Oct 2025
Message — Eurogas calls for technological neutrality and fair treatment of gas sources. They want incentives for condensing boilers and hybrid heat pumps. They also propose a binding 35bcm biomethane target for 2030.123
Why — This protects gas industry market share by keeping gas infrastructure relevant for heating.45
Impact — Environmental groups lose as gas usage is extended through reclassifying fossil-based heat.6

Fuel Industry Coalition Urges Recognition of Renewable Fuels in EU CO2 Standards

8 Oct 2025
Message — The Network requests that CO2 neutral fuels be recognized in the regulation with a Carbon Correction Factor reflecting their market share. They want a new vehicle category for cars running exclusively on these fuels, with zero-emission status equivalent to electric vehicles.123
Why — This would create regulatory recognition and market demand for their renewable fuel products.45
Impact — Electric vehicle manufacturers lose their exclusive zero-emission regulatory advantage and preferential market position.67

Meeting with Massimiliano Salini (Member of the European Parliament)

2 Oct 2025 · CO2 Standards light-duty vehicles

Meeting with Giorgio Gori (Member of the European Parliament)

30 Sept 2025 · Delegated act on low-carbon hydrogen

Meeting with Maciej Ciszewski (Head of Unit Energy)

22 Sept 2025 · Exchange of views on LNG markets trends and policies related to the EU methane regulation.

Meeting with Valdis Dombrovskis (Commissioner) and

22 Sept 2025 · Methane Emission Regulation

Meeting with Andrea Wechsler (Member of the European Parliament)

22 Sept 2025 · EU Energy and industry policy

Meeting with Nils Behrndt (Deputy Secretary-General Secretariat-General)

22 Sept 2025 · Implementation of the Methane regulation and the phasing out of Russian gas

Gas industry seeks 20-year certification period for carbon removal projects

19 Sept 2025
Message — Eurogas requests extending carbon removal certification from 10 to 20 years, expanding biochar definitions to include biomethane pyrolysis, and integrating certified removals into EU emissions trading. They argue current timelines create financing mismatches and discourage investment.123
Why — This would align certification periods with their 15-year subsidy schemes and financing structures.45

Eurogas Urges Scaled Back Reporting for Wholesale Energy Markets

17 Sept 2025
Message — Eurogas requests an implementation delay of 12 months after technical specifications are final. They also advocate for shortening the exposure reporting horizon to 18 months.12
Why — This would lower compliance costs and prevent regulators from misinterpreting commercial strategies.34
Impact — Regulatory authorities would have less data to monitor potential energy market breaches.56

Eurogas urges twelve-month delay for energy reporting standards

17 Sept 2025
Message — Eurogas requests that the new reporting table implementation be delayed for twelve months. They also propose limiting conflict of interest requirements to commercial entities.12
Why — This extension allows members to avoid immediate technical implementation costs and regulatory scrutiny.34
Impact — Regulators and traders lose access to reliable data during platform outages.5

Eurogas demands technology-neutral rules for EU 2040 climate goals

15 Sept 2025
Message — Eurogas requests a technology-neutral framework that recognizes all gases and carbon removal solutions. They advocate for simplified regulations to scale up hydrogen and biomethane production. The group also wants carbon removal certificates to be used for compliance in the carbon market.123
Why — This strategy would protect the industry's existing assets and reduce infrastructure investment.4
Impact — Advocates for an electrification-only energy system could see their influence diminished.5

Meeting with Yolanda Garcia Mezquita (Head of Unit Energy)

15 Sept 2025 · Exchange of views on REPowerEU Regulation

Meeting with Ditte Juul-Joergensen (Director-General Energy)

9 Sept 2025 · EU Methane regulation

Eurogas Urges EU Funding to Bridge Alternative Fuel Cost Gap

4 Sept 2025
Message — Eurogas proposes bridging the cost gap with fossil fuels using a Hydrogen Bank mechanism. They advocate for financial incentives for new bunkering infrastructure and fleet renewal. The association also recommends long-term contracts to scale up demand for gaseous fuels.123
Why — Increased public funding would reduce investment risks for gas suppliers and technology providers.45
Impact — Traditional oil suppliers lose market share as subsidies favor more expensive renewable gases.6

Eurogas urges inclusion of renewable gases in clean fleet mandates

4 Sept 2025
Message — The association requests a broader approach for selecting eligible technologies and fuels in corporate fleets. They argue for counting renewable gases like biomethane as zero-emission to ensure legislative consistency.12
Why — Including renewable gases allows gas suppliers and technology providers to maintain their market position.34

Meeting with Tatyana Panova (Head of Unit Financial Stability, Financial Services and Capital Markets Union) and Eurelectric aisbl and

1 Sept 2025 · JEAG position on commodity derivatives consultation

Eurogas Urges Improved Market Stability and Lower Reporting Burdens

8 Jul 2025
Message — The organization requests a more responsive price stability mechanism and reduced administrative reporting burdens. They also suggest using carbon removals and price-guarantee contracts to manage transition costs.1234
Why — These changes would reduce administrative overhead and lower the costs of switching technologies.56
Impact — The EU budget loses revenue if shipping emissions are deducted from the trading system.7

Meeting with Thomas Auger (Cabinet of Executive Vice-President Teresa Ribera Rodríguez), Valvanera Ulargui Aparicio (Cabinet of Executive Vice-President Teresa Ribera Rodríguez)

24 Jun 2025 · Implementation of EU legislation

Meeting with Annika Kroon (Head of Unit Mobility and Transport) and Gas Infrastructure Europe and

24 Jun 2025 · Certification of Biomethane in Europe

Meeting with Kitti Nyitrai (Head of Unit Energy)

5 Jun 2025 · Compliance with the import requirements of the EU Methane Regulation

Response to European Affordable Housing Plan

4 Jun 2025

Eurogas welcomes the opportunity to contribute to the Commissions initiative on the European Affordable Housing Plan. While the focus of this initiative will be on the affordability and availability of housing for the people living in Europe, Eurogas would like to draw the attention on another important aspect: the coverage of households energy needs. Today, buildings energy needs represent 40% of the EUs annual energy consumption of which 80% is used for heating and cooling purposes. Buildings are responsible for over 1/3 of the EUs overall GHG emissions. As from the EUs climate commitments, to reach its goal and turn the sector carbon neutral by 2050, Europe will have to invest substantial sums in the coming years. At the same time, while carrying out this costly process, the EU cannot afford to leave vulnerable and energy-poor households behind, who are more likely to reside in the least energy-efficient buildings and rely on fossil fuels for their energy needs. Natural gas continues to provide an affordable and reliable energy source for many vulnerable households a reality that must be factored into transition planning. As alternative technologies are deployed, their actual affordability, availability, and suitability will need to be assessed on the ground to ensure no one is left behind. A rapid shift toward electrification without adequate planning or support risks exacerbating energy poverty, particularly where alternative solutions are either unavailable or unaffordable. Any transition must take into account local conditions, including housing stock, existing infrastructure, and income levels, to ensure that all consumers especially the most at risk retain access to affordable and reliable energy. Protecting these households requires not only targeted financial support but also coordinated local planning and clear pathways to cleaner alternatives that are both viable and equitable. The integration of renewable and low carbon gases into building renovation strategies can offer a cost-effective decarbonisation pathway, particularly for the least efficient homes. Accordingly, to achieve a fair, realistic and timely decarbonisation of the building stock while maintaining affordability and social inclusion, a diversified, flexible and cost-efficient approach needs to be adopted. Due respect shall be given to the principles of technological neutrality, optionality and affordability. For this purpose, all decisions need to be taken in accordance with local needs, data, and in coordination with all stakeholders. It is paramount that such approach is also reflected in the European Affordable Housing Plan and especially in the implementation of Directive (EU/2024/1275) on the Energy Performance of Buildings (EPBD), whereas Article 11 is defining the characteristics and listing eligible energy sources to cover Zero-Emission Buildings (ZEBs) energy needs. In this context, it will be important to ensure that this provision is implemented in a way that maintains openness to all viable renewable energy solutions and reflects the diversity of local conditions and decarbonisation pathways. The decarbonisation of the gas grid through renewable gasses is one of these paths. Biomethane in particular has the advantage of bringing immediate emissions reductions by using the existing gas infrastructure and heating appliances, in addition to allowing for seasonal storage and offering the additional environmental benefits of valorising waste, reducing landfill pollution and creating economic opportunities for rural communities. Biomethane can thus be a fast, cost-efficient and scalable renewable energy source for buildings energy needs.
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Meeting with Kamil Talbi (Cabinet of Commissioner Dan Jørgensen)

2 Jun 2025 · Hydrogen

Meeting with Lukas Mandl (Member of the European Parliament)

2 Jun 2025 · Omnibus I Package

Meeting with Andrea Wechsler (Member of the European Parliament) and EVONIK INDUSTRIES AG

19 May 2025 · EU Energy and industry policy

Meeting with Yannis Maniatis (Member of the European Parliament)

14 May 2025 · Introductory Meeting

Meeting with Jutta Paulus (Member of the European Parliament)

12 May 2025 · Speaker: Methane Conference

Response to Common templates for the transfer of the information in national databases to the EU Building Stock Observatory

2 May 2025

Eurogas welcomes the possibility of providing feedback on the implementation of the Energy Performance of Building Directive (EPBD), the EUs Directive laying the tracks for the carbonisation of the building sector. As mentioned in recital 24, Europe needs to accelerate its pace to be able to achieve the 2050 goals. Accordingly, it is fundamental that the EU building observatory provides a correct picture on the Unions progress, keeping track also of the utilisation of renewable fuels. These are recognised under recital 22, Art.2(14) and Art.11 EPBD as effective means to reduce emissions from the buildings sector, including zero-emission buildings (ZEBs). Renewable fuels also play an important role in complementing intermittent electricity supply, prioritising cost-effective renewable energy use and grid congestions management. Accordingly, Eurogas suggests the following improvements for tables 19, 20 and 21: - Biomethane should be featured among the options for the Main source of energy - In footnotes 18, 19 and 20 the text should be changed to: Hybrid system using both electricity and fuels
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Eurogas urges delay and confidentiality in CO2 storage rules

16 Apr 2025
Message — Eurogas requests postponing the plan submission deadline to December 2025 and calibrating exemption thresholds to protect smaller entities. They also call for protecting commercially sensitive data, such as potential storage customers, from public disclosure.123
Why — Producers would avoid disclosing sensitive business secrets while gaining extra time to prepare complex compliance strategies.4
Impact — Reduced public transparency regarding carbon capture projects could limit local community engagement and oversight.5

Meeting with Borys Budka (Member of the European Parliament, Rapporteur) and Gas Infrastructure Europe

1 Apr 2025 · Gas Storage regulation

Meeting with Andrea Wechsler (Member of the European Parliament) and FuelsEurope and

1 Apr 2025 · EU energy and industry policy

Eurogas urges further simplification of EU Taxonomy reporting rules

26 Mar 2025
Message — Eurogas seeks materiality thresholds for individual activities and removal of the OpEx KPI. They also want to eliminate redundant gas and nuclear reporting tables.123
Why — Energy companies would avoid complex data collection and reduce high administrative costs.45
Impact — Data users lose standardized metrics, making it harder to compare corporate sustainability performance.67

Meeting with Dan Nica (Member of the European Parliament) and BUSINESSEUROPE and

25 Mar 2025 · Debate on The role of CEE countries and Romania in strengthening the competitiveness of the European Union

Meeting with João Cotrim De Figueiredo (Member of the European Parliament)

25 Mar 2025 · Energy Intensive Industries

Meeting with Cristina Lobillo Borrero (Director Energy)

14 Mar 2025 · EU Methane Emissions Regulation

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

20 Feb 2025

Eurogas welcomes the opportunity to comment the Implementing Act on non-price criteria in renewable energy auctions. Please find attached Eurogas position paper which provides our detailed recommendations.
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Meeting with Cristina Lobillo Borrero (Director Energy) and

14 Feb 2025 · Security of supply, gas storage, US LNG, methane emissions

Meeting with Kamil Talbi (Cabinet of Commissioner Dan Jørgensen)

10 Feb 2025 · Gas markets

Meeting with Andrea Wechsler (Member of the European Parliament)

4 Feb 2025 · EU Energy and Industry Policy

Eurogas urges inclusion of biomethane in Single Market Strategy

31 Jan 2025
Message — Eurogas requests explicitly including biomethane in the strategy to facilitate cross-border trade. They urge harmonized implementation of renewable energy rules and a functional certification database.12
Why — Harmonized rules would allow companies to trade biomethane as a standard energy commodity.3
Impact — Fragmented national regulations currently harm energy developers attempting to scale production across borders.4

Meeting with Dan Jørgensen (Commissioner) and

30 Jan 2025 · Affordable Energy action Plan

Meeting with Christian Ehler (Member of the European Parliament)

29 Jan 2025 · Hydrogen and biomethane

Response to Amendment to Registry Regulation in response to the ETS revision/Fit For 55 (Batch 2)

10 Jan 2025

Eurogas is the association representing gaseous energy in Europe. We are active throughout the gas sector value chain, including renewable and low-carbon gases, their derivatives and carbon capture utilisation and storage. Our members cover wholesale and retail gas markets, the distribution of gaseous energies and the use of gas in transport. We also represent technology providers including companies active on value chain methane emissions management. We thank the European Commission for the opportunity to provide feedback on the draft Delegated Regulation as regards the functioning of the Union Registry. Enclosed are our comments on Article 15b (Opening regulated entity holding accounts in the Union Registry).
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Meeting with András Gyürk (Member of the European Parliament)

2 Dec 2024 · Energy policy priorities

Meeting with András Tivadar Kulja (Member of the European Parliament)

21 Nov 2024 · Net zero in Europe

Eurogas Urges Extension of Fuel Data Registration Timelines

7 Nov 2024
Message — Eurogas recommends extending the transaction data entry timeline from three working days to one month. They request clarification on registration for farmers and traders to ensure compliance. They also suggest aligning the database with national schemes to avoid double reporting.12
Why — This would reduce administrative costs and lower the risk of regulatory non-compliance.3

Eurogas Urges Flexible Emission Rules for Low-Carbon Hydrogen

25 Oct 2024
Message — Eurogas requests a more differentiated approach for electricity intensity and project-specific values for natural gas inputs. They also demand measures safeguarding investments for first movers against future regulatory revisions.12
Why — Producers could meet the seventy percent threshold more easily while reducing risks of power cost fluctuations.34
Impact — Climate goals are at risk if rules for solid carbon lead to double counting emission savings.5

Meeting with Christian Ehler (Member of the European Parliament)

10 Oct 2024 · Energiepolitik und Wasserstoff

Meeting with Radan Kanev (Member of the European Parliament)

9 Oct 2024 · EU legislation on gaseous energies

Meeting with Andrea Wechsler (Member of the European Parliament) and BUSINESSEUROPE and

23 Sept 2024 · EU Energy and Industry Policy

Eurogas urges simpler monitoring rules for gas sector decarbonisation

29 Jul 2024
Message — The organization requests simpler proof for zero-rating fuels and alignment with the Union Database. They also want recognition of cross-border certificates and inclusion of solid carbon products.123
Why — Proposed clarifications would reduce administrative burdens and provide much-needed long-term legal certainty.45
Impact — National authorities lose discretion to refuse fuel sustainability evidence from other EU Member States.6

Meeting with Jens Geier (Member of the European Parliament) and ENGIE and EnBW Energie Baden-Württemberg AG

18 Jul 2024 · Exchange on Low Carbon Hydrogen

Eurogas urges inclusion of solid carbon in storage rules

15 Jul 2024
Message — Eurogas requests that solid carbon from chemical processes be recognized as permanent sequestration. They also call for clear rules on long-term liability and carbon tracking throughout the product lifecycle.12
Why — This would exempt their processes from the costly obligation to surrender carbon allowances.3
Impact — Climate objectives may be compromised if monitoring fails to ensure carbon remains stored for centuries.4

Meeting with Kurt Vandenberghe (Director-General Climate Action)

18 Apr 2024 · Achieving the EU 2040 climate target: The role of gaseous energy

Response to Evaluation and revision of the Weights and Dimensions Directive

11 Mar 2024

Eurogas welcomes the Commissions proposal to review the Weights and Dimensions Directive (WDD), which sets out the maximum weights and dimensions for heavy-duty vehicles (HDVs) to circulate on EU roads. This Directive aims at improving the environmental performance of such vehicles while ensuring fair competition among road transport operators. Commercial vehicles fuelled with biomethane (bio-LNG/bio-CNG) or hydrogen play a key role in the decarbonisation of road transport, alongside battery-electric vehicles. We firmly believe that the upcoming Directive should ensure a level playing field between technologies with lower GHG footprints while considering the specific requirements of alternatively fuelled and zero-emission vehicles. Eurogas recommendations: The revision should maintain the existing definition of alternative fuels encompassing fuels with GHG emission reduction potential in comparison to diesel and of alternatively fuelled vehicles which require additional weights to accommodate their alternative powertrains. The revision should apply the additional weights derogations uniformly for alternatively fuelled and zero-emission vehicles, capping the weights derogation at the incremental weights of the relevant powertrains or enabling alternatively fuelled vehicles to carry additional payload as well as ZEVs. The revision must ensure that Member States can allow weight derogations for cross-border traffic in line with the expected evolution of the commercial vehicle fleet deriving from the CO2 standards for heavy-duty vehicles (Regulation (EU) 2019/1242).
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Response to Guidance to facilitate the designation of renewables acceleration areas

22 Feb 2024

In response to the European Commission's call for evidence regarding Renewable Acceleration Areas, Eurogas appreciates the opportunity to provide feedback following the recent adoption of the RED III. However, we express concern regarding the limited focus of the consultation, which appears to exclusively address wind and solar power. Eurogas advocates for a broader perspective that encompasses various technologies capable of producing renewable energy, as outlined in section A of the Call for Evidence, which stipulates Member States' designation of renewables acceleration areas for one or more technologies by 21 February 2026. For more detailed feedback, please find attached Eurogas' one-pager.
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Response to Count your transport emissions: CountEmissions EU

3 Nov 2023

Eurogas and Gmobility are committed to the decarbonisation of the transport sector, notably through the increasing role of gaseous fuels, including biomethane (bioCNG/bioLNG) as sustainable and immediately available fuels with lower GHG footprints. We firmly believe that the upcoming CountEmissions EU Regulation will play a key role in addressing the climate performance of transport services and must ensure a level playing field among all viable technologies. Accounting for the actual environmental footprint of the fuels is critical and requires an enabling regulatory framework in support of further market development. To that end, please find attached our recommendations.
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Meeting with Joost Korte (Director-General Employment, Social Affairs and Inclusion) and industriAll European Trade Union and European Federation of Public Service Unions

2 Oct 2023 · Skills

Meeting with Jutta Paulus (Member of the European Parliament, Rapporteur)

13 Sept 2023 · Methane

Eurogas urges aligned emission factors for maritime reporting

30 Aug 2023
Message — Eurogas requests alignment with the Renewable Energy Directive to ensure consistency across maritime policies. They propose using specific Global Warming Potential factors to avoid incoherent dual reporting.123
Why — This would simplify administrative processes by ensuring multiple climate policies are updated simultaneously.45
Impact — Scientific accuracy may suffer if reporting standards rely on older scientific assessments instead of newer data.6

Eurogas Urges Purchase-Based Accounting for Grid Biomethane Reporting

23 Aug 2023
Message — Eurogas requests a uniform purchase record-based accounting system for biomethane in the grid. Physical analysis causes reporting inconsistencies and potential double counting of gas emissions. Amendments should ensure reporting reflects commercial reality across all regulatory provisions.1
Why — Harmonized purchase record definitions would reduce fragmented national interpretations and compliance costs.2
Impact — Climate advocates lose certainty provided by physical monitoring of actual gas flows.3

Eurogas calls for flexibility in EU sustainability reporting rules

7 Jul 2023
Message — The association requests explicit guidance and sufficient time for companies to prepare for new obligations. They advocate for market-based greenhouse gas accounting to be extended across the entire value chain. Eurogas warns against binding EU rules to international frameworks that are still under revision.123
Why — This reduces administrative costs and ensures that market-based investments in biomethane are recognized.45
Impact — Regulators may lose oversight if companies use materiality assessments to exclude specific reporting topics.6

Meeting with Andrus Ansip (Member of the European Parliament, Rapporteur) and Apple Inc.

27 Jun 2023 · Meeting on Green Claims

Meeting with Jens Geier (Member of the European Parliament, Rapporteur) and Global Witness and

7 Jun 2023 · Exchange on the gas market directive (staff level)

Eurogas Urges Inclusion of Gas-Powered Heat Pumps in EU Plan

26 May 2023
Message — Eurogas requests that the action plan includes all varieties of heat pumps, specifically thermally-driven and hybrid systems. They advocate for a bottom-up approach that utilizes existing gas infrastructure and renewable gases.123
Why — This would maintain the relevance of gas infrastructure and reduce industry transition costs.45
Impact — Purely electric heat pump manufacturers lose the advantage of a single-technology policy focus.6

Eurogas urges carbon correction factor for heavy-duty vehicle emissions

17 May 2023
Message — Eurogas wants a level playing field by introducing a Carbon Correction Factor. This mechanism accounts for the contribution of renewable fuels in gas-powered engines.12
Why — This proposal protects the market for gas-powered engines and utilizes existing refueling infrastructure.3
Impact — Pure electric vehicle manufacturers lose their competitive advantage if combustion engines receive emission credits.4

Meeting with Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans) and ExxonMobil Petroleum Chemical and

25 Apr 2023 · Energy, environmental and digital challenges of our time

Meeting with Jens Geier (Member of the European Parliament, Shadow rapporteur)

30 Mar 2023 · Exchange of Views on the Methane Regulation (Staff Level)

Meeting with Seán Kelly (Member of the European Parliament) and Snam S.p.A. and Uniper

13 Dec 2022 · Dinner Debate: Hydrogen and Decarbonized Gas Markets Package: an MEPs – Industry Conversation

Meeting with Martin Hojsík (Member of the European Parliament, Shadow rapporteur)

28 Nov 2022 · Methane Regulation

Meeting with Kadri Simson (Commissioner) and

26 Oct 2022 · Joint purchasing options.

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

12 Jul 2022 · Meeting with the new Eurogas president and discussion about joint purchasing of gas

Eurogas pushes for flexible carbon sourcing in renewable fuel rules

17 Jun 2022
Message — Eurogas recommends removing the 2035 time limit on using captured industrial carbon for fuel production. They propose using default values for transport emissions to avoid the technical challenge of tracking individual gas molecules. Additionally, they want the methodology to include carbon captured from waste treatment facilities.123
Why — This would reduce administrative costs and facilitate easier trading across the EU gas network.4
Impact — Environmental targets may be undermined by allowing continued use of non-sustainable industrial carbon.5

Meeting with Milan Brglez (Member of the European Parliament)

1 Jun 2022 · Energy Performance of Buildings Directive

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

6 Apr 2022 · REPowerEU

Eurogas urges flexible, market-based gas storage filling rules

3 Apr 2022
Message — Eurogas argues for market-based mechanisms to ensure security of supply. They recommend more flexible deviation rules and suggest tailor-made national solutions.123
Why — Flexibility and market-based rules would lower gross compliance costs for gas suppliers.45
Impact — Consumers face higher costs as storage mandates risk high gas wholesale prices.67

Meeting with Jens Geier (Member of the European Parliament, Rapporteur) and Gas Infrastructure Europe and European Roundtable on Climate Change and Sustainable Transition

17 Mar 2022 · Exchange on the gas market directive

Meeting with Alin Mituța (Member of the European Parliament)

10 Mar 2022 · Renewable Energy Directive

Meeting with Christophe Grudler (Member of the European Parliament, Shadow rapporteur)

2 Feb 2022 · Révision de RED II

Meeting with Markus Pieper (Member of the European Parliament, Rapporteur)

18 Jan 2022 · RED III

Meeting with Rasmus Andresen (Member of the European Parliament, Rapporteur for opinion)

12 Jan 2022 · Role of Gas in the shipping sector

Meeting with Caroline Nagtegaal (Member of the European Parliament, Shadow rapporteur)

7 Dec 2021 · ETD

Meeting with Markus Pieper (Member of the European Parliament, Rapporteur) and Wirtschaftsvereinigung Stahl and WACKER CHEMIE AG

25 Nov 2021 · RED III

Meeting with Gerassimos Thomas (Director-General Taxation and Customs Union) and GEODE - The voice of local energy distributors across Europe and

22 Nov 2021 · Videoconference - Energy Taxation Directive in Fit for 55 package

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

19 Nov 2021

The success of the energy transition requires a cost-effective decarbonisation pathway. To achieve this, the Energy Efficiency Directive must enable the identification and delivery of energy efficiency across the entire energy value chain. Eurogas is firmly committed to ensuring an energy transition that is both cost-effective and just. We believe that gas – natural, renewable, and low carbon – needs to play their role in this process, specifically also the building sector. Eurogas recommendations • The principle of ‘energy and system efficiency’ must be more consistently integrated throughout the provisions relating to ‘Energy Efficiency First’ • The decarbonisation potential of gas – natural, renewable and low-carbon – should be eligible to contribute towards national energy saving obligations • The timeline for the decarbonisation of district heating and cooling should consider the capacities of all member states and high efficiency cogeneration must be able to continue to play a role beyond 2035 to reach the targets set in the directive.
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Response to Revision of Alternative Fuels Infrastructure Directive

18 Nov 2021

Eurogas welcomes the opportunity to provide input on this proposal; please find attached our detailed feedback.
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Eurogas urges binding EU targets for renewable gases

17 Nov 2021
Message — Eurogas calls for a binding EU target for renewable gas demand. They want low-carbon hydrogen to count towards EU decarbonisation targets. They also advocate for mandatory Guarantees of Origin.123
Why — This would boost market growth and reduce costs for gas tracking.45
Impact — Advocates for an electricity-only transition would lose their policy dominance.6

Eurogas urges EU to recognize renewable gas in vehicle standards

8 Nov 2021
Message — Eurogas wants a lifecycle accounting approach to recognise the environmental performance of fuels. They suggest a crediting system to account for renewable and low-carbon alternatives.12
Why — This would prevent a total market ban on gas-powered vehicle technologies.3
Impact — Makers of zero-emission vehicles would lose their exclusive advantage in meeting climate targets.4

Response to FuelEU Maritime

8 Nov 2021

Eurogas welcomes the opportunity to provide input on this proposal for a Regulation; please find attached our detailed feedback.
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Response to Restoring sustainable carbon cycles

7 Oct 2021

Eurogas response to “Restoring Sustainable Carbon Cycles” Roadmap Eurogas welcomes the opportunity to provide comments on the proposed Roadmap for Restoring Sustainable Carbon Cycles. To achieve net zero emissions by 2050, the EU should develop a policy framework that promotes and incentivizes investment in both technological and nature-based carbon removals solutions, including a transparent and robust certification system that is sufficiently flexible to accommodate new technologies and innovative long-term permanent carbon removals solutions. We believe that an important element of any policy framework for carbon removals will be the development of new CO₂ transport and storage networks and infrastructures in the EU, connecting industrial emitters with CO₂ storage capacity, in order to achieve decarbonization of hard-to-abate sectors as well as carbon removals in the context of bio-energy with CCS (BECCS) and direct air capture (DAC). Eurogas agrees with the Commission’s objective set out in the Roadmap of achieving greater circularity of carbon in energy and industrial systems and welcomes the policy focus on carbon dioxide removals (CDR) as well as the utilization of captured CO₂ in synthetic fuels. It will be important for the future policy framework to recognise and support different CCS, CCU and carbon removals solutions, while rewarding their deployment and contribution in accordance with lifecycle GHG emissions carbon accounting. Such a methodology should be elaborated as part of the separate work on EU carbon removals certification, and Eurogas looks forward to working with EU policymakers on this initiative. More specifically, Eurogas believes the following policy considerations should be taken into account when designing the EU policy framework for carbon removals. • Verify the authenticity and permanence of carbon removals through the adoption of a transparent and robust certification system, with associated monitoring, reporting and verification (MRV). As part of this work, it will be important to identify elements of certification best practice from within existing and planned voluntary carbon removals schemes and trading platforms. • Ensure that certificates verifying the authenticity of carbon removals are tradeable, including as part of the EU Emissions Trading Scheme in due course. Tradability of CDR certificates will enhance the business case for investing in carbon removals, since market participants will be able to create value and achieve a better understanding of the value different CDR solutions provide in meeting climate targets. • Additional policy clarification may be necessary to fully understand the liability exposures associated with carbon removals reversals. In the case of technological removals, the existing EU CO₂ Storage Directive contains relevant provisions on liability in the highly unlikely event of leakage from geological storage. However, for nature-based solutions, such provisions may still need further development in EU legislation, in order to provide a clear legal framework around forestry and soil carbon removal solutions. • The proposed certification of carbon removals should be cross-border, in order that a single EU framework for the exchange and trading of carbon removals certificates across Member States can be established. • Additional work is needed to recognise and reward storage and use of biogenic CO₂ in the ETS. The Commission’s July Fit for 55 ETS proposals appears not to have included new incentives for installations seeking to capture emissions of CO₂ from biogenic sources, such as biomethane, organic waste or biomass. Capture and storage of such emissions can achieve carbon removal and should therefore be better recognized in existing EU policy frameworks. We hope that these policy reflections are useful and look forward to further dialogue as the policy framework for carbon removals, including certification, is further developed.
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Meeting with Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans) and Association of the European Heating Industry and COGEN Czech, Association for Combined Heat and Power Generation of the Czech Republic

21 Sept 2021 · Meeting on 2030 RENEWABLE GAS AND GAS DECARBONISATION TARGETS

Meeting with Kadri Simson (Commissioner) and

16 Sept 2021 · 2030 renewable gas and gas de-carbonisation targets. Analysis of the position papers of the companies.

Response to Gas SoS – risk groups amendment

17 Aug 2021

Eurogas welcomes the opportunity to provide input on the amendments to Regulation (EU) 2017/1938; please find our detailed feedback attached.
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Response to Detailed implementing rules for the voluntary schemes recognised by the European Commission

26 Jul 2021

Eurogas welcomes the opportunity to provide input on these draft implementing rules; please find our detailed feedback attached.
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Meeting with Asger Christensen (Member of the European Parliament)

26 May 2021 · Methane emission

Meeting with Nicolas Schmit (Commissioner) and

11 May 2021 · Pact for Skills roundtable with the renewable energies ecosystem sector.

Meeting with Thierry Breton (Commissioner) and Eurelectric aisbl and

11 May 2021 · Pact for Skills roundtable with the renewable energies ecosystem sector

Meeting with Frans Timmermans (Executive Vice-President)

25 Mar 2021 · Keynote speech on the Vision for Transition to Net Zero

Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

22 Mar 2021

Eurogas welcomes the opportunity to provide input on the inception impact assessment for the Energy Performance of Buildings Directive. Within the broader context of the Renovation Wave, heating and cooling is central to our daily lives and comfort and pivotal for achieving the climate neutrality target. Given the size of the challenge, all options should be considered. Gaseous solutions are already playing a major role in making buildings more comfortable and significantly reduces the buildings’ energy demand and GHG emissions. Transitioning from coal or oil heating has also contributed to improving air quality, especially in dense urban areas. More remains to be done to curb emissions from buildings and gaseous solutions still have a large role to play. The ongoing transformation of the gas sector will certainly enable fast progress, provide energy savings, and ensure cost-efficiency of the decarbonization of energy consumption in buildings. Gaseous solutions must be part of the pathway to decarbonise the EU building stock: - We share the Commission’s vision on the difficulty of decarbonising EU building stock: we underline the need for the energy transition to guarantee the security of energy supply - It is necessary to consider complementary solutions, in particular decarbonising the existing gas grid by blending natural gas with renewable and decarbonised gases including hydrogen, to enable fast progress and ensure cost-efficiency. - Hydrogen further enables accommodation of renewable electricity production and the decarbonisation of demand in heating and transport by integrating decarbonised embedded power generation solutions An efficient and affordable renovation is needed: Numerous barriers stand in the way of higher renovation rates, particularly the low awareness of consumers as to the benefits of renovation and the costs that end-users have to face. Cost is still the biggest factor for most consumers. For this reason, a cost effective and publicly acceptable transition is needed. Gaseous solutions can help households – particularly the most vulnerable – overcome barriers and get access to efficient and affordable heating. In order to design an effective regulatory approach, we believe that the following actions should be considered by the legislator in the policy framework: - Taking into account the specific characteristics of individual Member States - Clearer labelling and eco-design rules are needed - A harmonized approach is necessary to ensure transparency and enable the trading of Guarantees of Origin (GOs) across the EU - An update of the framework for Energy Performance Certificates is needed - The Primary Energy Factor (PEF) should accurately represent the GHG emissions stemming from appliances - Harmonizing overlapping measures that may emerge in the revision of the RED II and the EED initiatives, thus coordinating in a more effective way all the existing policies
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Eurogas Demands Binding Targets for Renewable and Low-Carbon Gases

10 Mar 2021
Message — Eurogas seeks binding 2030 targets to reduce gas intensity and increase renewable gas demand. They urge recognition of natural gas as a transition fuel to replace more polluting energy sources.12
Why — These rules would secure the gas industry's future role and provide long-term certainty for investors.34
Impact — Advocates of total electrification lose as the proposal promotes a multi-vectored approach including gas.5

Response to Revision of the guidelines for trans-European Energy infrastructure

8 Mar 2021

The TEN-E regulation represents a pivotal instrument to complete the internal market for gas and to provide secure, affordable and sustainable energy to consumers, together with its offshoots such as the PCI or CEF. The TEN-E has helped improve market integration thereby bringing lower spreads in Europe. Improvements in Security of Supply (SoS) have also been consistently delivered, through increasing access to flexibility from LNG terminal and storage along with interconnectedness between markets. Network Code implementation, along with pivotal legislation such as the Security of Supply regulation have helped complete this. Taking into account the significant progress made by TEN-E in the infrastructure sector and the measures to facilitate the timely development and interoperability of trans-European energy infrastructure networks, Eurogas believes in the importance of supporting the adequate planning of the necessary gas transmission and distribution network of tomorrow to deliver on the climate neutrality objectives. In addition, as TEN-E proposes to help create the infrastructure necessary for a cross-border hydrogen market to be realised, the scope is much broader than that of the original TEN-E. We therefore welcome the proposal to also consider the potential of smart gas grids and further digitalisation of the gas grid as way to deal with evolutions in flows and gas qualities and to provide final customers with additional information on their consumption. Equally relevant in the context of digitalization are notably technologies such as sensors for gas quality monitoring and deblending technologies such as membranes to separate hydrogen and methane which facilitate downstream treatment processes. This inclusion is a good initial step at the DSO level, but will require broader consideration, notably in the hydrogen category, to ensure the necessary network extensions can be realised. Projects of Common Interest (PCI) can make a significant contribution to reducing CO2 emissions and improving SoS, and ensure end-consumers have access to the energy they require to gradually decarbonise their uses. While PCIs usually aren’t eligible for single MS projects, we appreciate the attempt to address this through the need for cross-border impact to be proven in case the project doesn’t physically cross a border. This should be further encouraged through clarifying that two DSOs, or one DSO and a TSOs in the same country can be involved in the project in order for it to be assessed and potentially move forward, as long as other relevant operators are consulted; this is currently limited, particularly when it comes to DSO/DSO projects. In the broader context of the innovative solutions required in order to reach EU energy and climate targets for 2030 across all sectors, Eurogas highlights the need for a “just” transition as a driving principle to be strengthened in the TEN-E revision. The energy transition is fundamentally about people and the choices that they make; therefore we should be warry of imposing solutions to people. As we value citizens’ role in the climate transition as essential actors, they should have the possibility to actively participate in the whole process. In essence, Eurogas believes Energy Union Objectives should remain at the core of TEN-E, since is based on the three long-established principles of EU energy policy: security of supply, sustainability and competitiveness. Affordability also plays a pivotal role, since rolling out renewable and decarbonised energy will have a significant cost. As pointed out, sustainability remains the cornerstone of the energy transition and Eurogas is committed to climate neutrality through Renewable & Decarbonised gas targets supported by efficient gas infrastructure. This will ensure, in line with DNV-GL’s study on a pathway to climate neutrality, that the most cost-efficient pathway can materialise as quickly as possible, based on an initial policy push.
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Eurogas urges cost-effective methane rules and renewable gas targets

26 Jan 2021
Message — Eurogas advocates for cost-effective solutions and a toolbox approach accounting for local conditions. They suggest building on existing reporting frameworks while prioritizing safety for the energy system. They specifically propose a 2030 target for renewable gas to reduce emissions.123
Why — This allows the industry to use voluntary initiatives to avoid more prescriptive regulations.4
Impact — Environmental groups lose the certainty of uniform, mandatory leak detection standards across supply chains.5

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

12 Jan 2021 · Gas package – proposals of the European gas industry

Response to Climate change mitigation and adaptation taxonomy

12 Dec 2020

Eurogas represents 52 leading companies and associations in gas wholesale and retail markets, as well as operators of gas distribution infrastructure, responsible for the maintenance and safe operation of a majority of the 2.2 million km of distribution pipelines across Europe. Following the adoption of the taxonomy regulation, we believe fit for purpose Technical Screening Criteria in the delegated act (DA) will be crucial, in particular for enabling and transitional activities which would facilitate a swift and decisive decarbonisation effort towards 2050, while ensuring an overall adequacy of the energy system, affordable energy and a secure energy system. Our members remain committed to providing the necessary gaseous solutions to fulfil the EU’s 2030 and 2050 objectives and share the aim of the sustainable finance package, including the Taxonomy, but believe that these can only be delivered if the following is guaranteed: 1. Primary legislation should be the fundamental starting point upon which the delegated act should build. To this end, the delegated act should ensure that it delivers the necessary generating and storage technologies, along with the required infrastructure for the energy transition. To this end, we note that the need for enabling and transitional technologies is clear in the regulation, but technical screening criteria have not so far been developed to define these categories. This should be changed and separate, clear and achievable criteria should be put forward to guarantee a cost-efficient pathway to climate neutrality in 2050. These criteria, in addition, should be both quantitative, as for the current approach, but also qualitative, to ensure the advantages which molecules bring to the energy system are adequately accounted for. 2. The delegated act should facilitate and be compatible with the objectives and proposed implementation of National Energy and Climate Plans drafted by member states. To this end, the technology neutrality should be ensured to guarantee that a variety of transitional pathways can be followed, depending on countries’ starting conditions, and should provide sufficient dynamism by allowing for changes over time, taking stock of development in technology. Here, examples such as the impact which coal to gas switches have had, in the framework of the ETS for instance (as exemplified by the latest carbon market report published by the commission) were one of the main contributors towards reduced GHG emissions, and particular the impact the switch can have across sectors and end-users. Similar positive impacts can be associated with the use of gas mobility with regards to CO2 emissions currently limited by the tailpipe approach, thereby creating an imbalanced playing field. 3. In addition, the approach should cater for a secure, sustainable and affordable energy system, in line with the energy union objectives. To this end, a flurry of studies (Guidehouse 2020/DNV GL 2020, etc…) have underlined the need to quickly scale up renewable and low-carbon gases to guarantee a cost-effective energy transition, and their need in the long-term. Support for gas-based solutions and bioenergy will here be needed, whereas they are currently considered transitional in the draft DA, even though both can provide carbon neutral or even carbon negative production pathways depending on feedstock. A neutral approach would guarantee that cost-efficiency can be guaranteed. To help implement these recommendations in more concrete terms, we attach a set of proposed modifications building on the proposed draft delegated act. These include proposed transitional criteria for gas fired power generation, a LCA approach to mobility emissions, a more pragmatic approach to hydrogen production in order to help kick-start the market, as well as the required changes to guarantee gas technologies can help reduce emissions from building while ensuring future proofing increased levels of renewable and low carbon gas.
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Meeting with Kadri Simson (Commissioner) and

1 Oct 2020 · Energy System Integration, Hydrogen and low-carbon gases and methane emissions

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

24 Sept 2020 · TEN-E legislation and the potential for gas sector decarbonisation

Eurogas proposes binding targets for renewable and decarbonised gas

21 Sept 2020
Message — Eurogas supports binding 2030 targets for renewable gas and greenhouse gas intensity reduction. They recommend a harmonized system of certifications to ensure transparency for decarbonised gas.123
Why — The proposal allows gas companies to repurpose existing pipelines and maintain their market position.4
Impact — Consumers may face higher costs if electrification is prioritized over using existing gas networks.5

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

18 Sept 2020

Please find attached Eurogas' views on the review of the Energy Efficiency Directive.
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Meeting with Aliénor Margerit (Cabinet of Commissioner Paolo Gentiloni)

15 Sept 2020 · EU Hydrogen Strategy

Response to Commission Delegated Regulation on taxonomy-alignment of undertakings reporting non-financial information

8 Sept 2020

Access to finance remains crucial for investments geared towards the energy transition and the economic recovery. In this regard, the EU taxonomy will play a key role in ensuring that the existing and future EU legislation remain coherent with the objectives of a sustainable economic growth and of secure, competitive and sustainable energy supplies. Furthermore, it is essential that the objectives of the different legislative and non-legislative acts in connection with Sustainable Finance are coordinated and that any incoherence is removed. Sustainable Finance has close links to other policy priorities connected to the Green Deal, such as the energy system integration and hydrogen strategies along with the renewable energy directive revision, thus synergies should be exploited. In addition, the specific matters to be reported by enterprises under the NFRD should remain based on the assessment of what is really material to their business and be proportionate to the aims to be achieved under the sustainable finance package by limiting undue administrative burden. Eurogas suggests a pragmatic approach to ensure that all required data can be made available in a realistic timeframe, whilst building on the best practices already available (i.e. Global Reporting Initiatives) to facilitate timely implementation. The principles of proportionality and materiality must be taken into account as a guiding principle to ensure that the facilitation of financing sustainable products is not counteracted by high administrative burden. Keeping a balance between the businesses’ need to maintain lean processes that boost innovation and the increasing expectations regarding information on the investor side is pivotal in creating a sound and manageable administrative process. We agree with the Commission that this initiative could create positive environmental externalities. That being said, if the scope were to be defined in a narrow way without due consideration for physical constraints in power generation and transmission, systemic needs and flexibility requirements stemming from the intermittency of most renewable power production, the effect could be the opposite and prove counterproductive from a transition point of view. Whilst an investment in a type of technology does take into account the end product of the process which is being invested in, it currently does not consider either the required investment within the energy system to accommodate the additional production, nor does it take into account fully the contribution which certain technologies can make in facilitating the injection/integration of additional renewable energy production. Eurogas calls for a comprehensive assessment of all economic activities in their relevant context (i.e. geographical, sectoral) to avoid any unfair discrimination, and express our disapproval of “brown-listing” certain company activities, as this might turn out to be counterproductive both in terms of investment costs for the transition and realistic achievement of the EU long term policy objectives. In attention this could disregard considerations for both enabling and transition technologies which will gradually become fully sustainable as renewable and decarbonised gas production would increase exponentially over time. Recommendations Ensuring coherence of the taxonomy with the key objectives of a sustainable economic recovery and growth and with secure, competitive, and sustainable energy supplies, both under the existing and future EU legislation through an Efficient coordination of parallel legislative initiatives Avoid undue administrative burdens through the principles of proportionality and materiality in defining the Non-Financial Disclosure Requirements related to taxonomy Favouring positive environmental impacts taking into account the principle of level playing field and ensuring a system-wide approach which includes enabling and transition technologies
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Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski)

8 Sept 2020 · EU Energy System Integration Strategy and EU Hydrogen Strategy

Response to Offshore renewable energy strategy

13 Aug 2020

Eurogas supports the European Commission’s vision of a carbon neutral economy by 2050 and welcomes its objective of adopting an offshore renewable energy strategy. This strategy is particularly important in the context of the Commission’s long-term strategy “A Clean Planet for All” which indicates that a massive scale-up of offshore wind, renewable ocean energy, storage and conversion facilities will be required for deep decarbonisation. Please read full text in the attached document.
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Eurogas urges cost recovery for industry methane reduction efforts

5 Aug 2020
Message — Eurogas advocates for biogas production to capture agricultural emissions and wants a stakeholder working group. They argue national regulators must allow companies to recover costs for methane reduction.123
Why — This ensures gas companies receive financial compensation for their mandatory emission reduction efforts.4
Impact — Energy consumers may face higher bills as companies pass through their compliance costs.5

Response to Revision of the EU Emission Trading System Monitoring and Reporting Regulation (MRR)

24 Jul 2020

Please find attached the feedback from Eurogas
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Eurogas Urges Binding Targets for All Decarbonised Gases

8 Jun 2020
Message — Eurogas requests a binding EU-level target that includes both renewable and decarbonised gas. They also advocate for mandatory Guarantees of Origin and rules that permit blending hydrogen into existing networks.12
Why — The gas industry benefits from a strategy that justifies continued use of methane infrastructure.3
Impact — Proponents of green-only hydrogen lose as competition from cheaper natural gas-based options increases.4

Response to Commission Communication – "Renovation wave" initiative for the building sector

8 Jun 2020

Please find attached Eurogas' views on the roadmap of the European Commission on a Renovation Wave initiative for the building sector.
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Response to Strategy for smart sector integration

29 May 2020

Eurogas is fully committed to achieving the objectives of the Paris Agreement and supports the European Commission’s long-term vision of a carbon neutral economy by 2050. Eurogas advocates for an energy transition that delivers a diversified, economically, and environmentally sustainable energy mix, that guarantees security of supply, and that allows Europe’s competitive industries to continue to thrive. Climate neutrality and the deep decarbonisation of EU’s economy requires a fundamental restructuring of cross-sectoral energy use. It requires carbon neutral and carbon negative energy vectors, and increased interlinkages between energy carries and economic value chains: industry, mobility, heating, and agriculture. The energy transition cannot succeed by policy measures that seek to decarbonise sectors in isolation of each other. A holistic and technology neutral approach for mature technologies, while fostering the development of commercially non-mature technologies, is primary for climate neutrality to be a success. Energy system integration should promote the most cost-effective path towards carbon neutrality by 2050. To achieve this a variety of energy carriers are necessary. In 2017, about 22% of EU’s final energy consumption was electricity based and most parts of the economy will continue to rely on molecules. Decarbonising electricity or electrifying processes alone will not enable the deep decarbonisation of activities in a timely, just, and cost-effective manner or ensure the reliability and security of energy supply. A credible strategy to a decarbonised energy system must therefore give the right consideration to gaseous energy and its existing infrastructure. Unlocking the full decarbonisation potential of gas requires the rapid development of a supportive policy framework to accelerate the transition towards renewable and decarbonised gases. Energy system integration requires a level-playing field between electricity and gas to facilitate the transition towards renewable and decarbonised hydrogen, biomethane, biogas, synthetic methane, and other sustainable fuels. Leading the development of clean technologies will make Europe’s economy stronger, create jobs and wealth for Europeans and ensure secure and sustainable supply of energy and goods.
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Response to Climate change mitigation and adaptation taxonomy

27 Apr 2020

Eurogas is happy to provide views on the Commission's inception impact assessment (IIA) related to the drafting of the first delegated act on taxonomy. We believe that this exercise will be key in developing a comprehensive taxonomy to be applied in Europe. Eurogas and its members are committed to providing the necessary gaseous solutions to fulfil the EU’s 2030 and 2050 objectives. The economic recovery in Europe will require swift unlocking of public and private investment. For this reason, we see great value in setting up a framework for sustainable investment capable of providing clarity and certainty as to ensure that the objectives of the Energy Union are upheld through both its social and economic dimension. To this end the IIA already underlines that a coherent definition will help ensure stable investment and feed the objectives of the green deal, which Eurogas supports. That being said, we wish to strongly underline that the future definition of the Technical Screening Criteria (TSC) in the Taxonomy Regulation will play a key role in ensuring energy investments; a sector that has been identified as a crucial one to support and restart the economy of Europe. Regarding next steps we would strongly encourage the need to involve, inter alia, DG ENER among the DGs in the consultative process of inter-service discussions in addition to the JRC and others. We believe that this way, full consideration of the “system” impact of a harmonised labelling system would be considered. In addition, we note that the Sustainable Finance platform is not included in the considered stakeholder groups to work on the delegated act. We believe once set up, the platform should be a key stakeholder in taking over the current work of the TEG and should guarantee technology neutrality through the inclusion of a variety of stakeholders. We welcome the fact that further consultation is expected on the draft delegated act and sustainable finance strategy. Indeed, this is a welcome message as the consultation process of the TEG, which has indeed consulted in several fora over the past two years, openly pointed to the fact that feedback may not be incorporated in the drafting and that the aim of the group was openly that of electrifying its way to the EU’s 2050 climate change objectives rather than also paving the way for a cost-efficient approach that ensures security of supply. While we understand the need for increased electrification to achieve the 2050 objectives, we strongly believe that this can only be guaranteed through a secure and affordable energy system for citizens, with key contribution from natural, renewable and decarbonised gases through a stepwise process. To ensure this, further consultation should be conducted along with the setting up of a sustainable finance platform which would bring experts from all categories covered by the TEG report, but also of the sub-categories which, for many, were not represented in the TEG’s work. In addition, Eurogas would oppose the exclusion of activities which are in the process of starting their transition. We call for the Commission to take into account the far-ranging impact which the addition of, inter alia, a so-called brown criterion could have for transitioning activities, on both their own sector and interlinked activities, notably with regards to the affordability, security and sustainability of the transition towards climate neutrality, as a whole. Finally, we welcome the position of the Commission to propose additional guidance if required in the next steps. Eurogas and its experts will remain available to discuss the TEG recommendations and delegated act work ahead in a bid to ensure a solid and easy to implement proposal can be rolled out in the near term to ensure the required coal to gas switch, the increased electrification of the energy system, with the increased uptake of renewable and decarbonised gas in the technological solutions underpinning the stability and SoS.
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Response to Revision of the Energy Tax Directive

1 Apr 2020

A. Eurogas welcomes the commitment of the European Commission to align where necessary the Energy Taxation Directive to the objectives of the EU Green Deal, EU’s climate commitments under the Paris Agreement and market developments. Eurogas supports increased 2030 GHG reduction targets and considers natural, renewable and decarbonised gas integral to achieving climate neutrality by 2050. Eurogas supports the principle that each Member State, within a given framework of objectives, should be left with flexibility to adopt an appropriate energy taxation policy, taking into account its own present and potential mix, particularly taking into consideration the exclusive competence of Member States related to taxation. As the consultation document states, ‘a number of Member States and the Council conclusion have requested the Commission to act’. In contrast, the ordinary legislative procedure would require a unanimous agreement by the Council on this issue. B. Eurogas supports the Commission’s objectives of aligning where necessary the ETD with the Green deal and recognises taxation as an efficient tool to signal required investment and innovation of clean energy technologies. As such, Eurogas urges the Commission to recognise the role of natural, renewable and decarbonised gas to 2030 and beyond in the revision of the ETD. Natural gas has been key in reducing EU emissions since 1990 and can continue delivering important emissions reductions in many regions across the EU by switching from fossil fuels with a higher carbon footprint such as coal and oil. It would enable the EU to exceed by 5% its GHG emissions reduction target of at least 40% by 2030 in a timely and cost-effective manner. In this sense, Eurogas considers important to maintain the tax incentives applied in the transport sector to ensure greater usage of alternative fuels such as CNG, LNG, H2 that are primary to decarbonising mobility. Furthermore, modelling by Eurogas using PRIMES has shown that gaseous solutions accelerate the deployment of renewable electricity. Other major studies by DENA, ADEME, Navigant and PÖYRY confirm the strong potential and superior cost-efficiency of gaseous fuels to deliver climate targets. Whilst Eurogas agrees that certain aspects of the ETD must be reviewed, Eurogas reiterates the importance of leaving the flexibility in the area of taxation to the Member States. This would allow them to develop technologies consistent with their energy mix and geographical context. In addition, double taxation of energy conversion and storage processes including G2P, gas storage and P2G should be avoided. This is a systemic requirement ensuring that only end consumption of energy is subject to taxation which will be essential to removing obstacles for sector coupling. Furthermore, the ETD must recognise the emissions reduction potential of renewable and decarbonised gas technologies e.g. favourable taxation, tax exemption. C. Eurogas supports the Commission’s aim to strengthen the level playing field across all clean energy technologies. To achieve this, policies and economic evaluations should integrate the costs and benefits induced on the system by each decarbonisation option and ensure that adequate price signals are visible for end-customers. In turn, investments in cleaner alternatives will be incentivised. The existing European gas infrastructure enables the mass deployment and storage of renewable and decarbonised energy. It also ensures secure energy delivery to all sectors and provides the flexibility needed to meet seasonal variations and peak demand. Therefore, Eurogas calls on the Commission to acknowledge the role gas will play in the decarbonisation of the energy system and energy intensive industries. Eurogas warns against measures that would impose excessively high tax rates and increase prices for the end-consumer.
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Response to Fast-track interservice consultation on the 'SEIP including a JTM and the JTF"

12 Mar 2020

Eurogas welcomes the proposal for a Just Transition Fund. It is crucial to address the social impacts of the transition to a carbon-neutral economy and to bring all the citizens on board. Accompanying the transition with the support of people, SMEs and larger undertakings, emerges as crucial for the overall EU’s cohesion. Eurogas supports the establishment of a financial instrument that will help Member States address the societal aspects and create new jobs in regions that are the most at risk. Eurogas would welcome a cooperative approach to the elaboration of the territorial just transition plans. Indeed, for these plans to be publicly accepted and achieve their intended goals, it is important for the public authorities to involve the economic actors that will be affected as well as those that can provide solutions. This cooperation has already proven to be effective. In the Groningen region, local authorities have been working together with energy companies to facilitate the transition away from an economy based mostly on fossil fuel-related activities. Within the framework of the Governance Regulation, it is crucial to ensure consistency between these territorial plans and the overall NECPs. The purpose of the Fund is to support the transition of the regions likely to be the most negatively affected by the energy transition, in particular those dominated by energy-intensive industries and those heavily reliant on coal-based power generation. In these areas, gas – natural, renewable and decarbonised – will play a major role to bring down emissions as cost-effectively as possible. According to a 2019 Agora Energiewende and Sandbag report (“The European Power Sector in 2019”) the switch from coal-based power generation to gas-based generation is already well on its way and led to an important CO2 emissions reduction in the EU in 2019, while keeping electricity prices low. Eurogas would welcome a clarification on the scope of the Fund, which excludes “investment related to the production, processing, distribution, storage or combustion of fossil fuels”. However, excluding investments in coal- and oil-to-gas switching from the just transition funding mechanisms would result in a huge missed opportunity for quick carbon and GHG reductions in Europe. The Just Transition Fund must focus on technologies that quickly support countries shifting from carbon-intensive fuels to cleaner fuels. A switch from coal to gas is a key enabler in this respect and will provide a competitive alternative for European carbon-intensive industries. In addition, funding for efficient small gas boiler heating systems, as recently recognised by the EIB, can contribute to immediately cutting GHG emissions from heating in areas where citizens and SMEs cannot afford more costly options. Beyond the initial objectives of the Just Transition Fund, this type of targeted support would also help address the issue of energy poverty in the context of the energy transition. Finally, excluding investments that would guarantee future-proof gas distribution grids would have the adverse effect and slow down the transition towards renewable and decarbonised gases – especially hydrogen. In doing so, the Just Transition Fund would in fact limit the decarbonisation options. It would force regions into options that they will not be able to afford, even with European financial support. The Just Transition Fund should support all solutions that can help achieve the EU climate and energy objectives in line with the Energy Union principles. Investments related to gas, including renewable and decarbonised gases, as well as in infrastructure for the transportation of CO2 and Carbon Capture technologies, should therefore be covered by the scope of the Just Transition Fund. It will in any case be up to the Territorial Just Transition Plans to demonstrate that such investments make a significant and cost-effective contribution to the reduction of GHG emissions.
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Meeting with Catherine Sustek (Cabinet of Vice-President Margaritis Schinas), Chris Uregian (Cabinet of Vice-President Margaritis Schinas)

20 Feb 2020 · The role of Gas in the Green Deal

Meeting with Olivér Várhelyi (Commissioner)

20 Feb 2020 · Renewables & Power Total on green deal

Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski), Simona Pinzariu (Cabinet of Commissioner Janusz Wojciechowski)

29 Jan 2020 · The role of gas in the energy transition and the Green Deal.

Meeting with Natalie Pauwels (Cabinet of Commissioner Janez Lenarčič)

29 Jan 2020 · Green Deal

Meeting with Alina-Stefania Ujupan (Cabinet of Executive Vice-President Margrethe Vestager), Kim Jorgensen (Cabinet of Executive Vice-President Margrethe Vestager)

29 Jan 2020 · Energy transition and Green Deal

Meeting with Aliénor Margerit (Cabinet of Commissioner Paolo Gentiloni)

29 Jan 2020 · Role of gas in the energy transition and the Green Deal

Meeting with Kyriacos Charalambous (Cabinet of Commissioner Johannes Hahn)

29 Jan 2020 · Green deal, Investment Plan, Renewable Energy

Meeting with Agnieszka Drzewoska (Cabinet of Commissioner Phil Hogan), Dermot Ryan (Cabinet of Commissioner Phil Hogan)

28 Jan 2020 · Gas sector discussion. Green Deal.

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

21 Jan 2020 · Challanges and goals for the gas sector on the way to EU climate neutrallity

Meeting with Maroš Šefčovič (Vice-President) and

9 Sept 2019 · Implementation Energy Union Strategy in future gas in the context of the decarbonisation stratagy; Ukraine gas transit

Response to European Partnership for Smart Networks and Services

27 Aug 2019

Eurogas would like to welcome the roadmap looking at establishing a strategic partnership for smart networks and services in the context of Horizon Europe and the possibility to provide input at this early stage. The document highlights that, the proposal has initially “identified a European Partnership on Smart Networks and Services as a priority. The objective of this partnership is to support the development of European strategic value chains for the 'Industrial Internet of Things' and for 'Connected, Automated and Electric Vehicles”. Although the above are crucial priorities, the development of new dynamics in the gas market due to sectoral integration creates new dynamics also in the gas sector which could be further emphasized in the roadmap as we outline below; 1. Horizon Europe and its predecessor, Horizon 2020, are crucial tools in the development of adequate technological solutions to help solve the issues which the EU and its Member State currently struggle with. Funding may help develop new solutions which can help the decarbonisation effort and tackling climate change. 2. We believe the link with PCI can help streamline funding from various available sources to optimally support the development of smart networks and services. 3. We believe that the roadmap overlooks the crucial contribution which smart gas grids can provide to the energy transition a. Providing additional information to customers through the roll-out and availability of smart meters around Europe and the increasing digitalization of the grid. We note and welcome the “human-centric” approach outlined on page 3 b. Facilitating the injection of renewable and decarbonised gases through the roll-out of sensors providing more accurate and detailed information about gas quality c. Additional interactions between the electricity grid and the gas grid may be further facilitated by the digitalization of the grid. Examples of such projects which provide additional flexibility and security of supply to the grid can be witnessed with the Interflex project in France for example. 4. We would suggest adding a security of supply and safety of the network aspect, as there is a strong cybersecurity element in any digitalization exercise, which is noted in the roadmap; this risk, particularly if it is linked to critical infrastructure such as energy, must be addressed pre-emptively. 5. Smart networks, as is noted in the roadmap, also provide the potential for improved autonomy in the digital area, as well as developing a stronger competitive edge in the area of industrial policy which the EU is focusing on currently. 6. We note the three options which are presented but would suggest putting additional emphasis on bringing a variety of stakeholders together considering the increasing cross-sectoral dimension of digitalization programmes, notably when considering dynamics such as sectoral integration in the energy sector. Although only electric vehicles seem to be mentioned, the latter may have impacts on all networks as it may create spikes in electricity demand requiring flexible backup production which could be facilitated by smarter grids and networks. We wish to underline that Eurogas and its experts remain available for any further questions or clarification and that we look forward to providing feedback to the final report.
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Eurogas urges structured partnership to boost European clean hydrogen

27 Aug 2019
Message — Eurogas supports creating a Joint Undertaking with firm financial commitments and institutional structure. They recommend including energy infrastructure companies and focusing on technologies like pyrolysis. They also highlight hydrogen's potential for seasonal storage and power conversion.12
Why — This partnership would secure funding and a central role for gas infrastructure in decarbonization.34

Response to European Partnership on Metrology

27 Aug 2019

Eurogas would like to welcome the roadmap looking at establishing a European Metrology Partnership in the context of Horizon Europe and the possibility to provide input at this early stage. The document notes the importance of metrology as “the science and traceability of measurements, is crucial for today’s high-tech world. Metrology plays a part in every aspect of life. Increasingly precise, reliable measurements are essential to drive innovation and economic growth in the EU’s knowledge-based economy”. Considering metering is a central aspect in the energy sector, and as new dynamics are appearing in the gas sector due to sectoral integration, conversion of electricity into hydrogen/methane and decentralized production of biomethane, the science of metrology is a necessary pillar to support future developments. 1. Horizon Europe and its predecessor, Horizon 2020, are crucial tools in the development of adequate technological solutions to help solve the issues which the EU and its Member State currently struggle with. Funding may help develop new solutions, notably in the gas sector, which can help the decarbonisation effort and tackling climate change. 2. The roadmap underlines the importance of metrology and notes that “Metrology is also needed to evaluate the potential of any ground-breaking technology likely to contribute to reaching the sustainable development goals related to global challenges”. The need for adequate metrology units, that are comparable across Europe and can facilitate precise and comprehensive measurements and conversion are crucial with regards to technologies like Power-to-Gas. 3. In energy, and notably for Distribution System Operators, but also in relation to wholesale and retail activities, clear measurements are crucial. Cross-border transferability and compatibility make the need for a clearly defined metrology even more clear cut. 4. Taking the above into account, it must be recalled that individual countries and individual systems will have their own specificities. Although harmonization and cross-border compatibility is the aim, any measure drastically affecting the measurement systems used in certain countries should be the object of a comprehensive impact assessment before any proposals are made. Furthermore, we call on the responsible services in the Commission to take stock of existing work being done by other services on metrology to ensure cross-pollination between initiatives. 5. Moreover, clarifying how an exercise which would tackle metrology as an overarching topic rather than by sector, would be tackled would be welcome, as metrology in the energy sector will be fundamentally different than metrology in other areas such as healthcare. 6. Finally, clarifications would be welcome with regards to the ultimate goal of the program, as the current description could point to the setting up of a metrology agency, particularly as option 2 points to an exit strategy which could be correlated with an agency option. If this is the case, an impact assessment would be most welcome, particularly with regards to national specificities. We wish to underline that Eurogas and its experts remain available for any further questions or clarification and that we look forward to providing feedback to the final report.
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Response to European Partnership for a Circular bio-based Europe

27 Aug 2019

Eurogas welcomes the commitment of the Commission to set up European Partnerships to address the main challenges facing the EU in its energy transition. We believe that the Commission made sensible choices in defining the scope of these partnerships. A European Partnership for a circular bio-based Europe is all the more relevant as it would help bring about a shift in the business model of key European economic sectors and boost the emergence of new innovative value chains. The competitiveness of the European economy is at stake. Eurogas supports the establishment of a Joint Undertaking (option 2) as firm financial commitments and a clear institutional structure have proven to be efficient in the first Joint Undertaking on bio-based industries. The impact assessment rightly underlines the importance in developing the necessary synergies between various sectors, technologies and solutions. We believe that this is paramount to achieving EU objectives in terms of agricultural, energy and energy transition policy and objectives. Considering this and In line with the ongoing Joint Undertaking on bio-based industries, Eurogas believes that a focus on specific value chains would be welcome: • Waste-based products, like renewable gases, are essential value chains to support. Such a partnership would come in support of the objectives that the Commission may set in its upcoming legislative package on gas. • Renewable gases from agricultural waste can help preserve or restore the economic dynamics of rural areas, by adding value to the agricultural production. Waste can be a source of income for farmers and therefore make them less dependent on subsidies and enable them to invest more to remain competitive and shift towards more sustainable business models. • Renewable gases can also be produced from waste in urban areas, which can act as “sandboxes” for certain technologies and certain production processes; furthermore these can increase local resilience in terms of energy consumption. • In terms of the objectives of the energy transition and GHG emission reduction, the development of bio-based products and processes such as anaerobic digestion carry the additional advantage of facilitating the decarbonisation of otherwise difficult sectors to decarbonise; namely the agricultural sector. • Finally, industrial waste can be recovered and transformed, thus fostering industrial symbiosis. Eurogas remains available to provide more input into the Commission’s impact assessment on this partnership.
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Response to Evaluation of the effectiveness and policy coherence of the guidelines for trans-European Energy infrastructure

12 Jul 2019

Eurogas would like to welcome the roadmap looking at a potential revision of the TEN-E regulation, and the possibility to provide input at this early stage. As is rightly underlined in the roadmap document, the “TEN-E Regulation’s key objectives are the timely construction of projects which interconnect the energy markets across Europe, thereby facilitating a final impact of improved sustainability (via the better integration of renewable energy sources), better security of supply and improved competition within markets that keeps prices in check.” Considering the above, the development of new dynamics in the gas market due to sectoral integration and as the TEN-E directly impacts PCIs and the cross-border cost allocation element we believe that certain points could be further emphasized in the roadmap; 1. Eurogas considers the TEN-E and its offshoots such as the PCI or CEF as important cornerstone to complete the internal market for gas and to provide secure, affordable and sustainable energy to consumers. The latter energy union objectives could be further underlined in the roadmap as critical in building the future energy system. 2. As PCIs may be restricted to single Member States, if they have significant cross-border impacts, we would suggest assessing whether the financing of renewable and decarbonised gas production projects through the TEN-E and related funding opportunities such as the CEF would contribute to the achievement of EU objectives. Indeed, this could dramatically improve security of supply in that area and may also provide additional flexibility to an interconnected energy system through gas-to-power (biogas/methane or green/blue hydrogen for example) or power-to-gas conversion/production units. When assessing the level of achievement of TEN-E objectives, due account should therefore be taken of possible positive externalities of PCIs on other parts of the energy system. 3. As is well noted in the roadmap, TEN-E should support the timely implementation of energy transmission and distribution landscapes of tomorrow, we would suggest that an assessment should also consider the potential of smart gas grids and further digitalisation of the gas grid as way to deal with evolutions in flows and gas qualities and to provide final customers with additional information on their consumption. 4. Considering the increasing move towards a decentralized system of energy production, through renewable gas produced at the local level, Eurogas would recommend including Distribution System Operators in the list of main stakeholders. 5. The roadmap adequately identifies the need to consider the coherence of the TEN-E with “EU energy and climate targets for 2030, the EU long-term decarbonisation commitment, and the energy efficiency first principle”. We believe that the assessment should also consider the key principles of affordability and a “just transition”. We wish to underline that Eurogas and its experts remain available for any further questions or clarification and that we look forward to providing feedback to the final report.
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Meeting with Dominique Ristori (Director-General Energy)

15 Feb 2019 · global gas developments and the European context

Meeting with Peter Wehrheim (Cabinet of Commissioner Phil Hogan)

30 Jan 2019 · Use of biogas and biomethane for European farmers

Meeting with Bernd Biervert (Cabinet of Vice-President Maroš Šefčovič)

11 Sept 2018 · Electricity Market Design, Gas Directive amendment, Renewable Gas, Sector Coppling, Role of Gas in Transport

Meeting with Miguel Arias Cañete (Commissioner)

12 Apr 2018 · Future of gas and gas markets

Eurogas warns gas directive changes threaten security of supply

30 Jan 2018
Message — Eurogas recommends pausing the proposal until its impact has been fully assessed. The organization fears new rules create obstacles for existing pipelines and undermine investment security.12
Why — Delaying the rules protects members from retroactive legal changes and high compliance costs.34
Impact — Energy consumers lose as investment risks could stop new projects and reduce competition.56

Meeting with Günther Oettinger (Commissioner)

23 Nov 2017 · Energy Union

Response to Evaluation Energy Taxation Directive

26 Sept 2017

Kindly refer to the attached letter
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Meeting with Bernd Biervert (Cabinet of Vice-President Maroš Šefčovič)

18 Jul 2017 · Clean Energy Package

Meeting with Dominique Ristori (Director-General Energy)

19 Jun 2017 · Clean Energy for All Europeans package

Meeting with Miguel Arias Cañete (Commissioner) and

23 Mar 2017 · CAN GAS SPUR THE ENERGY TRANSITION IN CENTRAL AND EASTERN EUROPE?

Meeting with Miguel Arias Cañete (Commissioner)

7 Nov 2016 · Gas and electricity markets

Meeting with Dominique Ristori (Director-General Energy)

27 Oct 2016 · gas markets, energy issues

Meeting with Daniel Giorev (Cabinet of Vice-President Kristalina Georgieva)

6 Jul 2016 · Meeting with representatives of ''eurogas'' to discuss market and regulatory developments in the gas sector in Europe

Meeting with Dominique Ristori (Director-General Energy)

10 May 2016 · Energy policy

Meeting with Dominique Ristori (Director-General Energy)

29 Feb 2016 · European gas market

Meeting with Iwona Piorko Bermig (Cabinet of High Representative / Vice-President Federica Mogherini)

15 Jan 2016 · EU-Russia and geopolitics of natural gas

Meeting with Lee Foulger (Cabinet of Vice-President Valdis Dombrovskis) and Bundesverband der Deutschen Industrie e.V. and

12 Nov 2015 · Joint mtg energy assoc/Markets in Financial Instruments Directive II

Meeting with Maroš Šefčovič (Vice-President) and

29 Sept 2015 · Gas Strategy, Cooling and Heating Strategy, Internal Energy Market

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

24 Aug 2015 · Role of Natural Gas

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

31 Mar 2015 · Internal Gas Market

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

31 Mar 2015 · Internal Gas Market and Security of Supply

Meeting with Dominique Ristori (Director-General Energy)

2 Mar 2015 · European Energy Policy priorities

Meeting with Dominique Ristori (Director-General Energy)

4 Dec 2014 · Energy security

Meeting with Miguel Arias Cañete (Commissioner) and

2 Dec 2014 · Energy Union, 2030 Framework, Market Stability Reserve