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European Network of Transmission System Operators for Gas

ENTSOG

ENTSOG is the association of 43 gas transmission system operators across 26 European countries, established to coordinate Europe's gas transmission network and facilitate the internal energy market.

Lobbying Activity

Meeting with Monika Zsigri (Head of Unit Energy)

17 Dec 2025 · Exchange on physical security of gas transmission infrastructure

Meeting with Jens Geier (Member of the European Parliament)

21 Oct 2025 · Exhange on the implementation of the Gas market Directive

Meeting with Monika Zsigri (Head of Unit Energy)

16 Oct 2025 · Exchange on revision of the energy security framework

Gas operators urge integration over new energy security law

10 Oct 2025
Topic — The Commission is updating the EU energy security framework for a decarbonised system.
Message — The group suggests integrating updates into existing laws instead of creating a new regulation. They also seek national flexibility in defining which customers receive protection during energy crises.123
Why — This ensures that operators can recover the costs of building security-related infrastructure.4
Impact — Industrial companies face harm if future gas saving mandates are not economically sustainable.56
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Gas operators urge EU to include molecules in electrification

9 Oct 2025
Topic — The EU is consulting on strategies to shift energy demand towards electricity.
Message — ENTSOG insists that gas molecules are essential for stability and that electrification is not the only path. They argue that businesses and homes should choose their energy carriers freely.12
Why — Reusing gas networks for hydrogen protects existing assets and reduces infrastructure costs.3
Impact — Supporters of green goals lose if electrification targets remain non-binding benchmarks.4
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ENTSOG Demands Technology Neutrality and Gas Pipeline Repurposing

10 Jul 2025
Topic — EU consultation on measures to accelerate the expansion and digitalization of energy grids.
Message — ENTSOG demands that molecules like hydrogen and biomethane be treated equally to electricity through technology neutrality. They urge the Commission to prioritize repurposing existing gas assets and provide state guarantees to de-risk investments.123
Why — This allows gas operators to avoid decommissioning costs while securing funding for new infrastructure.4
Impact — Proponents of rapid electrification lose influence as gas infrastructure remains central to energy strategy.5
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Meeting with Joaquim Nunes De Almeida (Director Internal Market, Industry, Entrepreneurship and SMEs)

7 May 2025 · Hydrogen infrastructure development

Meeting with Jens Geier (Member of the European Parliament)

11 Mar 2025 · Effects of the Clean Industrial Deal on the Gas and Hydrogen Sector

Meeting with Dan Jørgensen (Commissioner) and

30 Jan 2025 · Affordable Energy action Plan

ENTSOG demands grandfathering to secure low-carbon hydrogen investment

21 Oct 2024
Topic — The European Commission is establishing a methodology to certify emission savings from low-carbon fuels.
Message — The organization requests a grandfathering clause to protect investors from future regulatory changes. They also want comprehensive default values for all production stages and the option to use specific clean energy contracts.123
Why — This would provide long-term regulatory certainty and reduce the technical complexity of project certification.4
Impact — Environmental protections may suffer if projects are exempted from future, more accurate emission reporting requirements.5
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Meeting with Christian Ehler (Member of the European Parliament)

19 Mar 2024 · CCUS

Meeting with Maroš Šefčovič (Executive Vice-President) and

26 Feb 2024 · Clean Transition Dialogue on EGD Infrastructures

Meeting with Ditte Juul-Joergensen (Director-General Energy) and EPIA SolarPower Europe and

26 Feb 2024 · Clean Transition Dialogue on EGD Infrastructures

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

13 Nov 2023 · Exchange on the gas market directive

Meeting with Ruud Kempener (Cabinet of Commissioner Kadri Simson), Stefano Grassi (Cabinet of Commissioner Kadri Simson)

6 Nov 2023 · Hydrogen and decarbonised gas markets, investments and infrastructure

Meeting with Ruud Kempener (Cabinet of Commissioner Kadri Simson), Stefano Grassi (Cabinet of Commissioner Kadri Simson)

6 Nov 2023 · Gas and hydrogen infrastructure planning

Meeting with Jens Geier (Member of the European Parliament, Rapporteur) and Verbraucherzentrale Bundesverband

31 Oct 2023 · Exchange on the gas market directive

Meeting with Patrizia Toia (Member of the European Parliament, Shadow rapporteur)

27 Oct 2023 · Hydrogen and Gas Regulation (meeting held by the APA responsible)

Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton)

10 Oct 2023 · Hydrogen infrastructure developments

Meeting with Maroš Šefčovič (Executive Vice-President) and

10 Oct 2023 · Hydrogen

Meeting with Kadri Simson (Commissioner) and

5 Oct 2023 · Winter outlook.

Meeting with Juraj Nociar (Cabinet of Vice-President Maroš Šefčovič)

5 Oct 2023 · Hydrogen

Meeting with Ruud Kempener (Cabinet of Commissioner Kadri Simson), Stefano Grassi (Cabinet of Commissioner Kadri Simson)

26 Jul 2023 · Winter outlook for gas 2023-2024 – hydrogen and gas decarbonisation package

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

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

ENTSOG Urges Role for Gas in Power Market Flexibility

16 May 2023
Topic — The EU is reforming its electricity market to improve resilience and reduce costs.
Message — ENTSOG advocates for permanent capacity payments to support dispatchable power like gas plants. They request including gas and hydrogen operators in system flexibility planning. The group supports locational signals to incentivize electrolysers and reduce grid costs.123
Why — This would ensure gas infrastructure remains financially viable and central to energy security.45
Impact — Environmental groups may lose if subsidies are extended to fossil-based power plants.6
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Response to Interservice consultation on the electricity market design reform - REMIT

11 May 2023

ENTSOG was founded in line with Regulation (EC) 715/2009 and has played a key role in facilitating integration of the European gas markets, ensuring technical interoperability, and providing security of supply by gas infrastructure planning. Looking forward, ENTSOG is contributing to the net-zero decarbonisation by 2050 by the integration of renewable and low carbon gases via future-proof gas transmission pipelines, in line with the EU energy and climate goals. Since 2015, ENTSOG has been an RRM, reporting fundamental data to ACER on behalf of the gas TSOs. Additionally, ENTSOG supports the REMIT implementation by its participation in Forums, Roundtables, User Group meetings, Expert Groups and more. ENTSOG has evaluated the proposed amendments of REMIT and enclose detailed feedback on the text. In summary, it is our view that the proposed REMIT updates are predominantly not directly related to the Electricity Market Design reform and thus not urgent. ENTSOG is therefore of the opinion that they should not be linked with the legislative proposals for Electricity Market Design. This de-linking would have the advantage to give sufficient time for a much-needed thorough discussion of the proposal with all affected stakeholders. Such further discussion is in our view essential for the following reasons: The proposed changes in the draft document seems to cover only ACER-CEER proposals made during the PCs in February 2023 on the EMD reform. The feedback provided by the other stakeholders is not reflected; Many of the new clauses are directly copied from MAR and the competition law without proper analysis on their applicability and potential negative effects on the energy market; ENTSOG finds it problematic that several of the suggested changes result in conflicts in the reporting regime and add disproportional burdens on Market Participants, RRMs, OMP and IIPs. As a preliminary input to such discussions, several improvement proposals are attached hereto, most importantly: Keep inside information disclosure out of the REMIT fees regime; Keep current PPAT notion, and avoid adding the element of execution that makes all Market Participants PPAETs; If obligations to report the full order book, aiming to align obligations and data availability, are placed on OMPs instead of market participants, OMPs must be empowered to do so; Keep obligations for data completeness and data quality on Market Participants; Empowerment of ACER in relation to investigations should be strictly limited to cross-border cases. The proposed new ACER powers jeopardize the balance set by the Third energy package between the competences of the national and European regulatory authorities; Application (technical entry into force) should be extended by at least 6 months due to technical reasons most importantly the implementation of new communication channels between ACER and IIPs, and registration of the IIPs. /ENDS/
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Meeting with Ruud Kempener (Cabinet of Commissioner Kadri Simson), Stefano Grassi (Cabinet of Commissioner Kadri Simson)

7 Mar 2023 · Hydrogen and Decarbonised Gas Markets – Electricity Market Design reform

Meeting with Tsvetelina Penkova (Member of the European Parliament)

19 Jan 2023 · Meeting between Mihael MIHOV (APA) and ENTSO-G on the gas package

Meeting with Kadri Simson (Commissioner) and

26 Oct 2022 · Joint purchasing options.

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

29 Sept 2022 · Infrastructure, preparedness and energy security.

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

21 Jun 2022 · Discussion about security of supply and gas infrastructure.

Response to Revision of EU rules on Gas

29 Mar 2022

ENTSOG welcomes the European Commission’s publication of the recast Gas Directive but finds there is need for certain amendments to achieve EU goals. The introduction of a system of financial compensation to ensure financing for cross-border hydrogen infrastructure (effectively an ITC mechanism for hydrogen) would be unnecessarily complex and overly burdensome. ENTSOG believes that tariffs for hydrogen should be based on current market arrangements. Whilst ENTSOG welcomes the inclusion of low-carbon gases and low-carbon hydrogen within the proposed recast Gas Directive, we are concerned that the methodology to calculate the 70% greenhouse gas saving threshold will not be determined until after the adoption of the recast Gas Directive. This will make related definitions obscure and difficult to apply in practice. ENTSOG asks the EC to clarify the definitions of low-carbon gases and low-carbon hydrogen to coincide with the adoption of the recast Gas Directive. ENTSOG is proposing a climate value market where a GO+ scheme (i.e. the current Guarantee of Origin with additional information on the GHG emission) would be the single currency to use for the EU ETS or any target compliance. This scheme would be easier and cheaper to implement. ENTSOG believes that the EC’s proposal on vertical unbundling risks stifling or delaying investment in hydrogen infrastructure. The future EU hydrogen network will be largely developed through the repurposing of existing gas infrastructure at a fraction of the societal cost of new infrastructure construction. Gas transmission operators are ready and willing to invest in the repurposing of gas assets. Both the EC and EU regulators have confirmed that the current unbundling models for energy infrastructure have been proven to function well. The hydrogen infrastructure is likely to share the same features as the electricity and natural gas transmission networks. Therefore, there is every reason to assume that all three unbundling models could also be effectively applied to hydrogen network operators (HNOs). The EC’s proposed unbundling models for hydrogen networks would prevent gas ITO TSOs from owning and operating a hydrogen network after 2030. This would disincentivise investment by ITO TSOs also before 2030. ENTSOG proposes to remove the 2030 time-limitation applicable to the ITO model. To foster decarbonisation, regardless of their unbundling models, TSOs should be allowed to invest in decarbonisation technologies such as power to gas under a tolling model. Under such a model, the owner and operator of the facility provides energy conversion or other services and is only responsible for operating such facilities. Current rules for gas, and future rules for hydrogen, would be respected as owner and operator of such a facility would not engage in trading or supplying those commodities. ENTSOG agrees with the EC that the joint operation of hydrogen networks and gas or electricity grids can create synergies and should thus be allowed. The separation of regulatory asset bases for gas and hydrogen networks ensures transparency to trace financial transfers between gas and hydrogen under the scrutiny of regulatory authorities and subject to their approval. Additional legal separation between HNOs and TSOs is not proportionate and would create unnecessary costs and administrative burden. As such, ENTSOG proposes to delete Article 63 on horizontal unbundling of HNOs. In addition, rules regarding disclosure of commercially sensitive information and operation of joint services, could result in a situation where synergies between TSOs and HNOs could be prevented, to the detriment of consumers and society. Finally, the concept of combined operator(s) should allow one single entity to carry out two or more of the following natural gas and hydrogen activities: gas transmission, gas distribution, LNG regasification, gas storage, hydrogen network activities, hydrogen terminal, and hydrogen storage.
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Response to Revision of EU rules on Gas

29 Mar 2022

ENTSOG welcomes the European Commission’s publication of the recast Gas Regulation but finds there is need for certain amendments to achieve EU goals. ENTSOG welcomes the EC’s proposal to allow financial transfers between regulated services for gas and hydrogen as one way to finance the hydrogen network. However, there should be some degree of flexibility for Member States in this matter. ENTSOG does not understand the reasoning behind the time limitation for such transfers. Any transfer should be able to continue until there is sufficient demand on the hydrogen system for hydrogen network tariffs to finance the required hydrogen network infrastructures. EC’s proposal to have an ex-post discount for renewable and low carbon gases in interconnection points of the gas networks risks fragmenting the gas market. Maintaining current tariffs for these gases in the gas system should be preferred. Furthermore, it would be more efficient and economical to implement a climate value market, based on integration of Guarantee of Origin (GO) and Proof of Sustainability systems to promote renewable and low carbon gases. The introduction of (i) an inter-TSO compensation (ITC) mechanism for these gases in the gas network would be unnecessarily complex and burdensome. Regarding the creation of ENNOH, ENTSOG welcomes the recognition of hydrogen under the gas market design. The creation of ENNOH must build on the existing synergies between gas and hydrogen and further integration of ENTSOG and ENNOH regulatory tasks. Otherwise, this will lead to fragmentation of the energy system, disintegration of gas and hydrogen modelling and planning activities, and create administrative burden. ENTSOG calls for the full integration of hydrogen and gas network activities, such as network planning and security of supply, especially while the hydrogen market remains immature. ENTSOG has the expertise and experience to fulfil specific hydrogen activities and the Ten-year Network Development Plan for Gas 2022 is already designed to assess hydrogen infrastructure. ENTSOG also supports close cooperation between ENNOH and ENTSOG in network code development and monitoring of their implementation and effect. ENTSOG welcomes the inclusion of provisions on gas quality (GQ) handling as relevant and necessary for users. For blending, TSOs are ready to accept the task of ensuring efficient GQ management in their facilities provided their investments and related costs are recognised by the regulatory framework. For this, TSOs need the possibility to assess new connections to the network against the stability of GQ parameters like the Wobbe Index. The legislation should also be more specific regarding the rights of TSOs to operate facilities for the blending/deblending of gases and to provide the respective services, to ensure gas quality management. In principle ENTSOG supports the 5% hydrogen content cap and the process of dispute settlement. ENTSOG however believes that exemptions from the acceptance of this hydrogen share should be possible, with approval of the regulatory authorities and the European Commission. ENTSOG appreciates the amendment of the Security of Supply Regulation with the inclusion of renewable and low-carbon gases and the introduction of preventive measures such as obligations for storage filling or strategic stocks and their possible usage in a Security of Supply crisis, based on regional risk assessments. Discussions with all relevant stakeholders will be needed to clarify the procedures for purchasing strategic stocks and their subsequent usage including the recognition to the TSOs or other undertakings designated by the member states of any costs borne. ENTSOG welcomes the inclusion of cost-coverage for Cyber Security (CS) in the revised SoS Regulation. However, ENTSOG believes that before developing a separate network code for CS, a careful evaluation of the effectiveness of the implementation of the NIS directive should be conducted.
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Response to Act amending Implementing Regulation (EU) 2018/2066 on the monitoring and reporting of greenhouse gas emissions

10 Jan 2022

ENTSOG (European Network of Transmission System Operators for Gas) fully acknowledges the importance of the robust and harmonised implementation of the sustainability and GHG emission saving criteria for bioenergy in the EU ETS. Thus, we support the initiative of the Commission to postpone their application according to Art. 38 of the EU ETS Monitoring and Reporting Regulation (hereinafter - MRR) until the end of 2022. To support further alignment of bioenergy policies with climate objectives and ensure consistent application of the MRR in the EU, we also suggest clarifying the requirements of Art. 39 complementing sustainability and GHG emission saving criteria of Art. 38, which together regulate the eligibility of biomethane for the zero-emission factor. To benefit from such a zero-emission factor, the EU ETS Operator will need to show a ‘purchase record’ of biomethane and prove that he is connected to ‘the same gas grid’ as the gas producer. However, Art. 39 does not explain what ‘the same gas grid’ and ‘purchase record’ mean, which gives room for multiple interpretations at the national level leading to a regulatory fragmentation at the European level. We believe that the ‘same gas grid’ should be understood as an ‘interconnected system’ for gas within the meaning of the Gas Directive (in other words, the European gas infrastructure). Due to the interoperability and the high interconnection level of the European gas infrastructure, renewable gas injected in one Member State, could be easily delivered to and withdrawn in another. This set-up allows biomethane to enter a liquid EU gas market where it can be purchased by EU ETS Operators for reduction of their emissions without unnecessary transaction costs. Our exchange with stakeholders has also indicated that the most efficient and convenient tool to prove a ‘purchase record’ of biomethane would be a tradable energy certificate based on the extended Guarantee of Origin (GO). Compared to other tools for determining the fraction of biomethane in a gas mix, this solution has the following advantages: • the GO-based certificate system will be introduced for biomethane in all EU Member States by virtue of RED II requirements (Art. 19) and is already in place in many domains (e.g. Denmark, Netherlands, Flanders in Belgium); • it is fully compatible with the current set-up of the EU gas market, i.e. allows for a separate trade of certificates and commodity, thereby facilitating the cross-border trade of biomethane and a truly integrated internal energy market; • the design of this system, common for the EU area, will prevent double claims on the use of biomethane, making it a trustworthy, fraud-resistant and user-friendly tool for tracing the origin of gases; • there is already a market infrastructure in place due to established use of electricity GOs, which will reduce related administrative costs; • the GO-based certificate could integrate the information on 1) compliance of biomethane with RED II sustainability criteria as verified by the voluntary certification schemes and 2) its injection into the European gas infrastructure and thereby its tradability in the internal gas market. It means that a full scope of information required to claim the zero-emission factor of biomethane will be accommodated in a single document for the convenience of EU ETS Operators. Such an upgrade is already proposed in the draft GO Standard EN16325 (under revision of CEN). We believe that the current revision of MRR is a good opportunity to clarify these aspects and bring certainty for the EU ETS Operators and competent authorities. Alternatively, this clarification could be done through the MRR guidance documents which also require an update. We remain at your disposal to discuss these proposals. ENTSOG
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Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans), Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans)

7 Dec 2021 · Hydrogen and gas sector decarbonisation package

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

20 Oct 2021

ENTSOG (European Network of Transmission System Operators for Gas) welcomes the European Commission’s legislative proposal COM (2021) 557 on the revision of the Renewable Energy Directive and would like to support the future legislative process with the following comments and proposed changes (please see attached). We hope our contribution will help policymakers better assess available policy options. We are at your disposal for any clarification questions and would be interested in exchanging views with you. Best regards, ENTSOG
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Meeting with Kadri Simson (Commissioner) and

12 Oct 2021 · Energy prices and security of supply.

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

10 Sept 2021 · Hydrogen and gas sector decarbonisation package

Response to Detailed implementing rules for the voluntary schemes recognised by the European Commission

27 Jul 2021

ENTSOG (European Network of Transmission System Operators for Gas) welcomes the initiative of the EC on preparation of the Implementing Regulation on rules to verify sustainability and GHG emissions saving criteria and low indirect land-use change-risk criteria and would like to provide its comments to facilitate the implementation of the recast Renewable Energy Directive. Please find our consultation response attached. Best regards, ENTSOG
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Response to Revision of EU rules on Gas

5 Mar 2021

ENTSOG welcomes EC’s analysis of hydrogen and gas markets and agrees in principle with the identified problem areas. Key ENTSOG statements: 1. Infrastructure will serve as driver for competitive hydrogen markets 2. Building on similar legislative principles, preferably by integrating hydrogen into the gas legislation, is relevant for current stage of hydrogen development 3. Role of gas TSOs to build on similar regulatory principles for grid access and operations 4. Guarantee adequate financing and cost recovery for development of H2 networks 5. Planning and investment clarity for first hydrogen projects is a must Like today’s gas consumers, future hydrogen consumers should enjoy liquid, competitive markets. Connecting hydrogen clusters and valleys across the EU will be key for cross-border trade, security of supply and to unlock decarbonisation potential. This connection can largely be achieved by repurposing gas infrastructure, minimising societal costs and benefitting consumers. Retrofitting of gas networks to transport blends of gas and hydrogen will also play a significant role at least in certain regions and markets. The internal energy market, and rules for natural gas, has served EU citizens and industry well. The future hydrogen network is expected to share basic attributes of the gas network (i.e. natural monopoly with multiple types of production and consumption). Thus, similar principles to the Gas Directive (e.g. concerning unbundling and non-discriminatory third party access) should also apply to hydrogen networks, with tailored regulatory interventions or exemptions for specific stages of development of the hydrogen market. Incorporating rules for hydrogen market and infrastructure in gas legislation would be the most efficient way to ensure regulatory alignment and promote system integration between hydrogen and gas. Existing hydrogen networks should follow similar principles of the Gas Directive to ensure a competitive market, promoting transparent and open access to infrastructure. Exemptions for a period may be applicable under certain criteria. Gas TSOs already have experience in planning, financing and operating efficient networks. As parts of these will form the basis for a hydrogen network, it makes sense to allow TSOs to own and operate hydrogen networks under similar conditions to those for gas. This will result in a more efficient transition to and operation of future hydrogen networks and enable existing safety and security of supply arrangements to be mirrored to hydrogen. In addition to existing roles of gas TSOs, new roles linked to grid management (such as gas quality management and conversion services) should be established to support operation of integrated gas and hydrogen networks. While issues of funding of investments is a matter for each member state, revised Gas regulation should provide a clear framework enabling such financing mechanisms. To ensure cost-effective and timely development of hydrogen networks, design and construction should meet longer-term forecast of hydrogen demand in terms of scale location and timing. Financing hydrogen network development through hydrogen users alone could, at least in the short term, lead to prohibitively high network charges and stifle liquidity. One solution could be to mutualise hydrogen network costs with gas network costs (without jeopardising cost recovery for existing gas networks). This could contribute to an affordable energy transition by spreading costs across a larger number of consumers. Such mutualisation could be complemented by general funding mechanisms, such as in the EU Recovery Plan and TEN-E regulation. ENTSOG will include hydrogen infrastructure planning at a cross-border level in TYNDP 2022. The revised regulation should, therefore, establish that governance for transition from gas to hydrogen should be planned transparently and integrated in existing planning framework at national and EU level.
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Response to Updating the EU Emissions Trading System

20 Nov 2020

The European Network of Transmission System Operators for Gas (ENTSOG) believes the EU Emissions Trading System (ETS) can give clear price signals to support decarbonisation and to meet the more ambitious climate targets for 2030, recently laid out by the EU Commission. ENTSOG recognises the need to adapt the EU ETS to align with these targets and possibly extend the scope of the EU ETS. ENTSOG also suggest that the EU ETS should encourage fuel switching, for example, from oil and coal to natural gas, and in particular by promoting the uptake of renewable and low-carbon gases with a high climate value. Increasing the use of renewable and low-carbon gases by EU ETS operators will not just be necessary to reach the 2030 and 2050 climate targets, their use will also provide a solution for decarbonisation that has a lower cost. In particular, the benefit of various types of hydrogen should be recognised in the EU ETS legal framework proportionate to their greenhouse gas reduction. To allow EU ETS operators to benefit from zero, or reduced, emission rate of renewable and low-carbon fuels, Guarantees of Origin (GOs) for renewable and low-carbon gases should be fully recognised in the EU ETS as a means to demonstrate consumption of these gases. The EU ETS should enable market participants to use the climate value of all renewable and low-carbon gases certified by GOs for compliance with their emission reduction obligations. These gases can decarbonise the fuel mix of carbon intensive industries subject to the EU ETS (in particular, energy intensive industry, power generation, maritime) and provide them with an additional carbon abatement solution (in addition to buying emission allowances or modernising their industrial processes). Recognising GOs for renewable and low-carbon gases in the EU ETS would also stimulate the use of these renewable and low-carbon fuels, speeding up the energy transition and decarbonisation of the economy at the lowest possible cost. Using EU ETS support instruments to increase investment in these fuels can also make a significant contribution. As demand rapidly increases and the market matures, support can gradually be phased out with primarily the EU ETS market remaining as stimulus. Extending the scope of the EU ETS to maritime and road transport emissions would stimulate the development and deployment of low-carbon fuels in these sectors. While renewable and low-carbon solutions such as hydrogen, bio-LNG and bio-CNG are not yet abundantly available, LNG and CNG can provide cheap and effective solutions. This would pave the way for infrastructure deployment which will eventually be used for renewable gases whilst already providing significant CO2 and local pollutant emissions (particle matter, NOx, SOx) benefits compared to fuels predominantly used in the maritime, road transport and other economic sectors. There would be no lock-in effect by encouraging LNG and CNG via the extension of the EU ETS as the relevant infrastructure would be developed and subsequently used by bio-LNG and bio-CNG (and potentially also by hydrogen). In addition, incorporating a full life-cycle CO2 emissions assessment of new HGVs - proposed in Regulation (EU) 2019/1242 setting CO2 emission standards for new HGVs - under the EU ETS, would take account of the benefits of advanced biofuels, such as bio-CNG, which could play a major role in reducing emissions from heavy transport. To avoid any double environmental taxation the revised EU ETS and related legislative initiatives in the field of climate and energy (e.g. Energy Taxation Directive or Carbon Border Adjustment Mechanism) should be complementary with distinct applications. If the EU ETS is extended to a certain sector, this should be taken into account in the scope of any related legislation to avoid GHG content being taxed twice. The EU ETS should be the primary mechanism to price GHG emissions.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

16 Sept 2020

ENTSOG is the European Association of Gas Transmission System Operators. With this response we would like to propose amendments to Renewable Energy Directive 2018/2001 (RED II) and, by doing so, advocate for Option 4 of the Inception Impact Assessment which is to ‘amend RED II to translate into legal measures the actions proposed in other energy strategies of the European Green Deal’. Our proposals are fully in line with recommendations made during Madrid Forum in June 2019 on behalf of a ‘Prime Movers’ group of associations (please see here: https://ec.europa.eu/info/sites/info/files/gie-entsog-_recommendations_-_eu-wide_system_of_certification_and_gos.pdf). According to the Inception Impact Assessment elements emanating from the EU strategies on Energy System Integration (ESI) and Hydrogen (H2) should be considered in the revision of RED II. We fully support this idea and suggest that particular attention should be paid to the proposal to introduce ‘a comprehensive terminology for all renewable and low-carbon fuels and a European system of certification of such fuels based on full life cycle GHG emission savings and sustainability criteria’. The Green Deal aims to achieve greater GHG emission reductions across EU, in particular 2030’s enhanced target. This could be done via the uptake of renewable and low-carbon gases (e.g. biomethane, ‘green’ and ‘blue’ hydrogen, synthetic methane etc.) fostering GHG emission reduction in a timely and cost-efficient manner. Therefore, the revision of RED II as such should give the framework to all gases which demonstrate GHG emission savings and should provide for: - a clear and straightforward classification (terminology) of decarbonised and low-carbon fuels. This would help consumers better understand characteristics and differences between various types of fuels and enable them to make a right choice depending on individual decarbonisation needs and preferences; - mandatory issuance of Guarantees of Origin (GOs) to all types of decarbonised and low-carbon fuels which demonstrate GHG emissions savings (e.g. ‘blue’ hydrogen). In this case GO issuing should not be the option for Member States (as currently provided for the non-renewable energy in Art. 19(2) of RED II) but should become an obligation. This would also ensure a level-playing field for various types of fuels and technologies used for their production; - the use of the GO system as a basis for the European certification system. GO is an effective European-wide and market-based instrument which provides market participants with a trustworthy information about the fuels and their characteristics. The GO systems will be shortly introduced in all EU Member States for the renewable energy and will be based on rules of the GO Standard (EN 16325), which makes GO system a good starting point for construction of a more sophisticated European certification system; - indication of information related to GHG emissions/savings and sustainability information (where relevant) in all types of GOs. Life Cycle Analysis comparable between all energy carriers is needed to allow end-users to make well-informed choices. We believe that market participants should get easy access to this information when it is properly confirmed by dedicated label/certification schemes (e.g. the one mentioned for biomass fuels in Art. 30 of RED II). This will be particularly important for industrial consumers subject to the EU ETS (in the light of the pending reform of the EU ETS Monitoring and Reporting Regulation). Moreover, this link between GOs and other labels/ certificates is considered as an effective tool to prevent false or double claims on the origin of energy and is being fruitfully discussed in the CEN fora for revision of the GO Standard. We hope this contribution will be helpful and remain available to discuss it in more detail. Kind regards, ENTSOG
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Response to Revision of the EU Emission Trading System Monitoring and Reporting Regulation (MRR)

15 Jul 2020

ENTSOG represents gas TSOs and with this response would like to support the Commission in the process of the revision of the Regulation 2018/2066 on the monitoring and reporting of GHG emissions (MRR). We endorse this initiative and suggest that MRR revision should be considered as an opportunity to introduce additional tools to speed up decarbonisation of the ETS sectors of economy in a cost-efficient manner and in line with the Green Deal objectives. However, it seems that this approach will not be fully secured with the current MRR draft. We suggest that the draft could be further developed, i.e. to address the following: - the need to enshrine a single market-oriented methodology to determine the biomass fraction in fuels delivered to the ETS Operators by gas networks, which will bring more value to climate attributes of biogas. Indeed, Art.39(3) of the current draft allows EU Member States to choose between two mutually exclusive methodologies. The first one is based on the use of purchase records of biogas and the second – on an average emission factor calculation for a specific gas network. We suggest that only one common methodology should be enshrined in MRR as it will bring harmonisation across the EU and prevent market distortions. Choosing between two methodologies, we believe the first one should be preferred (with some further changes) whereas the second should be abandoned as we do not consider that it is compatible with the internal gas market. It may reduce incentives to promote growth of biogas production and destroy a level playing field for the ETS Operators; - the need to clarify the notion of purchase records of biogas and conditions for application of related methodology. Art.39(4) of the draft provides that upon specific conditions ETS Operators may determine the biomass fraction using purchase records of biogas. However, it is not clear which documents could be qualified to serve this purpose. We recommend that guarantees of origin (GO) introduced in Art.19 of Renewable Energy Directive 2018/2001 (REDII) can be used as a part of the relevant documentation. The GO is a market-based tradable instrument designed to disclose the origin of energy, including biogas. It could prevent double incentives for energy production and double counting in its consumption. Herewith, some conditions specified in Art.39(4) should be reconsidered as they may constitute an unjustified restriction for the internal gas market where biogas is traded (i.e. point (c) according to which the ETS Operator needs to be connected to the same gas network as a biogas producer); - the need to clarify how the compliance of biogas with the sustainability and GHG emission saving criteria of REDII could be demonstrated by ETS operators. We understand that according to the current MRR draft compliance of biomass with the respective criteria of REDII should be verified. However, it is not clear which documentation ETS operators could use for this purpose. We believe that the GO could become such a document insofar as it provides information on sustainability and GHG emissions as confirmed by voluntary sustainability schemes according to Art.30-31 of REDII; - the need to extend the scope of MRR and introduce rules for treatment of decarbonised, low-carbon and renewable gases (other than biogas) in the ETS sectors. The draft is focused on treatment of biogas for the purpose of emissions monitoring and accounting (e.g. revised Art.38-39). We suggest that the scope of the revised MRR should be extended to ensure that these gases receive the similar treatment as biogas. This proposal, in particular, relates to gases injected into gas networks and would help an ETS Operator burning a blend of hydrogen and methane to document the hydrogen share in its fuel. Burning pure hydrogen may not need to be covered by MRR as it does not emit CO2. Please see our detailed proposals for the MRR draft in the file attached. We would be pleased to discuss this.
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Response to A EU hydrogen strategy

8 Jun 2020

ENTSOG supports the European Hydrogen Strategy Representing 44 EU gas transmission system operators (TSOs) – ENTSOG welcomes the European Commission (EC) plan to place the EU Hydrogen Strategy at the core of the green recovery, together with the Industrial Strategy, Energy System Integration Communication, sustainable finance taxonomy and the revision of TEN-E Regulation. We also wish to express our interest to join and support the works of the European Clean Hydrogen Alliance, as we strongly believe that existing gas grids, once adapted where necessary, will provide a key building block of a cost-efficient transition to a H2 economy. To allow for effective impetus and scale, all types of H2 should be considered We note the EC’s choice to focus on end-use when establishing the H2 economy, through direct decarbonisation of industry, heat and transport, and through sector coupling to maximise the potential of intermittent renewables. Evidence and growing industry consensus suggest that H2 has a key role in efficient decarbonisation of all sectors, not only those difficult to electrify. Clean H2 should contain an inclusive definition for renewable, decarbonised and low carbon H2, produced from electricity and from gas, combined with CCUS. Studies indicate that decarbonised and low carbon H2 is expected to be significantly cheaper than renewable hydrogen until 2040. Relying on renewable hydrogen alone will most likely lead to a more expensive energy transition and a slower GHG reduction. ENTSOG reiterates its view that low-carbon hydrogen will deliver necessary volumes to enable the markets and allow for scale-up of renewable hydrogen. Guarantees of Origin and Certificates System is key The Strategy should ensure incentives for market participants to invest in industrial-scale H2 production. The most cost-effective and efficient tool to do this is a robust EU-wide scheme for guarantees of origin (GOs) for all renewable, decarbonised and low-carbon gases, effectively connected to the EU ETS, as another carbon abatement solution (next to trading emission allowances). A full value chain approach and synergies with Energy System Integration are needed ENTSOG favours a systemic view and prepares for gas grids to play an important role in connecting H2 production, consumption, storage centres and efficient import. The Strategy needs to consider the full value chain perspective, involving producers, infrastructure, customers, and appliance manufacturers. This requires proper planning and gas quality and capacity management, to avoid a downstream injection point monopoly effect. P2G facilities will require careful siting and sizing that would support the electricity system needs and H2 demand. The Strategy should address current taxation regimes that provide a barrier to market integration of P2G. Looking at H2 clusters and H2 backbone networks, the Strategy should reflect regional specificities in the EU which will determine exactly how H2 is produced and used. Member States may allow for dedicated H2 systems and/or blending solutions, depending on conditions. The Strategy should design mechanisms for cross border coordination aiming at H2 market liquidity and Security of Supply. Build on gas markets’ and grids’ success A H2 system connecting supply, demand and storage centers is very similar in its nature to the natural gas system. Natural gas and H2 markets should align and ideally evolve into a single set of market rules, where possible. An open and non-discriminatory access to the system fosters competition and thereby reduces energy costs for consumers. Adopting similar regulatory principles for H2 transport as applied to gas is to the benefit of all market participants. Clarification of gas TSOs active role in supporting the development of a European hydrogen economy, as well as in leading on hydrogen networks development, can contribute to the overall goal and the actions listed in EU Hydrogen Strategy.
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Response to Revision of the guidelines for trans-European Energy infrastructure

8 Jun 2020

Since its foundation in 2009, the European Network of Transmission System Operators for Gas (ENTSOG) contributed to EU’s energy objectives: development of the EU Internal Energy Market and security of energy supply. With the commitment for European Green Deal’s climate neutrality, ENTSOG and its 44 Members have proved a progressive approach to decarbonisation in the Joint Scenario Report by ENTSOG and ENTSO-E for TYNDP 2020. Renewable, decarbonised & low-carbon gases projects enhance GHG reductions meeting the cross-border condition of TEN-E. Therefore, support to sustainability through renewables penetration, equally on electricity and gas side, is vital to achieve the decarbonisation without compromising security of supply, competition and affordability achievements. 1. Ensure a level playing field between electricity and gases ENTSOG believes that the future EU energy system should build on a Hybrid Energy System, with a level playing field and interlinkage between gas and electricity. For a cost-efficient decarbonisation, a coordinated and coherent interaction between electricity and gases (natural gas, biomethane, synthetic methane and hydrogen) is essential. As shown by Joint TYNDP 2020 Scenario Report, due to the intermittency of RES the power sector also needs decarbonised gases to ensure security of supply and to reach climate neutrality. Power to Gas enables renewable energy supply in the form of hydrogen to be transported via gas grids to sectors hard to electrify and alleviates electricity infrastructure by avoiding the curtailment of non-dispatchable renewable electricity and contributes to hydrogen economy. 2. Projects to be considered for revised TEN-E Regional differences of the decarbonisation pathways shall be considered while assessing possible inclusion in the PCI process. In some Member States, support to Just Transition projects is required for energy security, market competition reasons and for substituting more carbon intensive fuels, i.e. coal to gas switch. Renewable & decarbonised gases projects are needed to adapt and build gas grids for transport of hydrogen and biomethane. Energy Transition Related projects (ETR), already included in the TYNDP 2020 project collection, should be considered in the PCI selection as they address sustainability goal and support technologies such as Power to Gas; biomethane plants and reverse flows from DSO-TSO; hydrogen via steam methane reforming or pyrolysis, CCS/U; CO2 pipelines; repair gas grids against methane leakage; smart grid integration, and other projects. Market-driven projects play a significant role for market mergers and regional markets developments. Thus, TEN-E Regulation shall ensure that they enjoy the access to accelerated approval and permit granting procedures. A fast-track selection procedure should be allowed for projects already selected in the previous PCI process; having those projects only monitored and not fully re-assessed. Such solution would provide stability of the list and credibility of the process while guaranteeing costs savings for promoters and EC. 3. TEN-E Governance: Role of ENTSOG DSO-TSO coordination at national and European level should be considered, with a focus on data collection, on renewables generation and on demand technology deployment. ENTSOG together with ENTSO-E have applied transparent stakeholder processes and follow ACER’s recommendation to further investigate the interaction between gas and electricity projects and infrastructure with the Interlinked Model. ENTSOs are able to apply the collective knowledge and responsibilities of gas and electricity TSOs and conduct TYNDP together with EC, ACER & stakeholders. ENTSOG underlines the need for refurbishment and upgrading of the gas infrastructure and allowing such projects to be supported in TEN-E as necessary for a future proof system. The TEN-E should thus enhance the utilisation of existing gas infrastructure and recognise its capacity to transport new gases.
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Meeting with Kadri Simson (Commissioner) and

3 Apr 2020 · Impact of the COVID-19 crisis on the gas security of supply, lessons learned and way forward, developments on the gas market

Meeting with Kadri Simson (Commissioner) and

16 Jan 2020 · European Green Deal including possible contribution of gas, hydrogen; energy security

Response to European Partnership for Clean Hydrogen

27 Aug 2019

ENTSOG response to European Commission’s consultations on European Partnership for clean hydrogen-Horizon Europe Program Inception impact assessment – Ares (2019)4972390 The European Network of Transmission System Operators for Gas (ENTSOG) and its Members (TSOs) support the EC European Partnership Clean Hydrogen initiative and is ready to play its part in the development and deployment of ‘near-zero-carbon’ hydrogen in the European Union. In order to decarbonise the European energy system in the quickest and most cost-effective manner, the EU will have to make use of all available technologies and energy carriers. ENTSOG members therefore believe it will be necessary to develop a hybrid approach for the total energy mix (i.e. one based on an interlinked gas and electricity system) in order to meet decarbonisation targets: in practice, it will be essential to adopt a holistic system view and take into account decarbonisation options based on both electrons and molecules. The energy transition should also be technology-neutral in order to incentivise the most efficient, sustainable options in the long run, as well as the all-important initial steps to develop a clean hydrogen sector that will help to decarbonise the energy system. “Clean hydrogen technologies” should cover electrolysis and all close-to-zero-carbon technologies used to produce hydrogen (like: Pyrolysis, Steam Methane Reforming with CCS). We find that support to facilitate early deployment of technologies and related infrastructure is important. In this regard, we would highlight the role that natural gas transportation infrastructure (both transmission and distribution) can play in facilitating the development of the hydrogen sector. TSOs can also play a vital role in the development and application of hydrogen in sectors such as energy, transport and industry e.g. by contributing to the development of technical, regulatory and legal arrangements that could facilitate further development and implementation of hydrogen systems, including appropriate harmonisation of future admixture blends. ENTSOG and its Members are ready to collaborate with other stakeholders to achieve EU decarbonization goals, building on a European Hybrid Energy System (combining both electricity and gas infrastructures). ENTSOG will be interested in active participation in further EC work on the European Partnership Clean Hydrogen initiative. Please visit ENTSOG’s Innovative Projects Platform to see TSOs efforts to promote innovative technologies, regulation and business model, and partnerships across the value chain, including for hydrogen: https://www.entsog.eu/ipp *** The role of the European Network of Transmission System Operators for Gas (ENTSOG) is to facilitate and enhance cooperation between national gas transmission system operators (TSOs) across Europe, to ensure the development of a pan-European transmission system in line with European Union energy goals. ENTSOG’s tasks are mainly defined in Regulation (EC) No 715 / 2009. This includes developing network codes for market and system operation, elaborating the Ten-Year Network Development Plan (TYNDP), providing regular information on gas supply and demand for the European market and delivering common operational tools to ensure network security and reliability. ENTSOG work is continuing to evolve: from designing the secondary legislation and fulfillment of conferred regulatory tasks, monitoring the effects of the agreed outcomes through to responding to future challenges and building on achieved results. While its focus remains on monitoring Network Code implementation, ENTSOG future activities will also include assessing the progress of the functionality of the European gas markets and looking at longer term horizons for European Scenarios. For further information please contact: Jan Ingwersen - General Manager General-Manager@entsog.eu T +32 (0)2 894 51 02
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Response to European standards for alternative fuels infrastructure for L vehicles, shore-side electricity for inland navigation ves

12 Apr 2019

ENTSOG welcomes CEN work with regards to integrating renewable and low-carbon gases in gas quality standards. However, current technological developments have proven that CNG vehicles can already generally accept higher hydrogen concentrations than 2%. It is highly likely that in the short or medium term, the hydrogen requirement in EN16723-2 will become obsolete. By requiring fuel quality to comply with EN 16723-2 at refuelling points, a legal barrier to hydrogen injection in gas grids beyond 2% in volume will be established. This barrier may hinder the development of innovative mobility technologies (such as CNG vehicle tanks with a higher hydrogen tolerance) as well as the general use of hydrogen as a decarbonising fuel in the mobility sector. At the existing power-to-hydrogen installations, gas transmission system operators have respected the limitation established in EN 16723-2. Rather than limiting the ability of gas grids to integrate increasing shares of hydrogen in the near future by mandatory compliance to the referred standard, ENTSOG would find beneficial to have further clarity regarding current and future hydrogen readiness levels for the different gas end-use applications at EU level. In that respect, the 31st meeting of the Madrid Forum in October 2018 concluded that Changes to the gas quality range are expected due to the injection of growing volumes of biomethane, synthetic methane and hydrogen. Therefore, renewable and low-carbon gases should be included in the European standard for H-gas quality. The Forum invites CEN to continue its work in support of the use of renewables in gas infrastructure and gas applications and to report back to the next Madrid Forum. Therefore, ENTSOG is favourable to the proposed amendment on the directive « European standard for Alternative Fuels Infrastructure » as it will facilitate the development of CNG and LNG as a fuel through a harmonization of the gas quality requirements. However, we would like to draw your attention to the fact that the current version of the standard EN-16723-2 limits the amount of hydrogen in the CNG to a maximum value of 2%. While this limit may be acceptable for the moment, we consider that hydrogen-natural gas blends are likely to play a major role in the future in the way to a decarbonised economy, and as such, we would like to emphasize the need to review the 2% limits accordingly in future revisions of the standard EN-16723-2. In general, ENTSOG sees the need for a further consultation on the topic given the complexity.
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Meeting with Miguel Arias Cañete (Commissioner) and

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