France gaz
France gaz, créée en 1874, est le syndicat professionnel de l’industrie gazière française : gaz naturel, gaz renouvelables et bas carbone, gaz liquides et hydrogène.
ID: 656322315335-91
Lobbying Activity
Response to Revision of the EU’s energy security framework
13 Oct 2025
Questions about the EUs energy security architecture must be tackled with a global vision of the energy system, taking into consideration the important interconnections between various energy sources, as well as the existing dynamics, including the delicate balance between energy prices and supply security. Thus, security planning in the future framework should be based on coordinated assessments that jointly address electricity and gas systems. Focusing more specifically on gas-related regulations, France gaz believes that the current balancing responsibility framework in the European Union, along with existing last resort balancing mechanisms, is largely sufficient to meet system needs. During the energy crisis, both gas suppliers and infrastructure operators (including LNG terminals, storage facilities, TSOs, and DSOs) proved their resilience by maintaining uninterrupted supply to all consumers despite unprecedented conditions. This resilience was strengthened by the introduction of gas storage filling targets in 2022, which were appropriate at the time. However, current market conditions have evolved and maintaining rigid definitions for both intermediate and final targets no longer makes sense, as illustrated by the negative summer-winter spread observed for 2025. Consequently, France gaz welcomes the added flexibility to the current storage obligation which should allow for a more efficient functioning of the market and an optimal filling of gas reserves throughout the year. Going forward, any decision to extend gas storage filling requirements should be based on a thorough impact assessment. Unnecessarily prolonging these measures risks driving up costs for end consumers without delivering meaningful benefits to the energy system. Other emergency mechanisms adopted in the context of the 2022 energy crisis have proven to be redundant and counterproductive. This was the case of the Market Correction Mechanism (MCM) for gas, which aimed at protecting EU citizens and the economy from excessively high energy prices. The mechanism, which expired on January 31, 2025, had never been activated, highlighting the absence of need for further non-market-based mechanisms to ensure security of supply. Furthermore, it is important to remember that the preexisting framework already contained effective last-resort measures. This is the case of the solidarity mechanism which aims at preserving natural gas security of supply through regional cooperation between Member States. Introduced through regulation 2017/1938, it implies that a Member State directly connected to a Member State that is in a situation of emergency must reduce or interrupt the supply of non-protected customers in order to guarantee the supply of gas to the protected customers of the latter. This system is deemed sufficient and France gaz does not think it is worth enhancing it further. Nevertheless, France gaz believes that alternative gas supply sources have not been given enough thought considering the role they can play in strengthening the EUs security of supply. In that sense, France gaz emphasizes the need for the development of renewable and low-carbon technologies, such as biomethane and hydrogen, as a way to secure its energy supply and make it more independent from non-EU sources. Altogether, France gaz estimates that current emergency measures are enough to guarantee energy security in Europe, while maintaining acceptable prices for consumers. If any measure were to be introduced, it would have to happen after a thorough assessment of its potential impact on the functioning of gas markets.
Read full response17 Jun 2022
AFG welcomes the recent draft delegated act from the European Commission (EC) “establishing a minimum threshold for greenhouse gas emissions savings of recycled carbon fuels and by specifying a methodology for assessing greenhouse gas emissions savings from renewable liquid and gaseous transport fuels of non-biological origin (RFNBO) and from recycled carbon fuels (RCF)”. AFG considers this act as critical to enable the deployment of RFNBO - including hydrogen - as it is likely to have significant implications for the Renewable Energy Directive and the Hydrogen and Gas Package.
AFG underlines the need to develop:
• a robust methodology, ensuring a credible reporting of the GHG footprint of RFNBO and RCF;
• a future-proof act, assuming it may be extended to all RFNBO/RCF end-uses through the upcoming RED III and may also be used as a blueprint for low carbon gases in the upcoming Gas Directive.
Through this paper, AFG would like to put forward four main recommendations to achieve these objectives:
1. Remove the 2036 limit on all industrial CO2 source
2. Clarify the situation for municipal waste treatment plants
3. Define appropriate rules for the calculation of GHG intensity of mixed installations
4. Account for closed carbon loops
Read full responseResponse to Proposal for a legislative act on methane leakage in the energy sector
15 Apr 2022
AFG welcomes the publication of the proposal of the European Commission on Methane Emissions reduction in the energy sector. Considering that safety and reducing emissions is in our members DNA and also that French regulation already imposes a high level of requirement for safety reasons, AFG members are committed to pursuing and intensifying their contribution to reduce emissions. However, we believe that some provisions require adjustments, to better consider technical aspects and cost efficiency.
As a general remark and regarding principle of proportionality, costs resulting from the implementation of the measures should be better balanced with expected benefits. To make costs and investments efficient, gas companies, in close dialogue with competent authorities, should define a methane emissions mitigation plan, which will allow prioritisation of the most cost-effective mitigation measures.
Considering that the gas value chain covers at least 5 types of operators with huge differences between their technical activities, from operating limited number of very large sites to huge population of small installations, AFG would like to underline that only one solution can’t fit all industries along the value chain.
For our members, efficient methane emissions reduction plans should be based on a detailed methane emissions reporting in order to prioritize activities on emissions resulting from material sources. Thus, AFG supports the implementation of a transparent and robust MRV aligned with the ambitious standard OGMP 2.0. Reporting of methane emissions should therefore be based not only on measurement, that is not always feasible nor the most accurate option, but also on other methodologies such as engineering calculation. We also consider the time schedule to implement the regulation as too ambitious.
Regarding site-level measurement, we would like to emphasize that top-down methodologies are still under development and are considered not mature. As a consequence, provisions on top-down/site-level measurements in the Regulation should be performed on a voluntary basis and for the bigger sites only. We recommend that the EC launches a mandate to CEN to standardise the diverse quantification processes.
Concerning the LDAR campains, efforts should be proportional to emission mitigation potential which differs widely from one asset to the other. Existing practices account from the different specificities along the value chain, from the knowledge of the operators concerning their specific assets on the high level of safety requirements existing at national level and already existing environmental related measures.
The European Regulation should ensure that the different practices that are already successfully implemented by the operators are accounted for.
Timing for leak repair should consider the technical or administrative feasibility, safety and environmental benefits.
Therefore, to optimize costs and resources needed, we recommend not to set strictly defined intervals for LDAR survey but to make them defined in the LDAR programme submitted to the competent authorities. It guarantees reliable performance by identifying the main emissions to prioritize the action.
We recommend to develop a CEN standard on LDAR methodologies, including scope of the survey depending on operators, programme and repair or replace criteria.
We fully support the prioritization of recovery and re-injection of gas with respect to venting and flaring. However, It is important to ensure a lead time for implementing the venting & flaring provisions and to specify an exemption threshold for minor vented volumes.
The venting and flaring reporting should be the subject of annual reports, and double reporting should be avoided.
In addition, as a member of Marcogaz and Eurogas, AFG supports the attached position expressed by the 5 associations : ENTSOG, Eurogas, GERG, GIE, MARCOGAZ.
Read full responseResponse to Proposal for a legislative act on methane leakage in the energy sector
25 Jan 2021
AFG 25.01.2021
In France, the gas industry plays its part in decreasing methane emissions through reducing its own emissions and in pushing the development of renewables such as biomethane, as it also can help waste and agricultural sector to decrease their emissions.
Several French gas infrastructure operators have already set targets to cut down their own methane emissions by 2020 and by 2025 aiming an overall 45 % reduction in methane emissions form infrastructures between 2016 and 2025. As a first result, since 2016, methane emissions of the main gas infrastructures have been reduced by 15%, from 46.5 kt of méthane in 2016 to 39.3 kt in 2019 (source five infrastructures operators representing more than 95 % of infrastructures).
AFG could support:
1. Measuring, Reporting and Verification (MRV) to improve the existing methane dataset, based on a harmonized methodology to quantify methane emission for each part of the value chain.
A single methane emissions reporting framework would be useful, a majority of AFG mid-stream and downstream members have joined the OGMP 2.0 (Oil and Gas Methane Partnership) . The reporting templates are defined and main gas compagnies are working on the development of technical guides. Some smaller compagnies have not yet joined OGMP and should need time and help to learn the methodology.
2. LDAR campaigns should consider the characteristics of the different gas infrastructures. Mid and downstream companies have different levels of maturity across Europe on the subject (a time of adaptation and learning the methodologies could be helpful) and focusing the efforts on the actions with the lowest abatement costs and available mitigation techniques. Better and more widespread methane leakage detection and repair will reduce methane emissions for environmental reasons.
3. Mitigation of routine venting and flaring mitigation should be looked for, depending on operational conditions, safety and security of supply should be taken in account. A definition of “routine” shared by the industry is needed and must be evaluated in terms of actions, existing solutions, and compatibility with other regulations.
- Shared recommendations for National Regulatory Authorities to allow costs-efficient mitigation measures to be implemented by regulated companies (through cost recovery, incentives, and promotion of innovation).
- Using the European innovation support funds for mitigation programs and development of new technologies
- This European methane strategy should be part of a wider climate strategy, notably pushing the development of renewable gases (biomethane and synthetic methane).
Read full responseMeeting with Telmo Baltazar (Cabinet of President Jean-Claude Juncker)
29 Jan 2015 · Energy Union
Meeting with Dominique Ristori (Director-General Energy)
27 Jan 2015 · European Energy Policy priorities