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Gas Distributors for Sustainability

GD4S

Gas Distributors for Sustainability is an association representing leading gas distribution system operators in Europe.

Lobbying Activity

Meeting with Willem Van Ierland (Head of Unit Climate Action)

20 Jan 2026 · The decarbonisation of the gas grid

Gas Distributors Push for Green Gases as Circular Feedstocks

6 Nov 2025
Topic — EU Circular Economy Act aims to boost recycled materials and circular business models.
Message — The organization requests formal recognition of green gases and their co-products as circular feedstocks and secondary raw materials. They advocate for binding targets, support mechanisms, and incorporation mandates like biomethane blending obligations to scale up renewable gas production.123
Why — This would create market access and revenue streams for their members' renewable gas infrastructure.45
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Meeting with Paulo Cunha (Member of the European Parliament) and Floene, S.A. and Confederação dos Agricultores de Portugal

4 Nov 2025 · Unlocking Biomethane: A Successful Partnership Between Farmers and Energy Players - event co-hosted by me

Gas Distributors Seek Renewable Gas Priority in EU Security Framework

13 Oct 2025
Topic — Revised EU energy security framework for decarbonised, integrated energy systems
Message — The organization requests support for local biomethane production and storage infrastructure to reduce import dependence. They advocate for cross-sector integration allowing flexible use of renewable gases alongside electricity. They recommend strengthening solidarity measures and extending protected customer definitions to essential services.123
Why — This would maximize the value of their existing 929,500 km network infrastructure.45
Impact — The proposal does not identify specific groups that would be harmed.
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Gas Distributors Urge Life-Cycle Assessment in EU Vehicle CO2 Standards

9 Oct 2025
Topic — Revision of EU CO2 emission performance standards for new cars and vans.
Message — The organization requests full life-cycle assessment of all energy sources and vehicle types in CO2 standards. They argue current tailpipe-only methodology favors battery electric vehicles and overlooks bio-CNG performance. Policy should integrate carbon correction factors or full footprint analysis while ensuring technology neutrality.123
Why — This would legitimize their bio-CNG technology and protect their gas distribution infrastructure investments.456
Impact — The electric vehicle industry loses its regulatory advantage from current tailpipe-only standards.7
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Gas Distributors urge hybrid approach combining electricity with renewable gases

8 Oct 2025
Topic — EU plan to increase electrification and reduce fossil fuel dependency across sectors.
Message — The organization requests technology neutrality allowing hybrid heating solutions combining renewable electricity and gases. They want renewable gases fully integrated into EU frameworks including blending obligations and binding biomethane targets. They call for integrated planning of electricity, gas and heat infrastructures.123
Why — This would preserve their members' gas distribution networks and customer base during energy transition.45
Impact — Climate goals lose momentum as continued gas infrastructure delays full electrification and decarbonization.67
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Meeting with Margareta Djordjevic (Head of Unit Energy)

6 Oct 2025 · The role of gas and hybrid systems in the heating and cooling strategy.

GD4S urges technological neutrality for EU 2040 climate target

12 Sept 2025
Topic — The consultation involves amending the European Climate Law to establish a 2040 target.
Message — The group demands technological neutrality to ensure both electrons and molecules are supported. They advocate for integrating renewable gases and preventing the premature dismantling of networks.123
Why — This strategy protects the value of current gas infrastructure and reduces investment risks.45
Impact — Advocates for an electricity-only transition lose market exclusivity as gas infrastructure remains supported.6
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Gas Distributors urge hybrid heating systems for affordable energy transition

11 Sept 2025
Topic — EU consultation on protecting consumers and enabling participation in energy transition.
Message — The organization requests policy support for hybrid heating solutions that combine electricity and renewable gas. They argue this approach makes the transition faster and more affordable by using electric heat pumps when renewable electricity is available and switching to renewable gas during cold weather or when grids are congested.123
Why — This would preserve demand for their gas distribution infrastructure and renewable gas products.45
Impact — Full electrification advocates lose momentum as hybrid systems preserve fossil fuel infrastructure.67
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Meeting with Kamil Talbi (Cabinet of Commissioner Dan Jørgensen), Philippe Moseley (Cabinet of Commissioner Dan Jørgensen)

9 Sept 2025 · The EU’s building decarbonisation objectives

Gas Distributors Urge Recognition of BioCNG for Corporate Fleets

8 Sept 2025
Topic — EU directive setting minimum zero-emission vehicle requirements for corporate fleets.
Message — The organization requests technological neutrality recognizing BioCNG, hydrogen, and electrification as complementary options. They want life-cycle emissions accounting instead of tailpipe-only criteria and specific provisions exempting emergency fleets from mandatory electrification.123
Why — This would protect their members' existing BioCNG fleet investments and preserve operational flexibility for emergency vehicles.456
Impact — Climate goals lose faster emissions reductions by allowing continued fossil fuel infrastructure use.7
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Gas Distributors Urge EU to Include Biomethane in Transport Decarbonisation Plans

4 Sept 2025
Topic — EU strategic framework for renewable and low-carbon fuel investments in transport decarbonisation.
Message — The organization requests technology neutrality and recognition of BioCNG and hydrogen alongside electrification. They call for life-cycle emissions accounting instead of tailpipe-only standards, and support for biomethane through market instruments like Guarantees of Origin. They want investment in repurposing gas infrastructure for hydrogen distribution.1234
Why — This would allow gas distributors to repurpose existing networks and maintain relevance in transport decarbonisation.567
Impact — Electric vehicle manufacturers face increased competition from gas-powered alternatives in heavy-duty transport segments.
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Gas distributors demand role for renewable molecules in energy grid

5 Aug 2025
Topic — A legislative initiative to modernize and expand Europe's energy infrastructure and interconnected networks.
Message — GD4S urges the EU to recognize renewable gases as equivalent to electrification and set binding targets for their expansion. They call for faster permitting for distribution networks to accelerate the integration of biomethane and hydrogen.123
Why — Utilizing existing gas infrastructure allows distributors to avoid asset stranding and maintain their market position.4
Impact — Unregulated district heating providers would face new European rules to eliminate their current competitive advantage.5
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Gas Distributors Urge Assessment of Low-Temperature Emitters with Gas Systems

29 Jul 2025
Topic — EU regulation on energy labelling for low-temperature heat emitters like radiators.
Message — The organization requests the Commission explore benefits of low-temperature emitters with condensing boilers and assess their role in broader renovation strategies including hybrid heating systems. They propose comparing cost-benefits across multiple decarbonisation scenarios involving heat pumps, hybrid systems, thermally driven heat pumps, and condensing boilers with varying renovation approaches.12
Why — This would maintain the viability of gas infrastructure for renewable gases and avoid costly mandatory radiator replacements.34
Impact — Buildings relying solely on electric heat pumps may face higher costs without gas alternatives being considered viable.56
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Meeting with Bruno Tobback (Member of the European Parliament)

14 Jul 2025 · Supporting the EU’s net-zero ambition by enabling the large-scale deployment of renewable gases

Gas distributors urge technology neutrality in EU decarbonisation plan

8 Jul 2025
Topic — The EU is consulting on streamlining permitting and stimulating investment for industrial decarbonisation.
Message — The group requests a technology-neutral approach including gas infrastructure. They want faster permitting for biomethane and hydrogen projects. Existing networks must be recognized as strategic assets.12
Why — This would prevent their assets from becoming obsolete while lowering project costs.34
Impact — Consumers might face price inflation if procurement ignores the lowest cost options.5
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Gas Distributors Urge EU to Prioritize Biomethane in Bioeconomy

23 Jun 2025
Topic — This consultation seeks solutions for a circular, regenerative, and competitive bioeconomy.
Message — The group calls for the Bioeconomy Strategy to fully recognize biomethane's value. They advocate for consistent rules across energy and agricultural policies. Targeted incentives are requested to help biomethane compete with fossil fuels.123
Why — Targeted incentives and policy alignment would increase investments in renewable gas distribution.4
Impact — Producers of fossil-based fuels would lose market share to competitive renewable alternatives.5
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Response to European Affordable Housing Plan

4 Jun 2025

Gas Distributors for Sustainability (GD4S) represents leading gas distribution system operators from nine EU Member States France, Greece, Ireland, Italy, Netherlands, Poland, Portugal, Romania, Spain and the United Kingdom. GD4S is committed to the European Union net-zero target and is contributing to the decarbonisation of the residential heating sector across the EU by enabling the collection and distribution of renewable gases. Together, GD4S members operates 867,000 km of gas distribution networks and serves more than 54 million customers across Europe, enabling the reliable collection and delivery of sustainable energy at the local level. GD4S welcomes the European Commissions initiative on the European Affordable Housing Plan (EAHP). As a DSO association committed to decarbonisation, GD4S supports the Plans ambition to tackle the housing crisis in a way that is both socially inclusive and aligned with Europes climate, sovereignty and resilience goals. Renewable gases have a role to play to enable a fast, resilient and cost-effective energy transition in general, and in building decarbonisation in particular. Renewable gases, such as biomethane, are rightly fully recognised in the Energy Performance of Building Directive as a building decarbonisation solution. Their inclusion in the panel of building heating decarbonisation solutions brings in several key advantages: - They ensure that no-one is left behind without a reliable and affordable heating solution. Even where electric solutions are not technically or economically feasible, combining building insulation and green gases is always possible. - Combined with electric solutions such as hybrid heat pump or smart co-generation, they provide very efficient demand-side flexibility to not only maximise the use of affordable renewable electricity but to also cost-efficiently manage grid congestion. Buildings equipped with hybrid solutions can manage a cold snap occurring during a Dunkelflaute without major investment in the energy system and they can easily adapt their electricity consumption according to the fossil content of the electricity generation to cost effectively minimise the total fossil CO2 emission. Use of renewable gas must be assessed in terms of the broader benefits it brings to the building and the decarbonisation of the entire energy system Biomethane, a reliable, dispatchable, locally produced energy, enables rapid decarbonisation of heat without demanding disruptive, time-consuming or costly changes for end users and infrastructures. A smart use of renewable gas in buildings, can reduce the transition costs at both the buildings and energy system level, thus enabling lower energy costs for all. Use of renewable gases in the building level will prevent sharp increases of electricity during Dunkelflaute and reduce the costs of electricity infrastructure. This will particularly benefit vulnerable or low-income households. As the European Commission develops the Affordable Housing Plan, GD4S is asking for a technology-neutral approach that reflects the diversity of Europes building stock, climate conditions and social needs, along with an energy system consideration, to enable homeowners to find the best-suited decarbonisation pathway adapted to their building and to enable optimisation of the local energy system. In conclusion, GD4S stands ready to contribute to the development and implementation of the European Affordable Housing Plan. GD4S is convinced that inclusive decarbonisation, enabled by smart use of existing infrastructure and renewable energy, clean molecules like biomethane, clean electricity and heat, can ensure that no one is left behind in the transitions of both housing and energy.
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Meeting with Yannis Maniatis (Member of the European Parliament)

21 May 2025 · competitiveness and decarbonization of the EU industry

Meeting with Lukasz Kolinski (Director Energy)

13 May 2025 · Dialogue on heating decarbonisation and grid development

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

5 May 2025

Gas Distributors for Sustainability (GD4S) welcomes the European Commission consultation on the common transfer from the national Energy Databases to the EU building Stock observatory, in application of the Energy Performance of Building Directive. The Energy Performance of Buildings Directive (EPBD) sets an ambitious target for a zero-emission building stock by 2050. It supports the inclusion of all renewable energy sources, including biomethane and hydrogen. To ensure the EU Building Stock Observatory aligns with the EPBD and ensure effective monitoring, the collected data should reflect the full diversity of technologies and of the energy sources contributing to building decarbonisation. Therefore, we recommend that renewable gas-based solutions, alone or hybridised, to be taken into consideration while gathering data for the EU Building Stock Observatory. These solutions provide homeowners a wide range of options to find the one that fits them best. When technically and economically feasible, adding a small heat-pump to an existing boiler or replacing it by a hybrid heat-pump able to react to external signals enable a very cost-effective fossil CO2 emission reduction while maintaining the house comfort and system resilience. Currently, the draft version list only natural gas, without differentiation. We propose adding explicit fields for biomethane and hydrogen, as these are increasingly present in Member State gas networks and national policy frameworks. Fields for renewable gases should also be introduced in all relevant templates, especially HVAC inspections. In addition, we ask also for the inclusion of the renewable gases on the on-site renewable solutions category. Regarding the hybrid heating systems defined only as systems using both renewable energy (heat pumps included) and fossil fuels, we recommend defining hybrids as systems using both electricity and gaseous fuels from renewable sources and ensure that they are reflected in Energy Performance Certificates, renovation passport, and Smart Readiness Indicator templates. Furthermore, Annex II calculations should reflect both energy vectors and origin, by distinguishing between electricity, gas, heat, and between renewable and fossil shares where data is available. This will allow accurate GHG and efficiency monitoring aligned with decarbonisation goals.
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Meeting with Jana Nagyová (Member of the European Parliament)

26 Mar 2025 · Renewable Gas & Industrial Decarbonisation

Meeting with Jutta Paulus (Member of the European Parliament, Shadow rapporteur) and EPIA SolarPower Europe and

7 Mar 2025 · Security of Energy Supply

Meeting with Radan Kanev (Member of the European Parliament) and European Biogas Association

21 Jan 2025 · European Energy Forum dinner- Technology neutrality for an efficient energy system integration

Meeting with Grégory Allione (Member of the European Parliament)

15 Jan 2025 · Réunion GD4S/GRDF

Meeting with Radan Kanev (Member of the European Parliament)

5 Dec 2024 · Role of gas distributors in EU carbon neutrality

Meeting with Andreas Glück (Member of the European Parliament)

29 Oct 2024 · Climate and Energy Policy

Meeting with Nina Carberry (Member of the European Parliament)

15 Oct 2024 · EU Energy Policy

Meeting with Caroline Nagtegaal (Member of the European Parliament) and International Road Transport Union Permanent Delegation to the EU and

16 Apr 2024 · Biomethane in road transport

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

13 Sept 2023 · Exchange on the Methane Regulation (staff level)

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

28 Jun 2023 · Renewable gasses

GD4S warns EU against relying solely on heat pumps

26 May 2023
Topic — EU initiative to accelerate the deployment of heat pumps across Europe.
Message — GD4S urges the Commission to include hybrid systems and renewable gas boilers. They argue against a total phase-out of gas boilers by 2029.12
Why — This preserves the relevance and long-term value of gas distribution infrastructure.34
Impact — Environmental groups lose because the 2029 phase-out of gas boilers would be delayed.5
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Gas Distributors Urge EU to Recognize Biomethane in Heavy-Duty Vehicle Standards

17 May 2023
Topic — EU regulation setting CO₂ emission standards for new heavy-duty vehicles toward zero-emission mobility.
Message — The organization requests moving beyond tailpipe-only emissions measurement and introducing a carbon correction factor for renewable fuels like biomethane. They argue the current approach ignores the climate benefits of renewable gases and creates dependence on imported materials while biomethane supports local circular economies.123
Why — This would maintain their market position by recognizing biomethane as equivalent to electric vehicles for emissions.45
Impact — Electric vehicle manufacturers lose regulatory advantage as biomethane vehicles would receive emissions credits.6
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Response to European Critical Raw Materials Act

25 Nov 2022

Gas Distributors For Sustainabilty (GD4S) welcomes the EC initiative on critical raw material. Availability and affordability of natural resources will drive sustainable economic models and energy transition. Decision-makers need information and data to manage uncertainty and adverse conditions. Most of the energy transition visions foresee the replacement of fossil fuels with renewable sources through technologies that are highly demanding in metals (copper, lithium, cobalt, aluminium) and rare earth materials. These elements are necessary for electrification through generation technologies (solar and wind), infrastructure (networks, stations, storage) and users appliances (EV, HPs). According to the International Energy Agency, reaching net zero emission in 2050 would require 6 times more raw material by 2040. For lithium and cobalt, demand will multiply by 40 and 20 respectively. Critical sectors are electric batteries and EV (IEA, The role of critical minerals in clean energy transitions, 2021). For IFPEN, copper will be the most constrained metal with 90% of today's known resources that will be mined by 2050 (project ANR GENERATE). In parallel with the reduction of the volumes of fossil fuels used, current decarbonisation pathways are creating a fast-increasing need for extremely large amounts of metals and electronic components, which the European Union will have to massively import. Overreliance on critical raw materials therefore creates new risks for security of supply: out of the 30 critical raw materials already identified by the EC to be crucial for the energy transition, 19 are predominantly imported from China. Such consideration should be better reflected in the design of decarbonization and energy transition policies. Given the strong constraints on resources supply with the growing electrification, more attention should be paid to renewable solutions that are much less resources intensive. Biomethane production is one of them. The Institut National de lEconomie Circulaire and CapGemini (2022) studied the feasibility of the French low carbon strategy according to the induced materials consumption, revealing that a scenario relying on renewable gases and circular economies would divide by 4 the pressure on critical resources. Contrary to renewable electricity, biomethane value chain requires close to zero critical metals and minerals. This is especially true regarding the mobility sector, where cars running on biomethane are the best performers in terms critical materials intensity, while electric cars are far behind. To face climate emergency, systemic changes of demand, consumers habits, supply chains and international trade are needed. The Critical Raw Materials Act should have as a key parameter the availability and supply natural resources, fully integrated into energy planification and modelling exercises.
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Meeting with Daniel Mes (Cabinet of Executive Vice-President Frans Timmermans) and European Biogas Association

19 Sept 2022 · CO2 standards for trucks

Meeting with Filip Alexandru Negreanu Arboreanu (Cabinet of Commissioner Adina Vălean)

14 Sept 2022 · transport

Meeting with Filip Alexandru Negreanu Arboreanu (Cabinet of Commissioner Adina Vălean) and European Biogas Association and

6 Sept 2022 · CO2 Standards for heavy duty vehicles

Meeting with Jerzy Buzek (Member of the European Parliament, Rapporteur) and Climate Action Network Europe and

19 May 2022 · Meeting on gas and hydrogen regulation

Meeting with Kadri Simson (Commissioner) and

19 May 2022 · GD4S Sustainability Charter 'Decarbonising the gas grid as a key enabler for a climate neutral society'.

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

19 Apr 2022 · sustainable gas/carbon neutrality

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

19 Apr 2022 · Exchange on the gas market directive

GD4S urges risk-based approach to EU methane emission rules

15 Apr 2022
Topic — New EU legislation targeting methane emission monitoring and reduction in energy sectors.
Message — The association calls for a risk-based approach to leak detection rather than fixed inspections. They also recommend cumulative reporting for routine maintenance tasks to reduce administrative complexity.12
Why — Avoiding high-frequency inspections and individual reports would lower costs for gas distribution operators.34
Impact — Energy consumers would bear the financial burden of increased tariffs due to compliance costs.5
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Response to Revision of EU rules on Gas

12 Apr 2022

Gas Distributors for Sustainability (GD4S) welcomes the timely publication of the ECs draft legislative proposal on Gas networks - revision of EU rules on market access (Regulation), in light of the recent EC REPowerEU Communication. This proposal will act as a key enabler to GD4S’ vision and we welcome the clarity provided. There are however some areas where GD4S are of the view that reconsideration may be necessary, and we welcome the opportunity to present these below: GD4S welcomes the increased role that DSOs will play in system planning and the establishment of a DSO entity. However, gas and electricity distribution are two fundamentally different businesses with a very large number of active parties in both areas. The proposed expansion of the existing electricity DSO entity to cover both gas and electricity risks diminishing focus on gas related distribution activities and poses challenges, both technical and of governance. GD4S recommends that a DSO entity for gas be established, separate from the DSO entity for electricity. GD4S supports the EC proposal to allow financial transfers between gas and hydrogen regulated services to take place, subject to regulatory approval within the member state. Repurposing of gas pipelines to hydrogen is a fast, low cost and efficient way to achieve a mature hydrogen market in Europe. This flexibility can help to benefit consumers of both gas and hydrogen, through enabling the repurposing of infrastructure between the two. However, care must be taken to ensure end users whose tariffs are affected can also reap the benefits of any cost mutualisation at a later date, i.e. if gas distribution customers are impacted then these gas distribution networks should be enabled to repurpose their infrastructure to hydrogen in the long term also. These considerations are best decided at a Member State level and more discretion on how to apply these principles could be given to NRAs to account for this. In relation to the Commissions proposals on tariff discounts, GD4S does not believe these will achieve the desired effect of enabling the large-scale roll-out of renewable and low carbon gases and other mechanisms should be considered. The proposal to introduce tariff discounts at Interconnection Points will result in an overly complex mechanism of rebate and cost allocations between the TSOs. The promotion and use of Guarantees of Origin (GOs) along with a Proof of Sustainability as the mechanism for enabling the trade of renewable gases across borders is an alternative solution which already exists today without the drawbacks. On Entry tariff discounts, the inclusion of distribution connected biomethane into the entry / exit zones may in some cases drive undue administrative burdens and complex arrangements, not to the benefit of the producer. Whilst firm technical capacity on connection and the ability to trade gases on the wholesale market should be ensured, the exact mechanisms for achieving this could differ between member states. Other regulatory incentives should also be considered such as discounts on the connection costs for renewable gas facilities and the introduction of legally binding targets for the roll out of renewable and low carbon gases. This response should be read in tandem with GD4S’ response on the Gas networks - revision of EU rules on market access (Directive) which details our positions on other aspects such as targets, regulatory principles for the hydrogen market, as well as vertical and horizontal unbundling. GD4S remains at the disposal of the Commission for any clarifications and looks forward to the next steps of this consultation.
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Response to Revision of EU rules on Gas

12 Apr 2022

Gas Distributors for Sustainability (GD4S) welcomes the timely publication of the ECs draft legislative proposal on Gas networks - revision of EU rules on market access (Directive), in light of the recent EC REPowerEU Communication. This proposal will act as a key enabler to GD4S’ vision and we welcome the clarity provided on regulatory principles for the hydrogen market, rules on providing access for renewable gases, the flexibility given to member states (MS) on blending at a national level, the focus on TSO/DSO cooperation and dispositions related to smart metering. There are however some areas where GD4S are of the view that reconsideration may be necessary and we welcome the opportunity to present these below: The recent communication on REPowerEU proposed a target of 35 bcm of biomethane by 2030. This target should be made legally binding through inclusion within the internal gas market legislation and/or in other appropriate legislation such as the Renewable Energy Directive. The proposed definition of hydrogen network operator and the associated TSO focused unbundling regime creates large uncertainty about the role envisioned for DSOs in the future hydrogen market. DSOs can play a key enabling role in the future hydrogen market, with up to 99% of industrial and commercial customers connected at distribution level today in some countries and the majority of network assets ready for repurposing. The regulatory framework should be future proofed by allowing for a distinct regulatory framework for hydrogen networks at distribution level. This distinct regulatory framework should be based on the mirroring of existing unbundling rules for DSOs today. We believe gas DSOs can play an important enabling roll in kickstarting the deployment of renewable hydrogen. As the REPowerEU highlights, regulatory sandboxes should be encouraged to enable the testing of innovative technologies, products or services that aim to advance the coexistence of renewable deployment and environmental protection. Network operators are well positioned to step in under such scenarios, at least as part of these regulatory sandboxes, subject to clear boundaries defined by regulatory authorities. The separation of accounts and regulatory asset bases for gas and hydrogen networks will ensure transparency and sufficient separation between hydrogen and natural gas businesses. The additional requirement for legal separation between the two is unnecessary and will create additional costs and administrative burdens for DSOs and consumers. Therefore, we advocate for the removal of Art. 63 of the directive. GD4S welcomes the setting out of regulatory principles for hydrogen from the start, However, different MS markets will mature over different timeframes and therefore time-based exemptions from these may not be the most appropriate mechanism. A market maturity-based metric might be a more appropriate way to implement these, ensuring market development in the early stages is not hindered through over regulation. A good example of this is in the current gas directive where DSOs can seek an exemption from certain rules (e.g. unbundling) if they are below 100,000 customers. This response should be read in tandem with GD4S’ response on the Gas networks - revision of EU rules on market access (Regulation) which details our positions on other aspects such as the DSO entity, cost mutualisation and regulatory incentives. GD4S remains at the disposal of the Commission for any clarifications and looks forward to the next steps of this consultation.
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Response to Energy labelling requirements for space and combination heaters (review/rescaling)

31 Mar 2022

Energy Labelling was designed at a time when electricity was mostly fossil based, to help consumers select the most efficient solution to meet their needs, with the lowest energy consumption costs for them. This approach was relevant for comparing similar products, using the same energy, such as two fridges, but far less relevant when comparing appliances offering different services, using different energy vector, like a micro-cogeneration and a heat pump. This is still the case. All dwellings cannot be equipped with all appliances, for technical or economic reasons. If heat pumps can’t be used, customers will have nearly all renewable gas boilers, the best alternative, all in on class, not much of a help. The heating demand profile is very different from the standard electric equipment ones. It is seasonal, and, extreme cold weeks, occurring a few times in a century, which are essential for public health reasons, are a main design criterion for the infrastructure (grid, storage, dispatchable peak production capacity) of the energy carrier used for it, and therefore, have a major impact on the grid part of the energy bills. The heat pumps’ efficiency is the highest when the weather is not too cold and for temperature of the heating loop water temperature is under 50°C. This efficiency decreases when outdoor temperatures drop and is at its lowest values during the coldest days, it can then require the action of a direct low efficiency joule back-up, increasing dramatically the electric peak demand. At such times, it is important to be able to relieve the electric network by “offloading” the heat pump. It must be noted that simply switching off the heat pump for an hour or two, using the building heating inertia, is not a solution, as these extreme cold episodes last for several days. This long peak duration also excludes vehicle to grid as a solution for heating peak demand: for example, a 4 kWe Heat pump with a 4kW back-up, operating 80% of the time, would require, for an average house, 460 kwh for only 3 days of extreme cold, equivalent to 9 fully charged Renault Zoé battery! Providing genuine flexibility to the electric network during extreme cold peaks, requires switching peak demand to another energy vector. Smart hybrid heat pumps allow it by using the renewable gas boiler back-up during very cold days, or at any moment it could be relevant, when the boiler is more efficient, euro-wise or CO2-wise, than the heat pump. For instance, it could be useful to switch to renewable gas boiler when there is a lack of renewable electricity (if no wind at night), and when meeting the heating demand with electricity would require turbining hydrogen (cumulating losses at electrolysis – around 30% - and losses of electric power plants – around 50%). The use of a smart hybrid heat pump or a smart cogeneration would therefore : - avoid oversizing the electric infrastructure (saving huge amounts of investment), by offering flexibility during extreme cold peaks, - get the highest system efficiency possible, considering the upstream electric generation, grid efficiency and the available renewable energy (gas and electric). Should only efficiency (and even worse, average efficiency) be recognised in the proposed labelling directive, this will hamper the further development of flexibility (demanded by the Energy Efficiency first principle), enabled by smart-grids and smart hybrid appliances and will increase negative externalities making energy more expensive for all. We therefore recommend that smart Heating solutions that improve the energy system efficiency (Energy First Principle), by offering real flexibility enabling the optimisation of renewable energy integration, reducing infrastructure’s costs, and increasing system resilience, such as smart hybrid heat pumps or smart cogeneration, should be given an upgrade in labelling, to bring the best of them to the B class at least and over their nonflexible counterparts.
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Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

31 Mar 2022

The building sector is one of the hardest to abate. Firstly, the large variety of technical, social, societal issues, and high financial impacts, make it a very sensitive topic for our citizens, and requires a building-to-building approach, with no silver bullet. Secondly, heating seasonal peak demand, which represent several times the electric system capacity, sets the design criteria for the infrastructure supplying the energy for heating, with the additional difficulty that, the more extreme the peaks are, the more important they are for public health reasons. Finally, Citizen financial capability is to be considered. This makes heating a hard to electrify sector. A full electrification would require very heavy investments, rarely used, in grids, storage, peak production capacity, with a high impact on energy bills. These huge costs can be avoided, to the benefits of all, by taking benefits of the existing millions of kilometres of gas distribution grids, able to transport large volumes of renewable gas at a fraction of the costs of electricity grids reinforcements otherwise required. We need to combine at best building insulation, renewable gas, electricity, and heating technologies, with enough flexibility to let every homeowner find the more feasible, affordable transition pathway for his dwelling. Reaping the low hanging fruits of ceiling insulation, replacement of obsolete boilers and thermostat fitting, can provide fast and large energy reduction, up to 30% each, for only few thousand euros. Gas boilers are future-proof as they are renewable ready, have access to renewable gas, are often the most cost-effective, fastest, and easiest solution to retrofit, especially where heat-pumps aren’t technically or economically feasible, (e.g. historic building or multi-family houses with limited space). In this respect, recent studies in the UK demonstrates that increasing the number of heat pumps does not necessarily decrease the overall cost borne by the consumers, as it may be expected with the development of a new technology. A large part of electric heat pump efficiency relies on upstream energy production and outside temperature. They are very efficient under mild winter conditions and when the generation mix is renewable. During a cold spell and/or when the generation mix is dependent on fossil-based generation, they aren’t much better than a boiler. In that regard, hybrid heat pumps would be better alternative, with a higher global efficiency as they are more affordable and would benefit from the use of the gas and power network infrastructure, consuming renewable gas at system stress situations or with high electricity prices, making them an efficient smart grids tool. Biomethane potential is large, and hydrogen potential is even larger. Considering the efficiency gains, only a fraction of this potential will be required to decarbonise the building sector, leaving plenty available for the other hard to abate sectors. We therefore consider that: 1. Building sector is a hard to abate sector, due to its huge complexity and that its full electrification is not feasible, 2. Modern gas technologies are part of the range of solutions, with renewable gas readiness and immediate energy savings and emissions reductions, 3. Overall cost efficiency and resilience of heating decarbonisation policies will benefit from the optimisation of existing energy distribution grids, 4. All renewable energies should be equally accountable to meet buildings energy needs, independently of the energy grid and/or market player delivering it, 5. The use of biomethane in heating should be incentivised to promote the local circular economy and transition acceptability, 1. 6. Electricity tariffs need to reflect their cost structure, including peak capacity, to incentive smart buildings development contributing to the energy system optimisation, by a proper sizing of electric equipment and by shifting demand between renewable gas and electricity.
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Meeting with Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans)

15 Mar 2022 · RePowerEU

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

17 Nov 2021

GD4S welcomes the EC decision to revise the EED, and its inclusion of the Energy Efficiency First Principle. A broader view of efficiency, such as Life Cycle Analysis (LCA) and system benefits, is required to ensure that carbon emission are not just displaced but avoided. - An LCA to assess the overall CO2 and cost-efficiency, including in manufacturing and recycling. - A system approach to ensure that efficiency gain at one point of the energy chain does not result in greater inefficiency in another. Demand flexibility can increase the energy production efficiency, but only non-time constrained flexibility can really allow to alleviate the several days design criteria required for heating. Reinforcing gas and electricity coupling, at both production and consumers level, will provide the easiest, fastest, safest, and most affordable pathway to achieve energy transition leaving no-one behind : 1. The potential of renewable gas is large and can ensure a sizable share of the decarbonisation. Decentralised biomethane potential is estimated at 1200 TWh (EBA). The Danish example shows that its development can happen fast if well supported. Renewable Hydrogen potential, produced from otherwise wasted renewable electricity, is even larger, at 1700 TWh (Gas for Climate) . These figures are to be compared to the 2400 TWh of present final energy use of natural gas (Eurostat). 2. Technologies using gas are immediately available, cost-effective, and versatile. Replacement of an old boiler by a high-performance condensing one can increase the building energy efficient by up to 30% for a few thousand euros, making it a highly CO2 efficient investment, even before considering the use of renewables gases, a first step to decarbonisation. Not all buildings can be retrofitted with Heat Pumps. 3. Gas technologies are easy to couple with electricity. Combining gas and electric solutions in a building; like a boiler and a heat pump, or cogeneration, create the non-time constrained demand flexibility required by the transition. Hybridisation is easier to achieve than full electrification. 4. Gas technology can be renewable ready at very low cost. Very little CO2 is involved in their manufacture and recycling, making them interesting for many heating solutions, especially when electrification via heat pumps is not feasible. 5. All these advantages can, and should, be combined. A smooth step by step decarbonisation could be completed by combining renovation steps and heating system upgrades, done according to consumer capacity. Gas and Hybrids are compatible with staged renovation and growing rates of renewable gas and electricity, making them easy cost-effective solutions for homeowners, provided the energy tariff reflects the real energy production and infrastructure costs. 6. Gas infrastructure is a very efficient and cost-effective asset to transport, store and distribute large volumes of energy and is already designed to cover winter peak demand. Its low cost makes it suitable to manage peak demand. Coupling of gas and electricity infrastructure, via power to gas and appliances, allows for an efficient, safe, and affordable energy transition for all, by reducing the transition uncertainties and later ensuring an affordable and resilient fossil free energy system. We therefore recommend: 1. Non time constrained demand flexibility is defined in EED. 2. demand-side capacity is considered in the EPBD, to develop “near 100% flexible buildings”. 3. CO2 emissions involved in equipment manufacture and recycling is displayed on appliance labels. 4. Public procurement should develop “near 100% non-time constrained flexible buildings”. 5. Local use of local renewable energy is promoted, to increase system resilience and public support; and 6. Consumers investing in demand flexibility capacity, should be incentivised to reward their contribution to energy system efficiency.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

10 Nov 2021

GD4S welcomes the ongoing revision of the Renewable Energy Directive (REDII). The publication of the Energy System Integration and Hydrogen strategies has underlined the importance of renewable gases in achieving carbon neutrality in a cost-efficient way. The revision of REDII is the legislative opportunity to stimulate their development. GD4S supports the overall level of ambition proposed for sectoral targets (transport, building, industry). However, targets should also focus on decarbonising the current energy vectors. A binding renewable gas target at the EU level as a percentage of the total gas consumption would ensure effective decarbonisation of the gas sector by supporting increasing production and grid injection. The market can find the optimum allocation of end uses once a technology agnostic market is established. Achieving GHG emission reduction targets must be done in a resilient way, by investing in the energy mix that will provide continuous and secure supply to meet all needs. Injecting renewable energy in the gas grid is an efficient and effective way to reach the renewable energy objectives of the Union with the least impact on consumers. Demonstrating the sustainability and origins of a product is essential to user acceptance. GD4S would point out that the scope of Guarantees of Origins (GO) under Article 19 could be extended to trace sustainability, in addition to origins of the fuel. Moreover, GO mechanism should be fully in line with EU ETS mechanism in terms of monitoring and reporting. This would help to create a more liquid market for renewable gases, based on the sustainability of the product. Whilst GD4S welcomes the intent of the European Commission (EC) for the Union Database, it is important to avoid excessive administrative burdens, resulting in a lower uptake by consumers or higher cost product. Existing GO systems are already in place, favoured by the market and could be modified to deliver the same outcome. It should be emphasized that heating and cooling (H&C) systems and equipment are not “renewable” or “fossil” by themselves. The energy used to supply them determines the renewable label of the product. As such, it is important to maximise the use of renewable energy within H&C systems, in addition to efficiency upgrades. To this end, provisions within REDII should better promote the supply of renewables in buildings as a means of meeting the proposed 49% target for the sector. Administrative requirements to certify and track the fuel use via GO should be promoted as an effective way to achieve this. The recent proposal of the EC on the delegated act for the Union Database and the certification schemes showed some clarifications should be written about the mass balance approach: as such, the interconnected European gas grid should be considered as a unique system, and the last consignment of the mass balance calculation should be at the injection point for all renewable gaseous fuels injected into the gas grid. Under Article 27, the use of additionality criteria for RFNBOs could limit the amount of fuel produced from grid connected electrolysers. This is not consistent with sector coupling and GD4S would urge the EC to take a pragmatic approach in this area, unlocking investment and supporting EU ambition. The revision of REDII is also the opportunity to maximise the potential of sustainably produced biomethane and to recognise its environmental benefits. Annex IX, listing feedstocks that can be used for biogas production, should be revised to broaden the scope of feedstocks able to be used. For example, all biowastes according to the definition in the Waste Directive (2018/851) shall be included. A category for intermediary crops (or cover/catch crops) should be included as they provide numerous environmental benefits. GD4S remains at the disposal of the EC’s services for any clarifications, looking forward the next steps of the consultation process.
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Meeting with Markus Pieper (Member of the European Parliament, Rapporteur) and Climate Action Network Europe and

9 Nov 2021 · RED III

Gas Distributors Push Technology-Neutral Approach for Clean Transport Fuels

8 Nov 2021
Topic — EU regulation on alternative fuels infrastructure to support zero-emission mobility goals.
Message — The organization requests technology-neutral policies including biomethane and bio-CNG alongside electricity. They advocate for life-cycle assessment instead of tailpipe analysis and support for CNG infrastructure beyond 2025.123
Why — This would secure continued investment in their members' gas distribution networks and infrastructure.45
Impact — Electric vehicle advocates lose policy focus as funding spreads across multiple fuel types.6
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Gas Distributors urge EU to recognize biomethane vehicles in emissions standards

8 Nov 2021
Topic — Strengthening CO2 emission performance standards for new cars and vans.
Message — The organization requests a switch from tank-to-wheel to well-to-wheel emissions measurement and recognition of biomethane's emissions reductions. They want derogations for efficient natural gas vehicles that can achieve negative emissions through biomethane use.123
Why — This would protect their members' investments in natural gas vehicle infrastructure and biomethane production.45
Impact — Electric vehicle manufacturers lose competitive advantage from zero-emission standards focusing on tailpipe emissions.67
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Meeting with Kadri Simson (Commissioner) and

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

Meeting with Kadri Simson (Commissioner) and

12 Oct 2021 · Presentation of GD4S White Paper on the role of gas networks as key enabler of the EU's energy transition.

Meeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness), Peter Power (Cabinet of Commissioner Mairead Mcguinness)

14 Sept 2021 · Gas grids: a key enabler of decarbonisation Discuss the Energy Efficiency Directive the TEN-E Regulation and proposals to reduce methane emissions and leaks in the natural gas value chain.

Meeting with Maciej Golubiewski (Cabinet of Commissioner Janusz Wojciechowski)

22 Jul 2021 · Gas Distribution for Sustainability

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

22 Mar 2021

GD4S welcome the EC decision to revise the EPBD. Massive and fast deployment of CO2 efficient solutions are indeed required in the building sector, the largest energy consumer and CO2 emitter in Europe, to meet the 2030’s CO2 objectives. These solutions must adapt to the high variety of local conditions across Europe. They must also be affordable to leave no one behind and, for a fast and resilient transition, they must contribute to solve the new challenges brought by the decarbonisation of the energy mix: • How to balance, cost and CO2 efficiently, a non-dispatchable renewable electric production and demand? • How to adapt the energy infrastructure, fast enough and at an affordable cost for the society (electric network cost is presently nearly as high as production’s in EU household bills)? • How to better integrate energy in the local circular economy? Coupling electric and gas sectors, via end-user appliances, is a solution to meet these challenges and ensure resilience of the system. Coupling via Hybrid Heating Solutions (HHS), such as hybrid heat pumps or micro-cogeneration, brings immediate benefits to the energy system and the renovation wave, for a fast, resilient, affordable and easier transition. • HHS can create a very large demand-response capacity, to maximise renewable energies integration, optimise grids adaptation costs and increase system resilience. To maximise savings, demand-response must be able to manage infrequent but real very cold winter weeks demand. • HHS are easy to retrofit in the normal lifecycle of a house heating system, either by replacing an obsolete system or as an add-on to a boiler. • HHS bring immediate CO2 gains with limited upfront costs. • HHS are a future proofed first step of a staged renovation, each further renovation step increasing the building efficiency. • HHS can fully shave the peak demand of energy for weeks if needed. • Smart HHS allow for an active CO2 and peak management, trading between renewable electricity and renewable gas. • Use of the existing gas infrastructure reduces or avoids the costs and disruption of reinforcement or roll-out of new infrastructures. • HHS can contribute to a net-zero energy system by 2050, when supplied with renewable electricity, biomethane or renewable H2. • HHS offers citizens and local authorities an opportunity to increase their involvement in the energy transition by linking local circular economy (biomethane and other renewable energy production), choices in building renovations and mobility, local public investments in energy infrastructures and support to the energy poor. Use of boilers, hybrid and renewable ready, should be rolled out as a fast, reliable and affordable step to decarbonisation: • They are the easiest and cheapest way to gain energy efficiency when replacing obsolete heating system (about 30% for few thousand euros). • New boilers are biomethane and hybrid ready and will be H2 compatible with hardly any increase in costs, making them future proofed. • Associated with renewable gas, new boilers are a good solutions for new buildings, allowing for 100% decarbonisation, without putting pressure on an already solicited power system ; it provides a long-term income to green gas producers while keeping energy bills at a reasonable level. For a full contribution of sector coupling to the fit for 55’s objective, some barriers have to be lifted. • The demand response-flexibility must be integrated in the calculation method. It shall consider the peak demand (Kw/m2) and possible attenuation to valorise the contribution to the energy system efficiency. • The calculation method shall also promote the use of locally produced renewable energy, as it is done in the German law GEG. • DSOs shall be recognized as key partners of energy communities in the implementation of the renovation wave, helping them to overcome financial, technical and economic barriers and play their role in the energy transition.
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Response to Revision of EU rules on Gas

10 Mar 2021

Gas Distributors for Sustainability (GD4S) welcomes the opportunity to provide feedback on the “Gas networks - revision of EU rules on market access” IIA consultation. In particular, we agree with the EC’s assessment that “full electrification is unlikely to be technically or economically viable”, and that “the share of gaseous fuels to total EU energy consumption in 2050 would be about 20%”, broadly in line with today’s share. 1. Definitions of gases: We welcome the close coordination “with other initiatives emanating from the EU Green Deal relevant for the decarbonisation of gas”, in particular, the ongoing revision of RED III. A key pillar in developing renewable and low carbon gases will be the classification of these gases according to their decarbonisation potential in the updated RED III. This classification would form the basis for an EU wide guarantees of origin system, which should be compatible with the ETS. Such a treatment would allow the developers of renewable and low carbon production to monetise the sustainability benefits of their projects and help promote uptake of renewable gases. 2. Framework for an internal hydrogen market : GD4S believes that hydrogen should be incorporated into the existing gas legislative framework, which has successfully delivered a competitive, integrated and secure gas market. We believe that gas DSOs are well placed to enable the development of ”an open and competitive” hydrogen infrastructure. The retrofitting/repurposing of existing assets, where possible represents a low risk and least cost pathway to deploying hydrogen at scale and helping to realise the decarbonisation objectives This approach leverages the experience of gas DSOs in terms of safe and efficient operation of the gas market over an extended period and the storage potential of the gas network. Gas DSOs should be able to play a key role in the establishment of the hydrogen market, including the possibility to develop and own electrolysers in the ramp up stage, subject to appropriate conditions. GD4S agrees that “an efficient and sustainable development of renewable and low-carbon gases may require, among others, regulatory incentives for production and/or consumption”. An important concept will be consideration of the allocation of investments in gas and hydrogen networks. In the initial stages of conversion or repurposing, consideration should be given to limiting the exposure of initial hydrogen network users to higher tariffs. 3. TYNDP : We also welcome further consideration on the role of gas distribution grids. We agree that the current legislative framework “does not anticipate decentralised gas injections” leading to sub-optimal conditions for the development of decentralised renewable and low carbon gases. In order to optimise the deployment of local gas production, we believe that gas DSOs should play a greater role in infrastructure planning via the TYNDP planning process. 4. Renewable gas target: GD4S believes that the only viable option to deliver on EC’s climate objectives is the third option outlined, i.e. “Integration of renewable and low-carbon gases in the existing gas infrastructure and markets”. This holistic and comprehensive approach will promote the uptake of renewable and low carbon gases on an EU wide basis. This would allow the widespread decarbonisation of important sectors such as industry, transport power and heat, thereby ensuring a ‘Just Transition’ at least cost to EU citizens. The uptake of renewable gases in the network should be driven by a renewable gas target based on the fuels listed in RED II. Notably, we believe that an EU gas DSO entity bringing together European gas DSOs should be created, with the mission of defining the rules enabling the transformation of distribution grids in the context of the energy transition (digitalisation, grid access to renewable gases etc.).
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Meeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness) and European Biogas Association and NGVA Europe

8 Mar 2021 · EU taxonomy, draft delegated act

Meeting with Henrik Hololei (Director-General Mobility and Transport) and European Biogas Association and NGVA Europe

4 Mar 2021 · Sustainable and Smart Mobility Strategy

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

3 Mar 2021

GD4S welcomes the European Commission (EC) proposal for a new TEN-E Regulation (COM(2020)824). The proposal paves the way for the future role of gas infrastructures in the energy transition, enabling the development of renewable gases and contributing to energy system integration. Smart Gas Grids & Electrolysers In line with the Energy System Integration and Methane Emissions Reduction strategies, GD4S supports the addition of the “smart gas grids” and “electrolysers” priority thematic areas and infrastructure categories. Those new categories will allow projects contributing to the development of renewable gases and energy system integration to receive the Project of Common Interest (PCI) status, and ultimately, funding from the Connecting Europe Facility (CEF). The proposal of the Commission rightly defines “electrolysers” and the concept of “smart gas grids”, including for example reverse flows installations from distribution to the transmission level or ICT, control systems and sensors technologies. However, it does not explicitly mention the grid connection from a renewable gas plan to the existing grid, despite those being essential to the decarbonisation of the grid. Also, it does say that electrolysers, next to renewable hydrogen, accelerate the deployment of synthetic methane, an e-fuel identified in the EU Long-Term Strategy and in the Energy System Integration strategy. GD4S also welcomes the creation of a mandatory sustainability criterion in the proposal of the EC, including a methane emissions reduction aspect for “smart gas grids”, allowing to ringfence the contribution of PCI projects to the EU climate and energy objectives. But, while the proposal from the EC rightly recognises the necessary needs for infrastructures at distribution level to integrate renewable gases in the system, the cross-border criteria and the lack of consultation of DSOs in the planification may represent barriers to their development. TEN-E is a Regulation to plan the development of cross-border infrastructures. Infrastructures who do not cross a border must present a cross-border relevance defined in Annexe IV. We believe that the cross-border relevance criteria defined for “smart gas grids” is too restrictive for distribution projects to receive the PCI status. For a distribution project to receive the PCI status, it must involve a Distribution System Operator (DSO) with two Transmission System Operators (TSOs) from two different Member States. This requirement will likely exclude most of the projects at distribution level to emerge despite their contribution to the priority thematic areas, to the achievement of the EU Climate and Energy objectives, and to the recovery from the COVID-19 pandemic. Those projects at distribution level are also essential to answer security of supply needs of EU Member States. Developing infrastructures for renewable gases will contribute to the constitution of an indigenous source of gas supply. Also, technologies linking electricity and gas grids and optimising the energy system contribute to energy efficiency gains and will reduce Member States reliance on gas imports. Thus, we suggest that the Article 4 conditions should be softened to make sure that projects at distribution level contributing to priority thematic areas and European objectives can receive the PCI status. The TEN-E Regulation is the framework to define PCI projects. Before being included in the PCI list, a project must be identified by a Regional PCI Group. In the proposal, DSOs can be consulted by the Regional PCI Group but cannot be full members unlike TSOs. As distribution grids have been added in the new energy categories, we believe DSOs should be eligible to become full members of Regional PCI Groups to provide their expertise in drafting the Regional PCI lists. GD4S remains at the disposal of the EC to provide its knowledge and experience on the development of smart gas grids and electrolyses.
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Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans), Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans)

2 Feb 2021 · Virtual meeting on Gas Package

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

26 Jan 2021

GD4S welcomes the EC initiative for the reduction of Methane Emissions through the adoption of specific legislation, as well as the opportunity to provide feedback on this consultation As stated in previous documents to the attention of the EC, GD4S strongly endorses the EU climate neutrality goal by 2050 and supports the adoption of measures based on a holistic approach to all available technologies and on the role of gas networks in facilitating the development and rollout of renewable and low carbon gases Achieving this goal requires a comprehensive methodology, part of which consists of effective methane emissions reporting, control and reduction. This entails dedicated investments and operational rules that go beyond the traditional effort made by gas DSOs to reduce fugitive emissions. GD4S agrees that the time has come to take a decisive step forward by adopting binding measures based on already existing operational frameworks and state of the art LDAR technologies. For this reason, GD4S supports Option 2b in the inception impact assessment, Paragraph B, Point i, OGMP framework applicable only to the intra-EU supply chain, with sector coverage including upstream, midstream and downstream gas & oil - OGMP 2.0. On biomethane, to avoid hindering a significant renewable energy source, it must be considered that biomethane production allows for the reduction in methane emissions in the agricultural and waste sectors, recovering methane that would otherwise be released directly into the atmosphere (for example from manure). This is consistent with the EU strategy on methane emissions when it also considers agriculture and waste, not only the energy sector, to exploit all potential synergies between sectors. This is a view that GD4S fully supports. Also, in order to favour synergies between sectors in relation to methane emission reduction, GD4S supports the creation of a binding renewable gas target at EU level. This measure, by imposing a steady increase in the renewable gas content in gas consumption, will promote biogas and biomethane production to improve circularity and better practices of agroecology and waste treatment. In order to ensure effectiveness, GD4S endorses the EC’s proposal to urge NRAs to include investments on LDAR and methane reduction programmes as allowed costs for regulated gas DSOs. GD4S also believes that specific financing opportunities to cover the costs associated with the greater complexity of operations, deriving from the application of best practices, would complement and strengthen the fight against methane emissions. Hence GD4S proposes the following actions in order to achieve the desired reductions: -Establish and promote the application of an EU Measurement, Reporting and Verification (MRV) system to effectively detect and measure methane emissions, including imports, in line with the best global experiences such as OGMP 2.0 -Include methane emissions reduction within the scope of regulated activity, to ensure that all costs related to mitigation measures are included and incentivised accordingly by NRAs -Considers operational differences in the supply chain when determining reduction targets, ensuring independent verification of emission factors and reported data -Support renewable gases injection into the gas network, which considering the entire life cycle reduces methane emissions in other activities, such as agriculture and waste management, favours circular economy and contributes to smart sector integration GD4S confirms its willingness to cooperate with the EC in its efforts to monitor, control and reduce methane emissions and in the adoption of a reliable monitoring and reporting framework. GD4S supports the adoption in upcoming legislation of the work currently underway in the GIE/Marcogaz Methane Emissions working groups and is keen to participate in the improvement of methodologies and practices as part of its commitment to contribute to the EU's climate neutrality goal.
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Response to Climate change mitigation and adaptation taxonomy

15 Dec 2020

Gas Distributors For Sustainability (GD4S) welcomes the improvements on the TEG report in the treatment of gas network and bioenergies. Yet GD4S wishes to express serious concerns over the assessment of energy-related activities. The shortcomings highlighted below should be addressed to get a taxonomy that fulfils its role of facilitating an affordable and faster energy and climate transition in all Member States. a) Expansion of natural gas networks to replace more carbon-intensive fuels energies (coal, fuel oil and LPG) should be included (activity 4.14), at least as a transitional activity, and with clear criteria set to mitigate the risk of lock-in of fossil fuels. Activities that enable a future transport and distribution of hydrogen and green gases, despite not being fully dedicated, should be considered. The “transitional activity” category should include all relevant and effective technologies in light of the increased climate 2030 target. The triennal review reinforces the relevance of this tool. b) Digitalisation of hydrogen- or biogas-ready infrastructures should be included because they are necessary to establish the “energy infrastructure required for enabling the decarbonisation of energy systems” (article 10.1(g) of the Taxonomy Regulation 2020/852). They should not be restrained on the basis that they could led to increased infrastructure volumes. c) Activities related to bioenergy and biogas (4.8, 4.13, 4.20, 4.24) are considered as transitional. This goes against article 10.1 of the Taxonomy Regulation which clearly states that the generation and use of renewable energy in line with Directive 2018/2001 (RED II) substantially contribute to climate change mitigation. d) The criteria for the bioenergy related activities should be aligned with RED II: To avoid unnecessary confusion, only 70% of GHG emissions savings should be required instead of 80% should apply until 2026 for the use of bioenergy for electricity and/or heat generation. For biogas production for transport, a gas-tight cover on the digestate storage should not be required while it is not for other biogas usages. This practice is not relevant in each case as it depends the residual capacity to emit methane of the feedstocks used. The GHG emission savings required by RED II are an incentive strong enough for operators to apply a gas-tight cover when needed. e) Highly efficient gas and hybrid heating appliances are partially excluded (activities 3.4 and 7.6) even though they can run on renewable gases. Restrictions on the use of renewable gas in heating of buildings is not coherent with the criteria on biogas production. It also jeopardizes the market development of appliances that can meet the needs of different building types and climate zones as well as the flexibility need of the energy system. f) Proposed criteria exclude almost all types of vehicles running on biomethane. They fail to apply existing legislation consistently, preventing this renewable fuel to decarbonise the transport sector. This contradicts Activity 4.13 recognising that biogas can be used in transport. This is not consistent with the Green Deal policy objective to transition the EU towards a circular economy. Nor is it legally consistent with article 9 of the Taxonomy Regulation establishing the “transition to a circular economy” as one of the 6 environmental goals. Vehicles could use locally-produced biomethane, contributing to a circular economy benefitting to new biomethane producers and local population (job creation). This does not match either with technological availability and market needs in different transport modes and segments. Earmarking green investments only for zero emission vehicles will strongly penalize sustainable solutions in road transport, inland water transport and non-electrified segments of the rail networks. It will jeopardize the development of low-emission fleets in low-density areas where electric and hydrogen vehicles are not appropriate.
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Gas Distributors Urge EU to Recognize Biomethane for Mobility

25 Nov 2020
Topic — Revision of the CO2 emission performance standards for new cars and vans.
Message — The organization calls for a shift from tailpipe-only emission measurements to a full Life Cycle Analysis. They urge the Commission to implement a crediting system that accounts for the contribution of renewable fuels.12
Why — This would remove market barriers for gas-powered vehicles and foster the use of their distribution networks.34
Impact — Electric vehicle manufacturers may face increased competition as the regulatory 'playing field' shifts toward gas-based technologies.5
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Meeting with Filip Alexandru Negreanu Arboreanu (Cabinet of Commissioner Adina Vălean)

9 Nov 2020 · Sustainable and smart mobility strategy

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

21 Sept 2020

The revision of the Energy Efficiency Directive is an important step to cement the road to climate neutrality including recent related works such as the Energy System Integration, the renovation wave and the Hydrogen strategy. At GD4S, we are convinced that gas solutions and renewable gases, can bring key contributions to achieve a fast, safe and sustainable energy transition and meet the increased 2030 targets. - Sustainable renewable biomethane production has a potential of over 1,100 TWh in Europe (Gas for Climate: Gas Decarbonisation Pathways 2020–2050). The experience of France and Denmark shows that, when conditions are right, the development of this renewable energy can be fast, with many benefits for the environment and the people, such as facilitating the transition to sustainable agriculture and development of a local circular economy. This production will be completed by other renewable gases such as synthetic methane from pyrogasification and hydrogen from power to gas. Gas solutions are efficient and affordable, which is why they have been widely chosen for heating and can work with natural gas and renewable gases or a blend of both. Increasing the replacement rate of obsolete heating equipment with smart combinations of existing technologies from 4 to 5% per annum can yield important cost-effective benefits in building energy performance (about 40% in 2030 - Ecofys- “EU pathways to a decarbonised building sector”). They are no regrets solutions as they can be immediately or later, hybridised with other renewable compatible solutions (solar, heat pump) to make the best use of all renewable energy available. In the medium-long term, applications such as gas absorption heat pumps and fuel cell technologies can deliver substantial extra energy savings. - Indeed, Smart Hybrid Heat Pump options deliver a fast and optimised solution for existing housing stock (IEA Technology Collaboration Program – Hybrid Heat Pumps Annex 45) by offering cost effective solutions compatible with progressive renovation and greatly reducing the disruption associated with deep retrofit. Energy System Integration, through power to gas and smart hybrid solutions brings a new dimension to efficiency. Beyond their own efficiency, they increase the overall energy system efficiency, by avoiding losses of intermittent renewable electricity (power to gas) and by bringing much needed flexibility to the power system, by means of smart hybrid solutions to the energy grid. This flexibility allows to maximise the integration of renewable energies and to manage the electric peak demands, by temporarily transferring the extra load to the gas grid, thus reducing the risks of black-outs and the costs of electric grid adaptation. Prosumers have a major role in this efficiency energy system improvement. This requires that they have a clear information when choosing their heating solution, through pertinent labelling, and that they receive a motivating price signal in relation to the savings generated by the gains in system efficiency. Therefore, we recommend that : 1. EED shall encourage the efficiency improvement of all existing and emerging technologies (technology neutrality). 2. EED shall promote fast and cost-efficient ways of increasing efficiency in renovation (replacement of obsolete equipment and coal or fuel based heating systems by high performance gas or hybrid heating solution). 3. EED shall extend its perimeter to cover the contribution to energy system efficiency via sector coupling, at production, transport, distribution and consumer’s levels, through all energy carriers. 4. EED shall promote the development of smart appliances which can be set to respond to smart grid signals, such as smart hybrid heating, with boiler or cogeneration / fuel cells. 5. EED shall promote the assessment of system efficiency gains using smart appliances and how these gains can be made visible and shared with the consumers/prosumers.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

21 Sept 2020

GD4S welcomes the expected revision of the Renewable Energy Directive (REDII) as part of the Energy System Integration Strategy and the possibility to comment on the Inception Impact Assessment (IIA). With the publication of the ESI and Hydrogen strategies the Commission has underlined the important role renewable gases will play to reach carbon neutrality in a cost-efficient way. Thus, the revision of the REDII is the legislative opportunity to stimulate their development. With the European Climate Law under negotiations, the European Union is currently considering raising its greenhouse gases emissions reduction target from 40% to 50-55% by 2030. GD4S agrees that raising the climate ambition between 2020 and 2030 is necessary to meet the objective of a net zero continent in 2050. To reach this goal the renewable energy objective, today 32% in 2030, shall also be raised. Therefore, GD4S supports the option 3 to raise the level of ambition of the targets. The Commission underlines in the IIA that decarbonisation and the uptake of renewables for several energy carriers - such as gas – must be accelerated. Thus, GD4S calls for setting a renewable gas target. This target shall be binding at the EU level and adapted at national levels considering national features. The target will not only be useful to decarbonise the network, but also to better maximise production volumes and optimise end use. National Energy Climate Plans should provide the Commission with a view on renewable gas development in each EU Member State and how it will contribute to the objective of climate neutrality. The present REDII also includes sectoral renewable energy targets for transport and heating&cooling to specifically drive the growth of renewables in these areas. The Commission in the IIA underlines that the decarbonisation of buildings and transport sectors must be fast-tracked. Therefore, a reflexion on an increase and a redefinition of those targets may be needed. Additionally, to develop renewables in the transport and the buildings (heating) sectors REDII can be amended to translate into legal measures the actions proposed in the European Green Deal. For example, provisions within REDII could be updated to better integrate renewables, including biomethane, in buildings in the context of the Renovation Wave initiative. Therefore, GD4S also supports the option 4 of the IIA. Finally, the revision of RED II is also the occasion to see how we can maximise the potential of sustainably produced biomethane and to recognise its environmental benefits. Today, the Annexe IX of the REDII lists feedstocks that can be used for biogas production. We believe the Annexe IX should be revised to broaden the scope of feedstocks that can be used. For example, all biowastes according to the definition in the Waste Directive (2018/851) shall be included. A category for intermediary crops (also called cover crops, catch crops) should also be added to the list as they provide numerous environmental benefits. We have attached to our answer the study from Arvalis OPTICIVE underlining the CO2 capture and storage potential of catch crops/cover crops. GD4S remains at the disposal of the European Commission’s services for any clarifications. We are looking forward the next steps of the consultation process.
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Meeting with Kadri Simson (Commissioner) and

10 Sept 2020 · Energy system integration, decarbonisation of gases and the related regulatory framework, methane emissions.

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

8 Jun 2020

GD4S is convinced that gas solutions and renewable gases are essential for a complete decarbonisation of the building sector. Complementing electricity-based heating technologies, they bring contributions to flexibility and resource adequacy to the electric system thus enhancing the safety and reducing the high cost, in euros and CO2, related to electric peak management. This can be done through hybrid appliances, an electric heat pump coupled with an efficient gas appliance (high-performance boiler, or gas heat pump or fuel cell). For the end user, hybrid heat pumps are cheaper than their electric counterparts as the expensive part, the electric heat pump, doesn’t have to be dimensioned for the coldest day, but for the highest annual efficiency. Hybrids have the advantage to be much easier to retrofit, as they do not require a deep renovation prior to their installation. They are adapted to a step by step renovation with the highest benefits at the beginning, increasing with every isolation works. The hybrid settings can be adjusted according to the evolution of energy prices to optimise the end-user bill. At the energy system level, hybrid brings energy efficiency (>30% when compared to an obsolete boiler) and a very useful “passive flexibility” to the electric system: on the coldest days it switches to gas, reducing the need for electric peak power production, usually the worst in terms of CO2 emissions. Its full benefit comes when it becomes smart, responding to electric grid signals. It then brings flexibility to the energy system without any comfort impact on the end user. This flexibility can be used to optimise the energy supply with the lowest CO2 content (renewable electricity or renewable gas) and to manage the demand on the electricity grid at the local level. This “gas system back-up” will enhance the electricity system safety and its costs by reducing the need to invest in expensive, carbon wise and euro wise, peak electricity production back-up and electric grid reinforcements (network costs in EU households electric bills is close to production costs and are 4 times the gas grids costs). Smart hybrids solutions in the renovation wave are no regrets solutions: - They enhance sustainability, they make the best use all renewables, electric or gaseous; increase energy efficiency without deep renovation for a quick deployment - They enhance energy safety: in addition to the natural safety of a dual carrier system, they bring dynamic flexibility capacity to the electric grids to manage grid load and reduce the black-out risks - They enhance affordability, by reducing costs at end user and system levels For to the success of the Green Deal and Recovery, an enabling framework for renovation wave should: - Drive a diversified heating energy carrier mix including decarbonised gases by 2050: to supports affordable and cost-optimal decarbonisation of the building stock by 2050 - Optimise the use of existing gas infrastructures to facilitate decarbonisation: a smart mix of heating based on electricity and decarbonised gases supports the electrification of transport and industry, reducing costs by optimising the use of existing infrastructures - Tap the potential of innovative heating technologies: Investment technologies such as heat pump/gas hybrids with digital demand response capabilities are key enablers. They speed up the uptake of renewables, deliver large aggregated emission reductions and reduce energy bills - Secure investments in renewable gas supply with: binding EU-level targets for renewable gases and fair rules for flexible gas injection and distribution in support of optimized use of local resources such as biomethane - Prepare the integration of low carbon hydrogen in the energy system: further explore the use of existing gas infrastructure for hydrogen, in blending with methane or not. Synchronize decarbonisation of gas and market transformation of gas-using appliances under ecodesign and energy labelling
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Response to Strategy for smart sector integration

8 Jun 2020

GD4S fully supports the smart sector integration strategy, regarding it both as an essential step on the road to climate neutrality and vitally important in the context of the EU recovery plan. GD4S believes that gas solutions and renewable gases, including biomethane and hydrogen, are essential for fast, safe, affordable and sustainable decarbonisation of the economy. Complementing electricity-based technologies, they bring contribute significantly to the flexibility and resource adequacy of the energy system. At the users’ level, smart hybrid appliances such as hybrid heat pumps (coupling of an electric heat pump and high-performance boiler) open the possibility for dynamic management of electric demand, with no impact on the end user’s comfort. This flexibility will increase the energy safety by giving the possibility to shave local or national electric peaks, thus saving the high costs, in euros and CO2, associated with peak electricity production and grid capacity. For example, of the savings generated, the cost per KW of new electricity grids can be up to 20 times more expensive than gas grids, which are already in place. This flexibility can be used to prioritise the use of the most carbon efficient source of energy available, either electric or gaseous. At the production level, coupling gives the opportunity to adapt production to demand, either by storing the remaining excess production of renewable electric through power-to-gas, or to meet peak demand by producing electricity from renewable gas. In our view, an enabling framework for smart sector coupling should include the following policy goals: Secure investments in renewable gas supply with: -Binding EU-level targets for renewable gases -Fair rules to increase gas injection and distribution in support of optimised use of local resources such as biomethane -An EU-wide certification system for all renewable gases Prepare the integration of low carbon hydrogen in the energy system: -Further explore the use of existing gas infrastructures for transmission and distribution of hydrogen, in blending with methane or not -Synchronise decarbonisation of gas and market transformation of gas-using appliances under ecodesign and energy labelling - facilitate that end-use appliances are capable to process hydrogen-methane blends or pure hydrogen Optimise the use of existing gas infrastructure to facilitate decarbonisation of transport, industry and buildings under a holistic approach of the energy system: a diversified mix based on electricity and decarbonised gases supports the penetration of renewable energy, reducing costs by optimising the use of existing infrastructures -Couple electricity and gas infrastructure development plans to optimise transversely the investment effort required for the transformation of the energy system -A holistic approach based on the principle of technology neutrality must prevail in order to enable the most efficient and relevant investment choices from available options i.e. power line, installation of P2G, use of existing gas infrastructures, etc. It must also reconcile the economic, societal aspects and environmental impacts, while ensuring robustness against the consequences of the chosen transition path -Create a European Gas DSO entity with a clear mandate and adequate representation of the sector, as the energy system is more and more decentralised Mine the potential of innovative renewable gas technologies and foster hybridisation: Investments in modern heating technologies such as heat pump/gas hybrids with digital demand response capabilities are key enablers. They speed up the uptake of renewables, deliver large aggregated emission reductions and reduce energy bills. It is a ‘no-regret’ option for staged deep renovation. On the production side, P2G is a promising solution for a 100% decarbonised energy mix. With these measures smart sector integration can be a decisive contribution for the Green Deal and economic recovery
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Response to A EU hydrogen strategy

8 Jun 2020

GD4S is an association bringing together seven gas DSOs in Europe, each of them a leader in their respective country (France, Greece, Italy, Ireland, Portugal, Romania and Spain). GD4S is committed to contributing to the decarbonisation of the gas sector with renewable gases (biomethane, synthetic methane and renewable hydrogen). GD4S welcomes the opportunity to provide feedback on the “EU Hydrogen Strategy” Roadmap consultation and the scale and ambition of the proposed strategy including support for “the deployment of renewable hydrogen”. Indeed, hydrogen can contribute to the decarbonisation of all sectors of the economy, thus playing a key role in the EU Green Deal and Next Generation EU. In particular hydrogen can play a key role in heating homes and small businesses connected to gas distribution networks as many networks are using polyethylene pipes which are well suited to hydrogen. Furthermore, the rollout of hydrogen for industrial applications and for the purposes of sector coupling between gas and electricity networks will create economies of scale which can be leveraged to distribute hydrogen to smaller energy users at low cost. The roll out of hydrogen also enables advanced end use applications such as fuel cell technologies and hybrid heat pumps. As well as potentially avoiding deep retrofit of older dwellings and associated costs, these hybrid options can help avoid costs associated with reinforcement of electricity grids and allow arbitrage between hydrogen and electricity to deliver energy to the end user at lowest costs. Combined with other renewable gases, the rollout of hydrogen potentially represents a ‘least regrets’ pathway to decarbonisation of heat as new gas appliances could be mandated to be ‘hydrogen ready’ in advance of a rollout. Biomethane, especially from agriculture, has a huge potential in Europe. The upgrading of biogas into biomethane make available biogenic CO2, not valorised today. By combining this CO2 with hydrogen (produced locally from electricity generated by solar or wind farms) in a process of methanation, biomethane producer is able to produce a synthetic methane that can be injected in the gas grid with the same connection than for biomethane. Even if considered today as expensive, methanation is a promising technology to boost renewable gas development. It completes the biomethane plant by valorising the CO2 and to store hydrogen production in the existing gas grid. In a holistic approach, methanation avoid cost in the infrastructure and appliances as synthetic methane is perfectly substitutable to natural gas. In order to maintain the benefits of the Internal Energy Market, GD4S recommends that existing EU gas legislation be extended to hydrogen (as well as CO2 networks). Non-discriminatory third-party access to hydrogen networks is essential to guarantee a level playing field between all producers and users and to preserve the integrity and further develop the Internal European Energy Market. A regulatory sandbox framework approach allows for innovation, system adaptation and optimisation for technologies that are at an early stage of development. Power to gas, in particular, should be treated as an energy conversion service, recognising its unique role in energy systems integration. This treatment also potentially allows TSOs and DSOs invest, particularly where no other investors are present. Any such arrangements could be subject to appropriate exit criteria for TSOs and DSOs once markets have matured and cost reductions achieved. In order to foster development of the hydrogen economy the EU will need to provide clear policy incentives and remove regulatory barriers. GD4S is pleased to share it key recommendations of actions to scale-up clean hydrogen in the attached PDF.
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Response to Revision of the guidelines for trans-European Energy infrastructure

8 Jun 2020

GD4S is an association bringing together seven gas DSOs in Europe, each of them a leader in their respective country (France, Greece, Italy, Ireland, Portugal, Romania and Spain). GD4S is committed to contributing to the decarbonisation of the gas sector with renewable gases (biomethane, synthetic methane and renewable hydrogen). GD4S welcomes the opportunity to provide an answer to the Commission’s combined evaluation roadmap/inception impact assessment on the TEN-E Regulation (347/2013). The TEN-E Regulation is a cornerstone of EU energy infrastructure policy. In past years, it has been a motor for the finalisation of large gas and electricity interconnections, improving the liquidity of Europe’s energy markets. Today the TEN-E Regulation is no longer in line with the EU’s objective to reach carbon neutrality by mid-century. The TEN-E is criticized by many actors (ACER, national regulators, NGOs) for the lack of independence in the selection of projects, as well as contradicting the current and new energy challenges (Green Deal, RED II, Sector Coupling, European Hydrogen Strategy, etc…). Therefore, GD4S is calling to redirect European funds allocated under the TEN-E Regulation to projects contributing to the objectives of the Green Deal and consistent with an increasingly decentralised and decarbonised energy landscape. You will find GD4S recommendations and vision in the attached document.
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Response to Climate change mitigation and adaptation taxonomy

15 Apr 2020

Gas Distributors for Sustainability (GD4S) comprises the leading natural gas distributors in France, Italy, Ireland, Spain, Portugal and Romania. Together, we represent 27.4m customers in Europe. We support the aim of providing a clear framework to define environmentally-sustainable economic activities, routing investment accordingly. GD4S makes the following observations: 1. Scope and clarity of the classification GD4S concurs on the need to unify the disparate approaches taken by several market-led and Member State schemes which define criteria differently. The scope of the classification should be wide enough to include environmentally-efficient mature technologies and business models, as well as emerging technologies. In addition, criteria should not be excessively detailed in order to afford new, low-carbon innovation to emerge and be financed. Therefore investment scenarios involving different models of Anaerobic Digestion, that produces both biogas/biomethane and an organic fertiliser (digestate) and can have net carbon negative GHG footprint under a full Life Cycle Assessment (LCA) should be covered. Hydrogen production should also be taken into account and considered as a sustainable energy, in particular in light of the recently-revised state aid rules proposed by the European Commission for Important Projects of Common European Interest (IPCEIs) and the announcement of the forthcoming ‘Clean Hydrogen Alliance’, proposed in the Industrial Strategy. Clarity on the criteria for projects is imperative. The resulting set of activities will ensure clear lines in relation to what may be considered environmentally-sustainable for investment purposes, and will therefore enhance the information that businesses and investors have at their disposal. 2. Eligibility of technologies The European Commission should follow the technological neutrality principle set out in the Taxonomy Regulation. It would allow all relevant technologies in renewable energy (whatever the type of energy), low carbon transport, heat and infrastructure management to compete on the basis on their environmental performance. The logic applying to gas networks and electricity networks should be the same when it comes to equipment and activities enabling the increasing integration of decentrally-produced renewable gas (biomethane or hydrogen) or electricity. That is why technologies across sectors, including transportation, should be comparable on a consistent Life-Cycle Assessment (LCA) basis and none can be excluded from an LCA obligation. Under such principle, technologies which enable the production and use of gaseous energy from biomass, such as anaerobic digesters, biomethane plants, grid injection facilities, and bioNGV vehicles should be eligible. Organic renewable bio-fertilisers (such as digestate from anaerobic digestion facilities) need to be given higher priority given their positive combined benefits with the production and use of biomethane while promoting innovation, growth and jobs in the EU economy and reducing reliance on energy and mineral fertiliser imports. 3. Delivering on “expected impacts” To play a key part in enabling the EU to achieve its climate objectives, the taxonomy should enable a genuine energy transition by recognising the potential of CO2 emissions reduction of natural gas and, to a larger extent, biomethane (upgraded biogas), in production of electricity, heat, and heat and power (cogeneration). It would then follow the recommendation of TEG report stating “An economic activity cannot truly be considered sustainable independently from the wider system in which it operates” This will help ensure that capital is directed into activities that quickly contribute most to the EU’s environmental, economic and social objectives.
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Response to 2030 Climate Target Plan

14 Apr 2020

Gas Distributors for Sustainability (GD4S) comprises the leading natural gas distributors in France, Italy, Ireland, Spain, Portugal and Romania. Together, we represent 27.4m customers in Europe. GD4S welcomes this opportunity to provide feedback on the inception impact assessment of the 2030 Climate Target Plan. Overall, we support the Plan as part of the European Green Deal. Having reviewed the inception impact assessment, we make the following observations: We agree that raising the climate ambition between 2020 and 2030 is necessary to meet the objective of a net zero continent in 2050. Therefore, the renewable energy objectives in the renewable energy directive (RED II) and the energy efficiency objectives in the energy efficiency directive (EED) will need to be increased. As representative of the gas distribution sector, we would like to underline how our companies can help in meeting enhanced targets. A renewable gas target should be fixed at the EU level and adapted at national levels considering national features. This target, based on the injection of renewable gas into the grid will not only be useful to decarbonise the network, but also to better maximise production volumes and optimise end use. National Energy and Climate Plans should be aligned and based on a coherent approach. Those plans should provide the Commission with a view on renewable gas development in each of the EU Member States and how it will contribute to the objective of climate neutrality. We strongly agree with the Commission that the 2030 Climate Target Plan must “increase the ambition in a manner that best contributes to sustainable and inclusive growth, enhances economic competitiveness through accelerating innovation and modernising Europe’s enterprises”. Gas and renewable gas technologies fit this objective. Electrolysers and hybrid heat pumps can be easily produced in Europe and therefore be a vector of Europe’s competitiveness in the world. These technologies are participating to the coupling of gas and electricity sectors and will therefore reduce the need for additional infrastructures (reinforcement of electricity grid, electricity peak management technologies), which will be beneficial to energy affordability and security. We strongly agree with the Commission that “all sectors of the economy and society will need to contribute” to raising the targets. The gas sector has the advantage to reach different sectors. Biomethane can be injected in the grid easily and this renewable energy reduces agriculture and urban waste. It provides a substitute to chemical fertilizers – through digestate it co-produces – and brings additional revenues to farmers, consequently supporting rural areas. The use of sequential cropping in the process increases carbon capture in soils, while preserving land for food production. These biomass-based products play the role of natural sinks. Biomethane can also be used as a fuel to decarbonise mobility. BioNGV offers strong CO2 emissions reduction over its lifecycle. To consider this contribution in the Regulations setting CO2 standards for light-duty and heavy-duty vehicles, we urge for the adaptation of the lifecycle methodology at EU level to account for CO2 reduction emissions. GD4S remains at your disposal to further discussed the above points (contact@gd4s.eu).
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Response to Revision of the Energy Tax Directive

30 Mar 2020

Gas Distributors for Sustainability (GD4S) comprises the leading natural gas distributors in France, Italy, Ireland, Spain, Portugal and Romania. Together, we represent 27.4m customers in Europe. GD4S welcomes this opportunity to provide feedback on the roadmap to revising the Energy Taxation Directive. Overall, we support the Directive being updated to actively support delivery of the European Green Deal. Equally, we welcome the objective of preserving and further integrating the internal EU energy market, as well as the aim of providing more clarity to national Governments on how to implement the Energy Taxation Directive. Having reviewed the impact assessment, we make the following observations: • We urge caution to ensure that the revised Directive has no unintended impacts on security of supply. For example, capacity numeration supports ensure that thermal power plants are on standby to provide back-up to intermittent renewable energy sources. We ask the Commission to carefully consider how the EU will maintain security of supply and incentivise decarbonised thermal generation to support intermittent renewables. • We commend that the revised Directive is designed to support the scaling of capacity within EU energy networks and the development of new technologies. In particular, we highlight the opportunity for the Directive to support the development and commercialisation of technologies such as hydrogen, carbon capture storage, clean energy, CNG & bio CNG for heavy duty vehicles. To ensure continued security of supply, and to accelerate delivery of the EU Green Deal, GD4S proposes that all additional taxation revenues collected following the review be ring fenced and reinvested in the development of new energy technologies. • The review of sectoral tax differentiation is required to meet EU climate objectives. For example, only gas oil can get a differentiated tax rate depending on the private or commercial usage (article 7 §2). This option should be extended to all fuels listed under the AFI Directive. • The Commission must review the scope of the energy products covered by the ETD to apply favourable taxation regimes to products which benefit the environment. For example, charges on renewable gases (defined by the RED II Directive) must be reduced based on the actual framework for renewable electricity (15 §1 §b). Also, products from biomass should benefit from exemptions or reductions even if their development are obliged by European obligations (article 16 §§ 1, 6) such as the renewable energy objective for the transport sector in the RED II Directive. On biofuels, the taxation regime should be based on the sustainability of these fuels as defined in RED II. • Finally, we highlight the importance of the revised Directive avoiding massively increased energy costs, which would negatively impact the competitiveness of the European economy. We welcome the inclusion of a social impact assessment in the roadmap and ask that social consequences continually be considered in further consultation rounds. To minimise the negative impact on consumers from rising energy prices, we propose that least cost and least disruptive technologies are deployed and incentivised. Electrification, natural gas with carbon capture and storage, renewable gases, such as hydrogen and biomethane, and renewable electricity will all play significant roles in the energy system in 2050 and the Directive should support this objective. Several studies show that renewable & decarbonised gas provide the least disruptive way of decarbonising heating across the EU. Leveraging the decarbonisation potential within Europe’s existing energy infrastructure will help minimise the cost of decarbonisation to industry and consumers.
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Response to Carbon Border Adjustment Mechanism

30 Mar 2020

Gas Distributors for Sustainability (GD4S) comprises the leading natural gas distributors in France, Italy, Ireland, Spain, Portugal and Romania. Together, we represent 27.4m customers in Europe. We welcome the opportunity to provide feedback on the “EU Green Deal – Carbon Border Adjustment Mechanism.” GD4S acknowledges that this mechanism will move towards protecting the competitiveness of the European economy. It will also leverage the decarbonisation potential of Europe’s existing energy infrastructure, and in doing so, minimise the cost of decarbonisation to industry and consumers, meeting ‘Just Transition’ objectives. Having reviewed the Roadmap, we make the following observations: 1. Growth strategy impacts on innovation and research GD4S fully supports the ambition of the European Green Deal to “transform the EU into a fair and prosperous society…with a competitive economy”, an economy with no net emissions of greenhouse gases in 2050 and not threatened by carbon leakage. We acknowledge this growth strategy and note that green technologies proven to contribute to decarbonisation goals also represent positive opportunities: • Renewable biomethane, which is net zero carbon and fully compatible with the existing gas networks, represents the least cost and least disruptive way to decarbonise home heating. • For the EU to achieve net-zero emissions by 2050, Carbon Capture Storage (CCS) is a necessity. CCS with Bioenergy has the potential to deliver negative emissions. • In the longer term, hydrogen will play a major role in the EU’s energy mix. Renewable hydrogen can be produced using Power to Gas technology using excess renewable electricity. Hydrogen can also be produced from Natural Gas, and when combined with CCS technology decarbonised hydrogen can be produced. 2. Prioritising a fair transition to a carbon neutral economy Delivering a carbon adjustment will make it more expensive to import carbon-intensive products and thereby potentially impact on a fair transition to a carbon neutral economy. With the Green Deal emphasising the need for a just and socially balanced transition, GD4S supports the view that: • Renewable gases (natural gas, biomethane or hydrogen) should remain part of the energy mix and will help protect downstream jobs in energy-intensive industries. • Least cost and least disruptive technologies are deployed, with electrification, natural gas with CCS, renewable gases and renewable electricity all set to play significant roles in the 2050 energy system. • Several studies have shown that renewable & decarbonised gas provide the least disruptive way of decarbonising heating across the EU. • Leveraging the decarbonisation potential within Europe’s existing energy infrastructure will also minimise the cost of decarbonisation to industry and consumers. 3. Working in Partnership The EU Green Deal identifies the importance of “partnerships with industry and Member States”. Incentivising trade partners to decarbonise through the border adjustment will have an impact on global CO2 emissions. It may also enable the EU to become a leader in key technologies which unlock the development of hydrogen, including the electrolysers needed to produce Green Hydrogen. Europe is home to energy intensive industries, including the chemical and steel sectors, which have intensive energy and heat needs in their production processes. We propose that revenues recouped as the result of the carbon border re-adjustment are ring-fenced and reinvested in technologies, such as CCS and hydrogen, which will help decarbonise these industries. Policy and fiscal support for sectors already on a positive 2050 trajectory is also valid and will assist in the development and commercialisation of new energy technologies, ensuring their competiveness.
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Response to Climate Law

6 Feb 2020

Gas Distributors for Sustainability (GD4S) welcomes the Commission’s Intitative on a Climate Law that will contribute to the implementation of the Paris agreement on climate change and ensure an ambitious and just EU climate policy. GD4S supports the initiative’s goal to enshrine the EU objective of climate neutrality by 2050 in legislation. We believe gas grids can help meet this target in the short, medium and long term and be enablers of a “Just Transition”. In the short term, natural gas helps to phase out more carbon intensive fossil fuels such as coal and oil, while maintaining a resilient and affordable system. In the medium and long term, renewables gases (biomethane, hydrogen and synthetic methane) offer solutions to meet the enhanced European climate targets. The uptake of renewable gases highlights gas grids as valuable assets to a future hybrid energy system fit for climate neutrality. Additionally, the development of smart gas grids and digitalisation will contribute to the reduction of greenhouse gases emissions. Through Power to Gas, hybrid heat pumps and the broader concept of sector coupling between gas and electricity markets, the existing gas infrastructure, with its vast storage capabilities, can support the integration of renewable energy and reduce the need for large investments in electricity grids. Digitalisation of grids through the installation of smart meters and sensors will allow to make substantial energy efficiency gains. GD4S appreciates that the initiative seeks the participation of all sectors in the achievement of climate neutrality. Biomethane production can be intertwined with sectors that are difficult to decarbonise, including mobility and agriculture, through its climate benefits and positive externalities, providing a case for sectoral integration. • Biomethane production reduces agriculture and urban waste. It provides a substitute to chemical fertilizers – through digestate it co-produces – and brings additional revenues to farmers, consequently supporting rural areas. The use of sequential cropping in the process increases carbon capture in soils, while preserving land for food production. • Biomethane as a fuel offers strong CO2 emissions reduction over its life cycle. BioNGV mobility is a strong solution to reach climate-neutrality in the transport sector but also provides public health benefits due to lower emissions of NOx and PM. GD4S supports the Commission’s suggestion to have intermediate targets to 2050. These targets will allow to bring predictability for economic actors and ensure the transition to climate neutrality is irreversible. GD4S also think the Climate Law should set the principle of having sectoral targets. A renewable gas target should be fixed at the EU level and adapted at national levels considering national features. This target, based on the injection of renewable gas into the grid will not only be useful to decarbonise the network, but also to better maximise production volumes and optimise end use. The Climate Law and the National Energy and Climate Plans should be aligned and based on a coherent approach. Those plans should provide the Commission with a view on renewable gas development in each of the EU Member States and how it will contribute to the objective of climate neutrality. GD4S remains available to discuss any of the issues raised above. Please contact us at contact@gd4s.eu
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Meeting with Ditte Juul-Joergensen (Director-General Energy)

30 Jan 2020 · Green Deal and Renewable gas in Europe

Response to Evaluation of the effectiveness and policy coherence of the guidelines for trans-European Energy infrastructure

11 Jul 2019

The feedback of the European association GD4S is available in the attached document.
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Meeting with Dominique Ristori (Director-General Energy) and Gaz Réseau Distribution France and

18 Feb 2019 · The role of gas DSOs in the context of European gas markets