Gas Networks Ireland
GNI
Gas Networks Ireland is the owner and operator of the natural gas transmission and distribution systems in Ireland.
Focus Areas
2024-2025
2022-2023
2016-2021
ID: 026007721768-32
Lobbying Activity
Meeting with Maria Walsh (Member of the European Parliament)
4 Nov 2025 · Biomethane
Meeting with Nina Carberry (Member of the European Parliament)
4 Nov 2025 · Energy
Gas Networks Ireland Urges Flexible Storage and UK Cooperation
13 Oct 2025
Message — GNI requests a technology-neutral definition of strategic storage. They seek flexibility for Member States to address regional needs and non-EU connections. The group advocates for TSOs to manage strategic reserves, including liquefied natural gas.123
Why — This permits GNI to manage Ireland’s floating gas reserve while avoiding market unbundling conflicts.4
Gas Networks Ireland promotes renewable gas for 2040 target
1 Sept 2025
Message — Gas Networks Ireland recommends recognizing biomethane and hydrogen as vital for reducing pollution. They propose repurposing existing infrastructure to avoid lost investments and support a variety of technologies. They also seek EU funding for network improvements in isolated regions.12
Why — This would help the operator prevent financial losses from unused pipes and secure funding.3
Response to Gas SoS – risk groups amendment
14 Aug 2025
Gas Networks Ireland (GNI) welcomes the opportunity to respond to the European Commissions consultation on the proposed update to the composition of regional risk groups under Article 3(8) of Regulation (EU) 2017/1938. GNI appreciates the Commissions efforts to reflect the evolving landscape of gas supply in Europe and supports the objective of enhancing the EUs resilience and preparedness in the face of energy supply disruptions. GNI supports the Commissions proposal to reduce the number of regional risk groups from 13 to 4. This streamlining process represents a pragmatic and timely response to the significant changes in European gas supply dynamics since 2022, including the accelerated diversification of supply sources and the reduction in dependency on Russian pipeline gas. This simplification is expected to facilitate more efficient coordination, reduce administrative burdens, and enable more coherent joint risk assessments and emergency planning across Member States. The consolidation into four broader groups aligns with the principle of regional solidarity and acknowledges the growing role of LNG terminals in mitigating supply risks. Gas Networks Ireland supports this approach and believes it will enhance the effectiveness of regional cooperation. However, we wish to express our concern regarding the proposed removal of the United Kingdom (UK) from the updated risk group framework. While the UK is no longer an EU Member State, it remains a critical partner in the European gas network. The UKs infrastructureincluding the Moffat interconnector, which supplies gas to Irelandplays a strategic role in the security of supply for Ireland and other EU countries. The exclusion of the UK from formal risk group structures risks undermining the integrity of regional risk assessments and emergency response planning. Irelands gas supply is uniquely dependent on imports via the UK, and any disruption in UK infrastructure or policy decisions could have direct and immediate consequences for Irish consumers and industries. The absence of the UK from the risk group framework may hinder the ability of Ireland and the EU to conduct comprehensive joint risk assessments and to coordinate emergency measures effectively. GNI urges the Commission to consider mechanisms for continued engagement with the UK on gas supply security, potentially through observer status, bilateral agreements, or inclusion in relevant risk group activities. Maintaining a working relationship with the UK is essential to safeguarding the energy security of Ireland and ensuring the robustness of the EUs overall risk management strategy. Gas Networks Ireland supports the Commissions efforts to modernise and simplify the regional risk group framework. We believe the proposed reduction in the number of groups will enhance coordination and preparedness. However, we strongly recommend that the Commission revisit the exclusion of the United Kingdom and explore avenues for its continued involvement in regional risk assessments and emergency planning. With the requirement to complete the revised Common Risk Assessments (CRAs) based on the updated risk group structure by October 2026, GNI believes that its ability to participate in this procedure without the United Kingdom will be severely hampered and the results will not accurately reflect GNIs concerns. GNI remains committed to working with the Commission and its European partners to ensure a secure, resilient, and sustainable gas supply for Ireland and the wider EU.
Read full responseMeeting with Cynthia Ní Mhurchú (Member of the European Parliament)
5 Mar 2025 · Gas
Gas Networks Ireland calls for incentives to develop hydrogen valleys
15 Aug 2023
Topic — Strategic priorities to double Hydrogen Valleys and achieve 2030 renewable hydrogen targets.
Message — The organization advocates for developing hydrogen clusters around industrial hubs connected by dedicated pipelines. They recommend repurposing existing gas networks to ensure energy resilience and wider access for end-users. Additionally, they suggest introducing financial incentives to encourage new entrants to the hydrogen sector.123
Gas Networks Ireland Urges Support for Gas-Fired Power Flexibility
22 May 2023
Topic — The EU is revising electricity market rules to enhance resilience and reduce gas price impacts.
Message — GNI believes gas networks play a vital role in providing flexibility to the electricity system. They argue that gas-fired generation must be incentivised to provide vital back-up. They also state that investment in existing and new gas infrastructure is critical.123
Impact — Renewable storage developers lose investment momentum if policy prioritizes gas as the primary backup.6
Meeting with Billy Kelleher (Member of the European Parliament)
7 Mar 2023 · ERBD / Gas Policy
Gas Networks Ireland calls for flexible methane emission regulations
13 Apr 2022
Message — GNI requests a proportional approach to avoid high costs and ensure flexibility. They advocate for voluntary quantification until monitoring technologies mature. The group seeks leak repair timelines that respect technical and administrative constraints.123
Why — Flexibility and voluntary reporting would reduce their financial and administrative compliance burdens.4
Impact — Environmental groups lose faster emission reductions due to voluntary monitoring and delayed repairs.5
Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU
30 Mar 2022
Gas Networks Ireland (GNI) welcomes the opportunity to provide feedback on this Proposal and agrees with the main objectives of this revision, believing that to meet such ambitious targets, greater focus should be set on optimising the use of existing energy infrastructure, e.g. the gas grid.
Though full electrification is seen as the vehicle to deliver such objectives, GNI believes that it would be a mistake to exclude the natural gas network from the conversation or to limit its contribution towards meeting the 2030 and subsequent 2050 targets. Natural Gas can support our transition to cleaner energy in a phased process.
Step 1.
Replacing inefficient oil boilers with high efficiency (hydrogen ready) gas boilers can produce immediate energy improvements and reduce carbon emissions by 20%. Combining with smart controls and other sustainable technologies allow us to reduce carbon emissions, improve energy efficiency and still meet the renewable objectives of the recast directive.
Step 2.
Promoting and developing biomethane (renewable gas) in the gas network to decarbonise it will enable the further reduction of CO2 emissions displacing existing fossil gas with environmentally friendly renewable gas. These benefits can be realised without changing building appliances or carrying out expensive and invasive deep retrofits of building fabric. 300,000+ houses on oil heating are located close to the Irish gas network representing a low cost and future proofed pathway to improve overall energy performance.
A study on ‘Decarbonising Domestic Heating in Ireland’, determined that using biomethane in the gas network is the lowest cost way of decarbonising heat for homes, connected to or close to the gas network (one third of the cost of electrification alone). By supporting the development of renewable gas, the EU can aid energy affordability.
Step 3.
The introduction of Hydrogen or Hydrogen blend into European gas networks in the next 10 years represents an opportunity for natural gas networks to drive a reduction in carbon emissions, without incremental costs for the homeowner or business.
GNI agrees with the “energy efficiency first principle” and the focus on “waste heat” proposed in the ‘Energy System Integration’ Strategy. Energy efficiency is mainly considered in terms of building fabric improvements, however co-generation from high efficiency industrial applications and district heating schemes offers substantial efficiency gains. Efficiency gains from renewable and decarbonised gases with other technologies, will amplify the benefits to the overall energy system.
The revised EPBD must ensure cost-efficient reduction of direct and indirect fossil CO2 emissions, as requested by the Energy Efficiency First Principle. Policy makers should be aware of risks with recommending invasive, expensive retrofit policies in situations where the usage of the building or its fabric may not be suitable. The upfront costs of undertaking expensive home upgrades may be a deterrent for many end users and may result in no action being taken (noting the green wave will be accompanied by the waste wave). Whereas a low-cost replacement of an oil boiler with a hydrogen ready gas boiler, can provide long term environmental benefits at a much lower cost and may have a better chance of being undertaken by the homeowner.
Innovative solutions are required across all sectors and energy carriers to increase energy efficiency. Uncertainty will exist on the development of key technologies and whether some can be scaled, and costs made competitive. It is important therefore, not to rule out any technologies at an early stage. All technology options should be treated equally and evaluated in terms of energy efficiency and decarbonisation potential and costs. Evaluation of business cases should be carried out on a system-wide basis and consider the investment required in electricity and gas networks to facilitate deployment and integration into energy systems.
Read full responseMeeting with Thierry Breton (Commissioner) and Eurelectric aisbl and
11 May 2021 · Pact for Skills roundtable with the renewable energies ecosystem sector
Meeting with Nicolas Schmit (Commissioner) and
11 May 2021 · Pact for Skills roundtable with the renewable energies ecosystem sector.
Response to Revision of EU rules on Gas
10 Mar 2021
Gas Networks Ireland (GNI) welcomes the opportunity to provide feedback on this consultation. 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. This average share is higher for some Member States, including Ireland (at 31% in 2020), that have a higher dependency on their gas network from an energy security of supply perspective.
GNI agrees with the need to support a range of renewable and decarbonised gases and abatement to enable achievement of a net zero target. In terms of hydrogen, we welcome the creation of “a new framework for an internal hydrogen market”. GNI believes that hydrogen should be incorporated into the existing gas legislative framework, which has successfully delivered a competitive, integrated and secure gas market.
The EC’s Hydrogen Strategy calls for “an open and competitive EU hydrogen market, with unhindered cross-border trade”. We believe that gas TSOs are well placed to enable the development of the hydrogen backbone required to deliver this ambition. The 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 set out in the 2030 Climate Target Plan. This approach leverages the combined extensive experience of gas TSOs in terms of safe and efficient operation of the gas market over many years and the storage potential of the gas network. We believe gas TSOs 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, as outlined, subject to appropriate conditions.
GNI believes that gas TSOs should play a key role in development and operation of hydrogen storage, which will be key to (a) maintain stability of hydrogen gas networks, (b) via hydrogen for power generation, maintain stability for electricity networks and (c) provide overall national security of supply. As an island nation, hydrogen storage infrastructure, including port terminal facilities for import and export of hydrogen will be particularly important for Ireland’s future security of supply.
GNI 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.
We welcome coordination “with other initiatives emanating from the EU Green Deal relevant for the decarbonisation of gas”, including, the upcoming revised RED II. Classification of renewable and low carbon gases will be key, as it will form the basis for an EU wide guarantees of origin system, to be compatible with the ETS. This compatibility would enable developers of renewable and low carbon production to monetise the sustainability benefits of their projects and help promote uptake of renewable gases in sectors such as heat, industry and transport.
GNI believes that the only viable option to deliver on the ambition set out in the EC’s Energy System Integration and Hydrogen strategies 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.
Read full responseResponse to Revision of the guidelines for trans-European Energy infrastructure
9 Feb 2021
Gas Networks Ireland (GNI) welcomes the opportunity to provide feedback on the draft TEN-E Regulation. We believe that gas infrastructure can and should be leveraged to deliver a ‘Just Transition’ at least cost, whilst maintaining economic growth. That said, any amendments to the Regulation should consider the implications for Ireland following Brexit.
Security of Supply Considerations:
Among the provisions in the draft Regulation is to “exclude natural gas infrastructure but include hydrogen, P2G and smart gas grids”. The preamble to the draft Regulation states that “all Member States will have access to at least three gas sources”. Natural Gas is currently supplied to the Republic of Ireland (ROI) from one indigenous source, and via interconnection with the UK. The role of gas interconnection is particularly important considering that, with the expected fall in indigenous production in the future, Ireland is likely to be primarily reliant on one gas source from the UK, a third country. Furthermore, Ireland is no longer directly interconnected with another Member State which leaves Ireland in a very unique position compared to other EU Member States. Consequently, Ireland will not meet the ‘N-1 Infrastructure Standard’ as specified in Regulation (EU) 2017/1938 concerning measures to safeguard the security of gas supply. GNI believes that the TEN-E Regulation should take account of Ireland being an island EU Member State which has specific security of supply considerations post Brexit.
Cross Border Criteria Considerations:
The cross-border criteria for PCI projects in the draft Regulation, as it currently stands, will make it difficult if not impossible for projects in Member States which have limited interconnection, including ROI projects, to qualify for PCI status. In its current form, the draft Regulation could exclude projects that contribute substantially to EU energy and climate targets (through the deployment of renewable and low carbon gases), even though these projects could be key components of priority corridors and thematic areas. The new provisions in Article 4(2) concerning Projects of Mutual Interest (PMIs) do not overcome the inability of ROI projects to meet the cross-border criteria post Brexit, as PMIs are also required to bring significant benefits to at least two Member States.
We believe that the proposed cross-border criteria, set out in Article 4, should be broadened so that any project which is necessary for at least one of the energy infrastructure priority corridors and thematic areas should be eligible for PCI status. The corridors themselves are, by definition, a cross-border concept and any project which contributes to the development of corridors and/or thematic areas is, in GNI’s view, consistent with the intent of the Regulation and fully aligned with the European Commission’s Energy System Integration and Hydrogen Strategies.
GNI welcomes the addition of a ‘priority thematic areas’ and ‘infrastructure categories’ for smart gas grids, hydrogen and electrolysers. However further clarification is sought as to how electrolysers, biomethane injection points and similar projects, which are unlikely to have a cross-border component, can be eligible for PCI status; we believe they should be eligible once the project sufficiently demonstrates that it is an essential part of a priority corridor or thematic area.
In the context of the establishment of priority corridors for hydrogen and electrolysers, GNI welcomes the inclusion of Ireland in the ‘HI West’ group. However, we have some concerns as to how this will work in practice, and how ROI projects will be accounted for given the cross-border criteria issues identified above. GNI proposes that Ireland, as a Member State, should have a virtual link-in to the hydrogen priority corridors across other EU Member States following Brexit, in order to allow Ireland to develop PCI projects which form part of the HI West hydrogen backbone.
Read full responseMeeting with Seán Kelly (Member of the European Parliament)
11 Jan 2021 · TEN-E Regulation
Gas Networks Ireland Urges Inclusion of Gas Grid Blending
16 Dec 2020
Message — GNI requests including gas grid blending and phased conversions as transitional activities. They advocate for lower hydrogen emission savings and higher limits for gas-fired power. Biomethane should be categorized as fully sustainable to respect existing energy laws.123
Why — This allows GNI to utilize existing assets while avoiding exclusion of specific technologies.45
15 Dec 2020
Gas Networks Ireland (GNI) welcomes the opportunity to provide feedback on the forthcoming Trans-European transport network (TEN-T) - revised guidelines.
GNI agrees that “The current provisions of the TEN-T Regulation are insufficient to ensure an all-encompassing infrastructure basis for the achievement of the 2050 climate neutrality objective.”
The 2030 Climate Plan by the European Commission has increased the 2030 emission target from -40% to -50%. The increased EU emission reduction targets means that the mobility sector must accelerate its actions to meet these increased targets and this should be reflected in the TEN-T guidelines. As mentioned in the Inception Impact Analysis the current guidelines are insufficiently aligned with new transport developments and needs. The new guidelines should act as a driver in the development of infrastructure necessary to support the adaptation of zero / low emission fuel sources.
Compressed Natural Gas (CNG) is a lower carbon fuel alternative to diesel for heavy goods vehicles (HGVs) and buses. HGVs are responsible for approximately a quarter of CO2 emissions from road transport in the EU and for some 6% of total EU emissions . Decarbonisation of HGVs is particularly challenging as electricity is currently not a viable alternative to diesel. CNG has the potential to address these transport emissions with reduced carbon emissions relative to diesel. When the production of renewable gas is increased on the gas network, and this gas is utilised by CNG vehicles as bio-CNG, carbon neutral transport can be achieved. In addition to reduced carbon emissions, CNG also provides improved air quality with 95% less particulate matter and 70% Nitrogen Oxide relative to diesel . The refuelling times for CNG vehicles are comparable to diesel and petrol with similar travel ranges. As CNG stations are connected directly to the gas network, there is always a consistent and secure fuel supply.
GNI welcomes the inclusion of Problem 1A; “inappropriate rollout of infrastructure for recharging and refuelling affects the market take up of zero and low emission vehicles and the transition to overall zero emission vehicles for road transport by 2050.” This is a barrier to facilitating further development of gas in transport and decarbonisation of the mobility sector.
The use of renewable gas in transport through biomethane is an opportunity to reduce GHG emissions across various sectors. Greater investment in renewable gas and CNG infrastructure would facilitate utilisation of waste from agriculture and other waste sectors in transport solutions. CNG vehicles can be run on 100% biomethane without compromising performance thus offering a sustainable mode of transport that supports the circular economy. Infrastructure development for CNG in Ireland has already commenced, with 14 fast fill CNG stations being installed across the Core TEN-T road network via a project called the Causeway Study that is supported by the European Commission through the CEF Transport Fund and the Commission for Regulation of Utilities (CRU). The revision of guidelines presents an opportunity to aid greater development in this area by creating conditions which incentivise the adoption of sustainable technologies that offer impactful benefits in emission reduction.
Read full responseResponse to Monitoring and reporting of Light Duty Vehicles (LDVs)
14 Dec 2020
Gas Networks Ireland (GNI) welcomes the opportunity to provide feedback on the CO2 vehicle emissions – monitoring and reporting data on cars and vans (update). Emission targets increased under the Climate Action Plan 2030 from -40% to -55%. This requires the mobility sector to accelerate its efforts to reduce emissions. GNI supports a more comprehensive approach to emission measurement as outlined in Regulation (EU) 2019/631.
GNI welcomes the collection of “data on the real-world fuel or energy consumption of passenger cars and light commercial vehicles that are recorded by on-board fuel and/or energy consumption monitoring devices” under Regulation (EU) 2019/631. This incentivises manufacturers to produce zero / low emission vehicles, but it does not reflect the full reality of emissions as this measurement is solely based on tailpipe emissions. This partial measurement undermines the impact of CNG and biomethane in transport. Under Regulation (EU) 2019/631, Bio-CNG vehicles are classified as fully fossil vehicles. In reality, Bio-CNG vehicles are environmentally friendly with low Greenhouse Gas (GHG) emissions, and in some cases, negative GHG emissions . On a Well to Wheel (WTW) basis, emissions reductions from CNG HGVs range from 12% to 20% relative to diesel . Higher GHG emissions savings are achievable under specific conditions, loads and vehicles etc. In contrast, battery Electric Vehicles (EV) that are powered by the EU electricity grid are classified as zero emission vehicles even though the current EU electricity mix relies on close to a 50% contribution from fossil energy sources . A unified approach to the treatment of biofuels and EVs would reconcile the existing inconsistencies while helping to accelerate emission reductions in the EU.
GNI wishes to highlight some considerations around CO2 emission measurement. Regulation (EU) 2019/631, requires manufacturers to collect and report emission data from new vehicles using direct data transfer or when a vehicle is serviced or repaired. This form of measurement relies on tailpipe CO2 emissions, a tank-to-wheel approach (TTW). This approach is misleading when comparing different transport decarbonisation solutions. Introducing more comprehensive emission measurement mechanisms such as a WTW approach is necessary to accurately assess the impacts of different fuel options. The key benefit of a WTW approach to calculate CO2 emissions is that it will ensure a technology-neutral approach. A WTW approach guarantees a fair and complete evaluation of the decarbonisation effect among different solutions. This approach can boost the introduction of renewable energy solutions into the transport sector in a cost-effective manner. CNG and Bio-CNG will maximise the use of existing gas energy infrastructure, ensuring a least cost approach to achieving a cleaner transport energy future.
GNI agrees that “The monitoring and reporting of data on passenger cars and light commercial vehicles registered in the Union are essential for the functioning of the CO2 emission performance standards set out in Regulation (EU) 2019/631”.
A level playing field across technologies will help efforts to reduce GHG emissions across the EU mobility sector as the impact of biomethane and biofuels are fully accounted for. It would incentivise greater uptake of these technologies. Biomethane can play a key role in decarbonisation of the mobility sector. The sustainable biomethane production capacity in the EU (from both anaerobic processes and thermal gasification) is estimated to be 124 BCM, which equates to ten times the amount required by current road transport demand. Another benefit of biomethane, in the form of Bio-CNG, is that it is compatible with the current natural gas infrastructure. There are CNG refuelling stations in place in many EU countries and CNG vehicles can use biomethane in the same way as compressed natural gas.
Read full responseResponse to Revision of the CO2 emission standards for cars and vans
26 Nov 2020
Gas Networks Ireland (GNI) welcomes the opportunity to provide feedback on the revision of performance standards of CO2 Emissions for Cars and Vans. Emission targets have been increased under the Climate Action Plan 2030 from -40% to -55%. This requires the mobility sector to accelerate its efforts to reduce emissions.
The current regulation structure encourages moving to zero and low emission vehicles solely based on tailpipe emission measurements. This does not reflect the full reality of emissions. This partial measurement of emissions puts CNG and biomethane at a disadvantage and undermines their impact. Under the present regulations, Bio-CNG vehicles are classified as fully fossil vehicles. The reality is Bio-CNG vehicles are environmentally friendly with low Greenhouse Gas (GHG) emissions, and in some cases, negative GHG emissions . Natural gas is a cleaner alternative to diesel with up to 22% less CO2 emissions on a per unit basis. On a Well to Wheel (WTW) basis, emissions reductions from CNG HGVs range from 12% to 20% relative to diesel. Higher GHG emissions savings are achievable under specific conditions, loads and vehicles etc. The emissions savings benefits of CNG are also substantially higher when compared to Euro V diesel HGVs. In contrast, battery Electric Vehicles (EV) that are powered by the EU electricity grid are classified as zero emission vehicles even though the current EU electricity mix relies on close to a 50% contribution from fossil energy sources . A unified approach to the treatment of biofuels and EVs would reconcile the existing inconsistencies while helping to accelerate emission reductions in the EU.
GNI wishes to highlight some considerations around CO2 emission measurement. Current legislation in relation to transport decarbonisation relies solely upon tailpipe CO2 emissions, a tank-to-wheel approach (TTW). Such an approach is misleading when comparing different transport decarbonisation solutions. Therefore, introducing more comprehensive emission measurement mechanisms such as a WTW approach is necessary to accurately assess the impacts of different fuel options. The key benefit of adopting a WTW approach to calculate CO2 emissions is that it will ensure a technology-neutral approach. The WTW approach guarantees a fair and complete evaluation of the decarbonisation effect among different solutions. This approach can boost the introduction of more renewable energy solutions into the transport sector and, most importantly, in a cost-effective manner. CNG and Bio-CNG will maximise the use of existing gas energy infrastructure, ensuring a least cost approach to achieving a cleaner transport energy future, most notably, for heavy duty/commercial transport, a particularly difficult area to decarbonise.
GNI welcomes the fact that the impact assessment will explore a variety of options including a “specific mechanism to incentivise and preferences zero- and low-emission vehicles” along with exploring “the appropriateness of a new mechanism to take into account the potential contribution of renewable and low-carbon fuel when determining manufacturers compliance with their targets”.
Establishment of a level playing field across technologies will help ramp up efforts to reduce GHG emissions across the EU mobility sector as the real impact of biomethane and biofuels are fully accounted for. It would incentivise greater uptake of these technologies. Biomethane can play a key role in decarbonisation of the mobility sector. The sustainable biomethane production capacity in the EU (from both anaerobic processes and thermal gasification) is estimated to be 124 BCM, which equates to ten times the amount required by current road transport demand. Another benefit of biomethane, in the form of Bio-CNG, is that it is compatible with the current natural gas infrastructure. There are CNG refuelling stations in place in many EU countries and CNG vehicles can use biomethane in the same way as compressed natural gas
Read full responseResponse to Updating the EU Emissions Trading System
24 Nov 2020
Gas Networks Ireland (GNI), and its parent company Ervia, welcome the opportunity to provide feedback on the ‘Climate change – updating the EU emissions trading system (ETS)’ Inception Impact Assessment consultation. We fully agree that the ETS “has proven to be an effective tool in reducing greenhouse gas” and we support the aim to “provide a consistent carbon price signal across the Single Market”. In order to maximise the potential of the ETS to decarbonise the EU economy and deliver a ‘Just Transition’ at least cost, we believe that the review of the ETS should consider the following;
• The ETS should provide certainty to energy market participants and investors regarding the development of carbon pricing. Carbon pricing should develop in an incremental manner, stabilised using the MSR and should avoid any large one-off adjustments.
• In its ‘A Renovation Wave for Europe’ communication the Commission notes that “Inefficient buildings are often synonymous with energy poverty and social problems”. GNI and Ervia believe that it may be premature to extend the ETS into the buildings sector until incentives and supports are in place to deal with energy poverty, particularly in terms of dealing with the worst performing buildings. Gas, including renewable and decarbonised gases, can play a key role in reducing emissions from buildings through the deployment of renewable gas and hybrid (gas and electricity) heating solutions in buildings where deep retrofit is either impractical or prohibitively expensive.
• In terms of the transport sector, we note that Regulation (EU) 2019/1242 setting CO2 emission standards for new Heavy-Duty Vehicles (HDVs) indicates that “the Commission shall, not later than 2023, evaluate the possibility of developing a common Union methodology for the assessment, and the consistent data reporting, of the full life-cycle CO2 emissions of new heavy-duty vehicles”. Failure to incorporate this treatment into the ETS could hinder the development of advanced biofuels, such as bio-CNG, which could play a major role in reducing emissions from heavy transport.
• Guarantees of Origin certificates for renewable and decarbonised gases should be compatible with the ETS – the treatment of renewable and decarbonised gases should be consistent with other GO schemes and should be based on decarbonisation potential and aligned with the revised Renewable Energy Directive.
• The ETS review should assess the possibility of carbon leakage via electricity interconnector flows with adjacent third countries, including the UK. Carbon leakage could undermine the business case for gas generators in adjacent member states which provide back-up to intermittent renewables, and as such are critical in terms of system stability.
• On funding, we agree that “the deployment and scaling up of existing innovative low-carbon technologies will need support, as will research into further innovative solutions”. We propose that revenues raised by the ETS should be invested in the same sectors from which emissions arise, in order to permanently decarbonise these industries. This should include investments in CCUS and hydrogen, which will help decarbonise energy intensive industries, thereby protecting jobs and enabling a ‘Just Transition’.
Renewable electricity is pivotal to decarbonising Europe’s energy sector. The Energy System Integration strategy estimates that electricity will provide c. 50% of Europe’s energy by 2050 (currently 23%). However, even if this projection is reached by 2050, the remaining 50% must also be decarbonised and zero carbon gases (e.g. biomethane and hydrogen) and Carbon Capture and Storage (CCS) are essential to achieve this. The review of the ETS should take account of the industries and sections of society that cannot be electrified and thus are unable to decarbonise and reduce emissions in line with the 2030 Climate Target Plan until key technologies mature and are readily available at the scale required.
Read full responseResponse to Revision of the Renewable Energy Directive (EU) 2018/2001
17 Sept 2020
Gas Networks Ireland (GNI) and parent company Ervia welcome the opportunity to provide feedback on “EU renewable energy rules” Inception Impact Assessment. GNI and Ervia agree with the expressed view that “there is a need to ensure that all sectors fully contribute to decarbonisation”. We also agree that “EU action on renewable energy is necessary because it is more efficient and effective than individual Member States’ actions.” In particular we believe that the EU should set binding targets at EU and Member State level for renewable and low carbon gases, including biomethane and hydrogen, subject to appropriate evaluation of renewable gas potentials.
GNI and Ervia welcome the focus on gaseous energy carriers in the recently announced Energy System Integration strategy and also welcome the ambition of the EC’s Hydrogen strategy. The ambition expressed in these strategies should be reflected in the approach to the review of REDII. We believe that it will be necessary to “amend REDII to translate into legal measures the actions proposed in other energy strategies of the EGD”, i.e. Option 4 as proposed in the Impact Assessment.
The Energy System Integration strategy sets out the requirement for “a comprehensive terminology for all renewable and low-carbon fuels and an EU system of certification, based on full life cycle greenhouse gas emission and sustainability criteria”. We believe that these principles should be extended to the classification of all renewable and low carbon technologies, across all energy carriers. The terminology and classification system developed should form the basis of an EU wide Guarantees of Origin framework.
GNI and Ervia note that the Hydrogen strategy signals “a comprehensive terminology and European-wide criteria for the certification of renewable and low-carbon hydrogen possibly building on the existing ETS monitoring, reporting and verification and the provisions set out in the Renewable Energy Directive”. In relation to the ongoing review of Regulation 2018/2066 on the ‘Monitoring and Reporting of Greenhouse Gas Emissions’ there is an apparent contradiction in the proposed text on the treatment of gases. Article 39(5) of the MRR draft evaluates the treatment of biogas based on calculation of an “average mix” in gas networks, whereas in Article 39(4) bases this on “purchase record of biogas”, providing the basis for Guarantees of Origin. We believe that Article 39(5) and the optionality that this represents could undermine the integrity of a Guarantees of Origin framework and could lead to a fragmented and sub optimal approach in terms of encouraging the development of renewable and low carbon gases. This issue should be clarified in the MRR regulation and REDII should be updated to account for this.
The Hydrogen strategy recognises that “the EU already has the basis for a supportive policy-framework, notably with the REDII and the ETS”. In relation to the ETS, verified Guarantees of Origin certificates from all energy carries should be recognised, to allow for a technology neutral approach.
The Hydrogen strategy commits to exploring “additional support measures, including demand-side policies in end-use sectors, for renewable hydrogen building on the existing provisions of REDII”. While RED II “lays down rules on financial support for electricity from renewable sources”, these rules should be explicitly extended to cover renewable and low carbon gases.
GNI and Ervia believe that a range of innovative solutions is required across all sectors and energy carriers to increase the uptake of renewables. There will be some uncertainty around the development of key technologies, in particular their scalability and potential for cost competitiveness within certain timeframes. Given this uncertainty, it is important not to rule out any technologies at an early stage. All technology options should be treated on an equal basis and evaluated in terms of their decarbonisation potential and costs.
Read full responseResponse to Review of Directive 2012/27/EU on energy efficiency
17 Sept 2020
Gas Networks Ireland (GNI) and its parent company Ervia, welcomes the opportunity to provide feedback on the forthcoming evaluation of the EU Energy Efficiency Directive (EED). GNI and Ervia agree with the view that “efficient use of energy is key to achieve the European Green Deal objectives”. GNI and Ervia also agree that “cost-effective delivery of the EU’s current and future climate ambition” must be a key consideration in the energy transition.
Gas grids can play a key role in the energy transition and in terms of energy efficiency. Smart combinations of existing technologies can yield significant benefits in building energy performance. In Ireland around 37% of households still use oil for heating. By switching to gas and when used in combination with smart controls and other sustainable technologies such as LED lighting and PV panels, significant improvements can be made in energy performance. Using such a combined approach, the carbon intensity of an oil space heating and hot water system in a typical dwelling can be reduced by up to 20% by simply switching from oil to natural gas. GNI is also promoting the increased penetration of biomethane in the network as a means of decarbonising the gas network, which would further reduce the CO2 emissions without the need to change any building appliances or carry out a deep retro-fit. Given that over 300,000 houses which rely on oil heating are located close to the gas network, this represents a low cost and future proofed pathway to improving energy performance.
A KPMG study on ‘Decarbonising Domestic Heating in Ireland’, determined that utilising biomethane within the existing gas network is the lowest cost way of decarbonising heat for homes connected to or in close proximity to the gas network (one third of the cost of electrification alone). By supporting the development renewable gas, the EU can thus aid energy affordability.
Furthermore, GNI and Ervia agree with the “energy efficiency first principle” and the focus on “waste heat” proposed in the ‘Energy System Integration’ Strategy. Energy efficiency is mainly thought of in terms of building fabric improvements, however co-generation from industrial applications and in district heating schemes will offer substantial efficiency gains. As these processes become more and more decarbonised, using renewable and decarbonized gases and other technologies, the effect of these efficiency gains will in effect amplify the benefits to the overall energy system.
In the medium-long term the use of advanced end use applications such as gas absorption heat pumps, hybrid heat pumps and fuel cell technologies can deliver substantial energy savings. Hybrid options can also help balance gas and electricity systems when coupled with smart technologies enabled by the growing digitalisation and integration of gas and electricity networks. Hybrid options can deliver an optimised solution for existing housing stock offsetting some of the cost and disruption associated with deep retrofit of older housing stock.
A range of innovative solutions is required across all sectors and all energy carriers to increase energy efficiency. There will be some uncertainty around the development of key technologies, in particular as to whether certain technologies can be scaled up and costs reduced to competitive levels. Given this uncertainty, it is important not to rule out any technologies at an early stage. All technology options should be treated on an equal basis and evaluated in terms of their energy efficiency and decarbonisation potential, and costs. Evaluation of the business cases for technologies should be carried out on a system-wide basis and consider the investment in electricity and gas networks required to facilitate their deployment and integration into energy systems.
Read full responseResponse to Sustainable and Smart Mobility Strategy
29 Jul 2020
Gas Networks Ireland (GNI) welcomes the opportunity to feedback to the European Commission’s initiative concerning Sustainable and Smart Mobility Strategy.
GNI supports the EU Green Deal objective to deliver a 90% reduction in transport-related greenhouse gas emissions by 2050 to support the EU’s aim to become the first climate neutral continent. A variety of technologies will be needed to shape future sustainable mobility.
In the mobility area, GNI is actively involved in the rollout of Compressed Natural Gas (CNG) infrastructure for gas in transport in Ireland. CNG provides a pathway to the use of biomethane in transport which is a clean, renewable and carbon neutral fuel. The production of biomethane from existing waste streams and a variety of sustainable biomass sources (including grass, animal waste, crop residues and food waste) is sustainable and supports the circular economy.
CNG can form part of a sustainable mobility strategy and help decarbonise heavy good vehicles (HGVs) and buses, where electricity is not a viable alternative to diesel. CNG provides fleet operators with additional choice when decarbonising their fleet and is an established technology ensuring safety and reliability.
Infrastructure development for CNG in Ireland has commenced, with 14 fast fill CNG stations being installed across the Core TEN-T road network via a project called the Causeway Study that is supported by the European Commission through the CEF Transport Fund and the Commission for Regulation of Utilities (CRU). In addition, GNI has received grant approval from the European Commission for a project called Green Connect, running from 2019 to 2023, which includes the installation of an additional 21 public CNG stations along the core road network, 4 direct renewable gas injection facilities and 4 mobile CNG refuelling units as well as a vehicle grant scheme for 400 vehicles.
Biomethane is already being injected into Ireland’s gas grid at an injection facility which was also developed as part of the Causeway Study. When the production of biomethane is increased and utilised by CNG vehicles as bio-CNG, carbon neutral transport can be achieved.
The EU establishment of minimum standards for refuelling infrastructure across the EU to ensure interoperability was a positive development. GNI suggests that consideration is given to the development of EU regulation requiring member states to deliver a mandatory number of LEV refuelling points by a specific date.
Policy support is also required to accelerate the take-up of low carbon technologies such as hydrogen in transport. This would help to promote and normalise the use of non-conventional fuels and technologies such as hydrogen to the general public.
GNI supports the establishment of EU and Member State targets for the production of renewable gases such as hydrogen and biomethane. Both these gases will significantly contribute to decarbonising transport.
GNI would welcome the opportunity to discuss this response in more detail and can provide further information on any of the topics discussed.
Read full responseResponse to EU Strategy on Adaptation to Climate Change
30 Jun 2020
Gas Networks Ireland (GNI) welcomes the opportunity to respond to the European Commission’s (EC) roadmap for a communication on adaptation to climate change. As part of the European Green Deal, we note that the adaptation strategy aims to support the objectives of the EU Climate Law. GNI welcomes the ambition to “recover better” and we share the EC’s drive to improve European resilience as we seek to rebuild our economies following the Covid-19 crisis.
GNI’s vision is for the Irish gas network to be net zero carbon by 2050. Our Vision 2050 strategy confirms that the existing Irish gas network can reduce annual CO2 emissions by 31% in 2050, thus supporting emissions reductions across every sector of the Irish economy at the lowest cost possible.
Imperative to achieving these reductions are innovations such as biomethane, compressed natural gas vehicles, carbon capture and storage and hydrogen. We highlight that biomethane production has the potential to sustain “100,000 – 150,000 direct jobs in agriculture and forestry” in the EU, while also providing efficiencies in land use, and supporting the development of a circular economy.
Throughout the Covid-19 pandemic, Europe’s gas network has been proven as a reliable, secure and critical piece of economic and social infrastructure. Learning from the pandemic, it is essential that a move towards climate proofing investments does not happen at the expense of our energy security. Gas networks offer a solution for delivery of the EU Green Deal, as gas networks can switch from more carbon-intensive energy carriers to low-carbon and renewable gases, such as biomethane or green hydrogen, without extensive network investment for the benefit of society. Notably, renewable gases provide essential back-up to intermittent renewables such as wind and solar energy, by providing flexibility to respond to changing weather patterns.
GNI notes that the European Green Deal adaptation strategy should aim to help all levels of government and stakeholders to: “accelerate action with a focus on solutions (in addition to understanding), on deploying innovation (in addition to research), on implementation (in addition to planning), and on prevention (in addition to ex-post).“ In relation to deploying new innovations to accelerate action on climate adaptation, GNI suggests that technologies/innovations are compared on the basis of all associated costs. For example, some methodologies do not account for additional infrastructure required to support the scale-up of renewables (e.g. grid infrastructure), and so do not reflect the true cost of some electricity based technologies, making them appear inexpensive compared to low or zero-emission gas technologies.
GNI has implemented an award winning Biodiversity Enhance Programme across its business. As part thereof, we support the All-Ireland Pollinator Plan, contribute to Ireland’s efforts to meet the United Nation’s Sustainable Development Goals target, and utilise our large asset base for creating a network of pollinator-friendly habitats nationwide. In relation to increasing climate awareness, it would be useful for the European Commission to provide biodiversity guidance/standards on how business can participate in protecting, restoring and improving biodiversity. Having a standard that businesses could work towards and that businesses could gain certification for would be a welcome inclusion in the Climate Adaptation communication to the Parliament. For example, in Ireland businesses can sign up as a business supporter to the All-Ireland Pollinator Plan but all businesses can sign up as supporters no matter how big or small an effort they make with regards to supporting the plan. It would be useful if there was recognised biodiversity standards that businesses could achieve certification for to demonstrate their commitment to biodiversity.
Read full responseResponse to A EU hydrogen strategy
5 Jun 2020
Gas Networks Ireland (GNI) welcomes the opportunity to provide feedback on the “EU Hydrogen Strategy” Roadmap consultation. In particular GNI welcomes the scale and ambition of the proposed strategy including support for “the deployment of renewable hydrogen (also referred as ‘green’)” and “the production of low-carbon hydrogen (also referred as ‘blue’) based on natural gas, combined with carbon capture and storage (CCS) technologies”. This approach will allow the scale up of the hydrogen economy whilst maintaining security of supply.
GNI agrees that hydrogen can play a key role in mobility and industry, however GNI believes that hydrogen can contribute to the decarbonisation of all sectors of the economy, thus playing a key role in Next Generation EU. In particular hydrogen can play a key role in heating homes and small businesses connected to gas distribution networks. Gas distribution networks in many member states are constructed using polyethylene pipes which are well suited to the distribution of hydrogen. Furthermore the rollout of hydrogen for industrial applications and for the purposes of sector coupling between gas and electricity 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, hybrid options can lower costs associated with reinforcement of electricity grids and allow arbitrage between hydrogen and electricity to deliver energy to the end user at lowest costs. The rollout of hydrogen represents a ‘least regrets’ pathway to decarbonisation of heat as new gas appliances could be mandated to be ‘hydrogen ready’ in advance of rollout.
In order to maintain the benefits of the Internal Energy Market (IEM), GNI recommends that existing EU gas legislation is extended to hydrogen (and CO2 networks required for Blue Hydrogen). Non-discriminatory third-party access to hydrogen networks is essential to guarantee a level playing field between producers and users and to preserve the integrity and further develop the IEM.
A regulatory sandbox 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 / DSOs invest, particularly where no other investors are present. Any such arrangements could be subject to appropriate exit criteria for TSOs / 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. GNI recommends the following actions to scale up clean hydrogen;
• Establish targets for renewable and decarbonised gases at EU and Member State level and mandate Member States to develop national hydrogen plans.
• Ring-fencing funds derived from the ETS and directing those funds towards R&D and innovation in key technologies such as Power to Gas and CCS.
• Extend remit of the Trans-European Network for Energy (TEN-E) Regulation to cover decarbonised gases and CO2 networks, providing funding for their development.
• Ensure that appropriate incentives are applied to electricity exit and gas entry tariffs to promote sector coupling and hydrogen production and remove barriers such as the double charging of gas and electricity tariffs
• Develop an EU wide Guarantees of Origin framework, establishing a clear classification system for renewable and decarbonised gases.
• Encourage gas TSOs / DSOs and technical standards bodies to evaluate grid adaptation requirements for existing networks for dedicated hydrogen networks and networks blending hydrogen with natural gas.
Read full responseResponse to Commission Communication – "Renovation wave" initiative for the building sector
5 Jun 2020
Gas Networks Ireland (GNI), and its parent company Ervia, welcomes the opportunity to provide feedback on the ‘Energy efficiency in buildings – consultation on ‘renovation wave’ initiative’. GNI recognises that in light of the Covid 19 crisis that the EU’s ‘Green Deal’ can aid the recovery of the EU Economy whilst also setting Europe on the pathway to sustainability. The planned ‘Renovation Wave’ should focus on the least cost and least disruptive technologies required to deliver the EU’s climate and energy targets.
Gas grids can play a key role in the energy transition and in terms of the renovation wave. Smart combinations of existing technologies can yield significant benefits in building energy performance. In Ireland around 37% of households still use oil for heating. By switching to gas and when used in combination with smart controls and other sustainable technologies such as LED lighting and PV panels, significant improvements can be made in energy performance. Using such a combined approach, the carbon intensity of an oil space heating & hot water system in a typical dwelling can be reduced by up to 23% by simply switching from oil to natural gas. GNI is also targeting a 20% penetration of renewable biomethane in the gas network by 2030, which would further reduce the CO2 emissions without the need to change any building appliances or carry out a deep retro-fit. Given that over 300,000 houses which rely on oil heating are located close to the gas network, this represents a low cost and future proofed pathway to improving energy performance.
In 2019 GNI published our ‘Vision 2050’ strategy where we set out our ambition for a net zero carbon gas network by 2050, via four pillars: Carbon Capture & Storage (CCS), Biomethane, Hydrogen and Compressed Natural Gas. In doing so, the Irish gas network will support emissions reductions across every sector of the economy at least cost. The volume of renewable gas and hydrogen in the gas network can increase over time, potentially reaching 50% by 2050.
A KPMG study on ‘Decarbonising Domestic Heating in Ireland’, determined that utilising biomethane within the existing gas network is the lowest cost way of decarbonising heat for homes connected to or in close proximity to the gas network (one third of the cost of electrification alone). By supporting the development renewable gas, the EU can thus aid energy affordability.
In the medium-long term the use of advanced end use applications such as gas absorption heat pumps, hybrid heat pumps and fuel cell technologies can deliver substantial energy savings. Hybrid options can also help balance gas and electricity systems when coupled with smart technologies enabled by the growing digitalisation and integration of gas and electricity networks.
Regarding the use of revenues raised in the ETS sector, we propose that these revenues should be invested in the same sectors from which emissions arise to permanently decarbonise these industries. This should include investments in CCUS and hydrogen, which will help decarbonise energy intensive industries, thereby protecting jobs and enabling a ‘Just Transition’. This will enable the EU to maintain its position as a global leader in clean industries.
A range of innovative solutions is required across all sectors and all energy carriers to increase energy efficiency. There will be some uncertainty around the development of key technologies, in particular as to whether certain technologies can be scaled up and costs reduced to competitive levels. Given this uncertainty, it is important not to rule out any technologies at an early stage. All technology options should be treated on an equal basis and evaluated in terms of their decarbonisation potential and costs. Evaluation of the business cases for technologies should be carried out on a system-wide basis and consider the investment in electricity and gas networks required to facilitate their deployment and integration into energy systems.
Read full responseResponse to Union renewable Financing mechanism
2 Jun 2020
Gas Networks Ireland (GNI) welcomes the opportunity to respond to the proposed Renewable Energy Financing Mechanism (‘the Mechanism’).
GNI supports the EU objective of achieving net-zero greenhouse gas emissions by 2050. Our vision for Ireland’s gas network is to be net zero carbon by 2050. Transitioning to a climate neutral economy will be challenging and requires new infrastructure to enable integration of more renewables. As such, we welcome this tool to encourage investments in renewable energy projects across Europe.
We support that the Mechanism should “facilitate Member States with the opportunity to increase the sectoral share of renewable energy in the electricity, heating and cooling, and transport sector” by reducing the capital cost of renewable energy projects through grants and low interests loans, awarded based on increases in renewable energy capacity/production following a competitive process.
On renewable targets, GNIs view is that any projects built in Ireland should contribute towards Ireland’s targets. If not, such projects risk taking the place of another project that could contribute to national targets.
Renewable & Low Carbon Gas
GNI is concerned that renewable and decarbonised gases may not be eligible for funding under the proposed Mechanism. Our concern arises from the definition of renewable energy in article 2.1 of Directive (EU) 2018/2001: “energy from renewable sources’ or ‘renewable energy’ means energy from renewable non-fossil sources, namely wind, solar (solar thermal and solar photovoltaic) and geothermal energy, ambient energy, tide, wave and other ocean energy, hydropower, biomass, landfill gas, sewage treatment plant gas, and biogas”
EUs gas network provides a least cost way to decarbonise heating and power generation and cost effective solutions for other sectors. GNIs Vision 2050 strategy confirms that the existing Irish gas network can reduce Ireland’s overall annual CO2 emissions by 31% by 2050. Imperative to achieving these reductions are innovations such as biomethane, compressed natural gas vehicles, carbon capture and storage and hydrogen. We highlight that transition fuels and projects should remain eligible for EU funds to enable member states reach the goal of the EU Green Deal.
Renewable gases, including hydrogen and biomethane, are suitable for a wide range of applications currently served by gas, as recognised in the New Industrial Strategy for Europe and the establishment of a new European Clean Hydrogen Alliance. The EC’s report ‘Potentials of sector coupling for decarbonisation’ explains how renewable and decarbonised gases such as biomethane and hydrogen could be “transported and stored at lower cost than electricity”. Utilising the gas infrastructure may also “avoid potentially costly and disruptive changes to end-use appliances.”
The EU is a forerunner in renewable and decarbonised gas technology development. Significant employment and financial opportunities arise from supporting its scale up. GNI strongly recommends that the Mechanism is structured so that hydrogen investments will be eligible for funding.
Supporting New Technologies
We welcome that the Mechanism adopts a neutral approach to new renewable technologies. Electrification, wind energy, renewable gas, carbon capture and storage, hydrogen, and biomethane will all need to grow for the EU to achieve its renewable targets.
We note the plan to award funds “based on the lowest price” but welcome scope to apply diverging criteria in the case of demonstration projects. GNI suggests that the EU adopts a Total Systems Cost approach whereby technologies are compared on the basis of all associated costs. Some methodologies do not account for additional grid infrastructure required to support increased renewables, and so do not reflect the true cost of some electricity based technologies making them appear inexpensive compared to low or zero-emission gas technologies.
Read full responseGas Networks Ireland urges clear definitions for ESG benchmarking
5 May 2020
Message — GNI suggests including all relevant ESG definitions to ensure consistent ratings. They propose comparing technologies on a consistent Life-Cycle Assessment basis.12
Why — Standardised rules would validate gas infrastructure assets and ensure continued investment flows.34
Gas Networks Ireland seeks inclusive climate benchmark standards
5 May 2020
Topic — New EU rules for standardising climate transition and Paris-aligned financial investment benchmarks.
Message — GNI proposes that gas operators qualify for benchmarks by reducing emissions. They argue current revenue limits exclude companies transitioning to renewable fuels.12
Why — This would secure investment for their transition to renewable gas and hydrogen.3
Response to Climate Law
27 Apr 2020
As expressed in our response to the roadmap on Climate Law, Gas Networks Ireland (GNI), and its parent company Ervia, supports the European Union objective of achieving net-zero greenhouse gas emissions by 2050. As an essential step in this process we welcome the publication of the proposed regulation to enshrine EU’s climate ambition into law.
GNI’s vision for Ireland’s gas network is to be net zero carbon by 2050. Transitioning to a climate neutral economy will be challenging as a balance between sustainability, security and affordability must be achieved. Using existing assets and capabilities will achieve these aims earlier, offering the potential to achieve a smoother and more sustainable transition. We highlight that Europe’s gas network provides a least cost pathway to decarbonise heating and power generation and will provide cost effective solutions for other sectors. In the short term, the displacement of more carbon intensive fuels such as coal and oil by natural gas can have an immediate impact.
In relation to article 2.1, we note that negative emissions will be needed to achieve net-zero emissions. This can be achieved in electricity generation by utilising bio-energy with CCS. Negative emissions can then be used to compensate for emissions in sectors that are more challenging and expensive to decarbonise, such as agriculture, heating and transport.
GNI agrees with the proposal to review member states’ progress every five years as suggested under article five. We recommend that such reviews should be extended to individual sectors, including gas, to ensure that they make the necessary contribution towards climate targets. Binding targets should be set at EU and member state level for renewable and decarbonised gases in gas grids, subject to an appropriate evaluation. This will help the decarbonisation of difficult sectors such as heat and industry, and help achieve the energy transition in a cost efficient manner, whilst safeguarding jobs and achieving a ‘Just Transition’.
In the medium term, innovation and further integration of the EU internal energy market will be needed to reach the 2050 target (as is recognised under observation (6) page 10). In relation to the proposed article 3.3(c), we recommend that the EU Commission adopts a neutral approach to assessing new technologies. GNI maintains that technologies should be comparable on a consistent Life-Cycle Assessment (LCA) basis and none can be excluded from an LCA obligation. Furthermore, we propose that a ‘Total System Cost of Abatement’ approach is adopted when assessing zero-emission technologies. Marginal Abatement Cost Curves and Levelised Cost of Energy do not account for the additional grid infrastructure required to support increased renewables. Therefore, they do not reflect the true cost of some electricity based technologies and can make them appear inexpensive in comparison to low or zero-emission gas technologies. It is the view of GNI that sustainability criteria should be evidence-based and not assumed when it comes to assessing new technologies.
GNI welcomes the inclusion of ‘energy efficiency, energy affordability and security of supply’ and ‘competitiveness of the Union’s economy’ as important considerations under article 3.3.
As for the proposed amended article 11 of Regulation (EU) 2018/1999, we propose that energy partners are specifically mentioned as critical participants in multilevel climate and energy dialogues.
Finally, it is essential that economic stimulus packages, as well as regulatory frameworks and wider EU policies, support the trial and commercialisation of new and innovative technologies such as electrification, natural gas with carbon capture and storage, renewable gases (e.g. hydrogen and biomethane) and renewable electricity; all of which will play significant roles in Europe’s energy system in 2050.
Read full responseGas Networks Ireland urges inclusion of renewable gas in taxonomy
17 Apr 2020
Message — GNI requests that gaseous renewable energy, such as biomethane and hydrogen, be comprehensively included. They argue gas network investments supporting these sources should be deemed valid and eligible. Furthermore, all technologies should be assessed using a consistent life-cycle approach.123
Why — This classification would ensure investment flows toward GNI's gas infrastructure and renewable projects.45
Impact — Mineral fertilizer producers would lose market share to sustainable organic bio-fertilizer alternatives.6
Response to Revision of the Energy Tax Directive
30 Mar 2020
Gas Networks Ireland (GNI), and its parent company Ervia, welcomes this opportunity to provide feedback on the roadmap to revising the Energy Taxation Directive. Having reviewed the impact assessment, GNI makes the following observations.
Overall, GNI agrees that the Directive needs updating to actively support delivery of the European Green Deal. Equally, GNI welcomes 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.
As part of this review, in particular removal of existing subsidies for fossil fuels, GNI urges caution to ensure that unintended impacts on security of supply do not occur. Careful consideration must be given to the potential impact on power generation capacity remuneration which could result in a withdrawal of existing power plants from the market, thus negatively affecting EU security of supply. For example, capacity remuneration mechanisms ensure that thermal power plants are on standby to provide back-up to intermittent renewable energy sources. GNI asks the Commission to carefully consider how the EU will maintain security of supply and incentivise decarbonised thermal generation to support intermittent renewables.
To overcome the challenge above, GNI commends that the revised Directive is designed to actively support the scaling of capacity within EU energy networks and the development of new technologies rather than solely looking at the removal of supports. In particular, GNI wishes to highlight the opportunity for the Directive to support the development and commercialisation of technologies such as hydrogen, carbon capture and storage (CCS), clean energy, compressed natural gas (CNG) & bio CNG for heavy duty vehicles. To ensure continued security of supply, and to accelerate delivery of the EU Green Deal, GNI proposes that all additional taxation revenues collected following the review be ring fenced and reinvested in the development of new energy technologies.
In relation to the rules for taxation of energy used in motor fuel, GNI notes that Regulation (EU) 2019/1242, setting CO2 emission standards for new heavy duty vehicles, indicates that “the Commission shall, not later than 2023, evaluate the possibility of developing a common Union methodology for the assessment, and the consistent data reporting, of the full life-cycle CO2 emissions of new heavy-duty vehicles”. GNI stresses the need to expedite the establishment and adoption of a Life Cycle Assessment methodology (replacing tailpipe emissions) in all EU legislation related to clean vehicles and CO2 standards. This treatment should be reflected in the Tax Directive to ensure greenhouse gas savings are calculated in a non-discriminatory way across all technology options, including renewable biofuels which comply with RED II.
Finally, GNI highlights the importance of the revised Directive’s role in avoiding significant increases in energy costs, which would negatively impact the competitiveness of the European economy. GNI welcomes the inclusion of a social impact assessment in the roadmap and asks that social consequences continually be considered in further consultation rounds. To minimise the negative impact on consumers from rising energy prices, GNI proposes 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 and decarbonised gas provides 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.
Read full responseResponse to Carbon Border Adjustment Mechanism
30 Mar 2020
Gas Networks Ireland (GNI), along with its parent company Ervia, welcomes the opportunity to provide feedback on the “EU Green Deal – Carbon Border Adjustment Mechanism.” GNI 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, GNI makes the following observations:
1. ‘Growth strategy impacts on innovation and research – opportunity for growth of green technologies
GNI 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. GNI acknowledges this growth strategy and notes 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 and 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 that utilises 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, GNI supports the view that:
• Gases such as natural gas, biomethane and 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 and 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 - Incentivising trade partners towards climate ambition
The EU Green Deal identifies the importance of “partnerships with industry and Member States” and the European Commission proposes to work strategically with sector partners to raise global ambition in respect of climate. Incentivising trade partners to decarbonise through the border adjustment will have an impact on global CO2 emissions. It may also provide the platform for the EU to become a leader in key technologies which enable 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 requirements in their production processes. GNI proposes that revenues recouped as a 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.
Read full responseResponse to Fast-track interservice consultation on the 'SEIP including a JTM and the JTF"
12 Mar 2020
Gas Networks Ireland (GNI) and its parent company Ervia welcome this opportunity to provide feedback on the European Commission’s Just Transition Mechanism proposal. Having reviewed the proposal, we make the following key observations:
1. Prioritising Least Cost & Least Disruptive Technologies
GNI fully supports the ambition of achieving a net carbon zero EU by 2050. We note that all sectors play their part, and that the solution to the climate challenge will require the deployment of many different technologies. As a guiding principle, we recommend that the green transition and new technologies be considered in economic as well as environmental terms.
• To ensure a successful transition while also protecting the competitiveness of the European economy and the disposable income of citizens, it is essential that the least cost and least disruptive technologies are deployed. Electrification, natural gas with carbon capture and storage, renewable gases and renewable electricity will all play significant roles in the energy system in 2050.
• 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 help minimise the cost of decarbonisation to industry and consumers.
2. Stimulating a Circular Economy & Jobs Growth through Renewable Gas Deployment
GNI welcomes the focus of the Just Transition Fund (JTF) on reskilling the labour market to help adapt to new employment opportunities and modernising local economies. Relating to the proposal JTF should support “investments in enhancing the circular economy, including through waste prevention, reduction, resource efficiency, reuse, repair and recycling” (article 4.2.(g)), GNI notes:
• Through the deployment of renewable gases, there is an opportunity to link energy decarbonisation with growing the circular economy and rural job creation. In this way, there is potential to reinforce separate strands of the Green Deal’s eight focus areas.
• For example, the ‘Gas for Climate’ report shows a potential of direct employment opportunities within renewable gases across the EU economy by 2050, including up to 225,000 jobs in renewable electricity generation for hydrogen production; up to 150,000 jobs in agriculture and forestry to support biomethane production facilities; and up to 300,000 jobs in the development and operation of digesters, thermal gasification plants and electrolysers.
3. Ensuring Support for New Technologies
Relating to the proposal that the Just Transition Fund should support “investments in the deployment of technology and infrastructures for affordable clean energy, in greenhouse gas emission reduction energy efficiency and renewable energy” (article 4.2.(d)), GNI observes:
• Europe is home to energy intensive industries, including the chemical and steel sectors, which have intensive energy and heat needs in their production processes. Ensuring that renewable gases (natural gas, biomethane or hydrogen) remain part of the energy mix will help protect downstream jobs in energy intensive industries during the green transition.
• For the EU to achieve net-zero emissions by 2050, Carbon Capture Storage (CCS) is a necessity. In Ireland, CCS can be used to decarbonise the production of hydrogen, to capture carbon from natural gas CCGT power stations and across a number of industries. CCS with Bioenergy has the potential to deliver negative emissions.
• A supportive policy and fiscal environment for the development and commercialisation of new energy technologies such as hydrogen and carbon capture storage could enable the EU to become a global leader in green technology development and boost job creation. We propose that a portion of the fund is ring fenced for this purpose.
We await the outcome of this consultation, and look forward to working with the Commission towards a greener Ireland and EU.
Read full responseResponse to Climate Law
4 Feb 2020
Gas Networks Ireland (GNI) along with its parent company Ervia welcomes the opportunity to provide feedback on the “European climate law – achieving climate neutrality by 2050”. GNI affirms the view that “all sectors play their part”, and that the solution to the climate challenge will require the deployment of many technologies. Electrification, Natural Gas with Carbon Capture and Storage (CCS), renewable gases and renewable electricity will all play significant roles in the energy system in 2050.
GNI agrees with the “principle of having intermediate targets”. This should be extended to all sectors, including gas, to ensure that they make the necessary contribution towards climate targets. Binding targets should be set at EU and Member State level for renewable and decarbonised gases in gas grids, subject to an appropriate evaluation. This will help the decarbonisation of difficult sectors such as heat and industry, and help achieve the energy transition in a cost efficient manner, whilst safeguarding jobs and achieving a ‘Just Transition’.
GNI also agrees with the EU’s “objective to be net-zero greenhouse gas emissions by 2050”. GNI’s vision is for Ireland’s gas network to be net zero carbon by 2050. Transitioning to a climate neutral economy will be challenging as a balance between sustainability, security and affordability must be achieved. Using existing assets and capabilities will achieve these aims earlier, offering the potential to achieve a smoother and more sustainable transition.
The gas network will provide a least cost pathway to decarbonise heating and power generation and will provide cost effective solutions for other sectors. In the short term, the displacement of more carbon intensive fuels such as coal and oil by natural gas can have an immediate impact. In the medium term innovative technologies such as CCS and renewable gases can help decarbonise gas grids.
Renewable biomethane is already being injected into gas grids and represents the least cost and least disruptive way to decarbonise home heating for those on or near the gas network. Biomethane is net zero carbon and fully compatible with the existing gas networks.
Negative emissions will be needed to achieve net-zero emissions. This can be achieved in electricity generation by utilising Bio-Energy with CCS (BECCS). Negative emissions can then be used to compensate for emissions in sectors that are more challenging and expensive to decarbonise, such as agriculture, heating and transport.
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. This technology will enable the broader concept of Sector Coupling between gas and electricity grids, whereby the gas grid can be used to store excess renewable energy for later use when intermittent energy sources are not available. Hydrogen can also be produced from Natural Gas, and when combined with CCS technology decarbonised hydrogen can be produced.
Hydrogen can potentially be injected into gas networks as a blend with natural gas or existing gas infrastructure could be repurposed to transport 100% hydrogen, subject to technical evaluation and standardisation. Hydrogen is suitable for a wide range of applications which are currently served by gas, however for certain end use applications further investigation will be required.
The initiative calls for the EU’s 2050 climate-neutrality objective to be met in a ‘cost-efficient manner’. GNI recommends the adoption of a ‘Total System Cost of Abatement’ approach when assessing zero-emission technologies. Marginal Abatement Cost Curves and Levelised Cost of Energy do not account for the additional grid infrastructure required to support increased renewables. Therefore they do not reflect the true cost of some electricity based technologies and can make them appear inexpensive in comparison to low or zero-emission gas technologies.
Read full responseMeeting with Miguel Arias Cañete (Commissioner) and Greenpeace European Unit and
13 May 2016 · EU energy and climate agenda for 2016