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GasNaturally

GasNaturally’s mission is to highlight how, by using natural, low-carbon and renewable gases, we can make a clean future real.

Lobbying Activity

Meeting with Stefano Grassi (Cabinet of Commissioner Kadri Simson)

14 Dec 2022 · Discussion on the gas markets outlook

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

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

13 Apr 2022

GasNaturally welcomes the proposal for a Regulation on methane emissions reduction in the energy sector. To achieve a successful implementation and tangible emissions reductions, we offer the following recommendations: The Regulation should be less prescriptive and establish proportionality and materiality criteria to avoid excessive requirements with disproportionate efforts to industry and consumers but with no or very limited environmental benefit. Leak detection and repair (LDAR) and monitoring, reporting and verification (MRV) requirements should be proportionate considering flow rates, equipment installed, the risk to leak, and the type of asset (e.g. offshore platform vs. distribution pipeline). In this context it should also be possible to prioritize leak repair activities based on emissions mitigation impact and components identified as having significant emissions reduction potential. We suggest that CEN is mandated to develop LDAR and MRV standards. Until such standards are developed, the Regulation can list (e.g. in an annex) key parameters of the OGMP 2.0 Framework including templates and technical guidance documents. The Regulation should be technology open providing for technology evolution. It should promote the use of best available technology for detection and not prescribe a concentration as the standard. The Regulation should also recognize the technical limitations to accurately quantify emissions with top-down/site level technologies and methodologies. Several terms used in the Regulation need definition or clarification: The term ‘quantification’ should be used in most cases where currently the term ‘source level measurement’ is used: Source-level quantification methods depend on the source type and operation; in most cases, quantification methods based on engineering calculations, simulation tools and emission factors lead to higher data accuracy than ‘direct measurements’. The Regulation builds in parts incorrectly on the OGMP 2.0 Framework or reinterprets its terms thereby jeopardizing one of its objectives; establishing comparable data on methane emissions. The definition of inactive wells is too broad and should exclude permanently plugged and abandoned wells to avoid disproportionate intervention requirements on plugged and abandoned wells with no environmental benefit but significant cost to the industry and consumers. Roles & responsibilities defined in the Regulation should be clarified to avoid overlapping activities. For instance, the Regulation creates similar roles for ‘competent authorities’, ‘verifiers’, and ‘IMEO’. The Regulation also creates reporting obligations on both operated and non-operated assets, leading to double reporting, while the data should consistently be reported by the operator of an asset. Existing inspection and reporting procedures and formats under national rules shall be aligned to avoid parallel activities. The Regulation should avoid establishing procedures which create activities increasing overall GHG emissions. Inspections and LDAR surveys should be combined with existing operational and safety procedures and GHG emissions created by LDAR activities should be proportionate to emissions avoided. While the concept of minimising/banning of venting/flaring (V/F) is accepted, some venting to enable safe operations is technically required and must be reflected in the Regulation by establishing clear exemptions. Also, flaring should be prioritized over venting. The installation of V/F mitigation measures should have feasible lead times and be based on mitigation plans prioritizing investments approved by competent authorities. In case foreign suppliers do not provide data, importers should not be held liable for non-compliance on data requirements. We welcome the recognition of investments and operating costs incurred by regulated operators. GasNaturally and its members stand ready to discuss the aforementioned aspects in more details.
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Meeting with Mauro Raffaele Petriccione (Director-General Climate Action)

18 Jan 2022 · Fit for 55 package and the gas sector

Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans), Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans) and International Association of Oil Gas Producers Europe

26 Oct 2021 · Energy transition

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

21 Jun 2021 · Fit for 55 package and the decarbonisation of gas industry

Meeting with Mauro Raffaele Petriccione (Director-General Climate Action) and International Association of Oil Gas Producers Europe

13 Apr 2021 · Role of gas in decarbonisation

Response to A EU hydrogen strategy

8 Jun 2020

GasNaturally welcomes the European Commission’s intention to present an EU Hydrogen Strategy and set up a Clean Hydrogen Alliance. We commend the Commision on its clear commitment that clean hydrogen will play a key role in decarbonisation. Our feedback is detailed in the attached document.
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Response to Commission Communication – "Renovation wave" initiative for the building sector

8 Jun 2020

GasNaturally welcomes the European Commission's initiative for a Renovation Wave, emphasizing that gaseous energy is a cost-effective solution for the decarbonisation of heat. Our suggestions are included in the attached document.
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Response to Strategy for long-term EU greenhouse gas emissions reductions

9 Aug 2018

The natural gas industry supports the EU’s efforts to meet its commitments under the UN Paris Agreement and will contribute positively and constructively to help do so in an affordable manner for its citizens, businesses and governments. We welcome the launch of the public consultation on the Strategy for long-term EU greenhouse gas emissions reductions and acknowledge that designing such a strategy is highly complicated. GasNaturally particularly welcomes the Commission’s holistic approach to the analysis of various transition options outlined in the Roadmap. Affordability and technology leadership need to be at the centre of the new 2050 GHG reduction Strategy. This will allow the EU to retain the support of its citizens for significant emission cuts and inspire other countries to follow its leadership. Natural, renewable and decarbonised gas can significantly contribute to delivering EU climate and energy policy goals. We strongly encourage that the gas sector’s positive potential to offer affordable and reliable low-carbon solutions in both the short-term and the long-term is reflected in further stages of preparation of the Strategy. Please consult the attached file to read our full feedback.
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Meeting with Mauro Raffaele Petriccione (Director-General Climate Action)

9 Jul 2018 · Preparation of the EU’s strategy for long-term greenhouse gas emissions reduction.

Meeting with Aurore Maillet (Cabinet of Vice-President Karmenu Vella)

13 Oct 2017 · Gas

Meeting with Maria Cristina Lobillo Borrero (Cabinet of Vice-President Miguel Arias Cañete)

24 Mar 2017 · Clean Energy Package

Meeting with Dominique Ristori (Director-General Energy)

22 Sept 2016 · Energy policy