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Gaz Réseau Distribution France

GRDF

GRDF is a major French operator managing the national gas distribution network.

Lobbying Activity

Meeting with Jutta Paulus (Member of the European Parliament)

26 Nov 2025 · Energy Politics

GRDF urges EU to recognize circular methane as strategic resource

6 Nov 2025
Topic — The European Commission is consulting on the new Circular Economy Act for sustainable production.
Message — GRDF calls for an EU framework to incentivize the reuse of circular methane and biogenic CO2. They recommend implementing blending obligations and harmonizing definitions for recovered nutrients. The organization also suggests making circular procurement criteria flexible and locally tailored.123
Why — This would lower regulatory barriers for gas infrastructure while boosting market demand for biomethane.45
Impact — Producers of fossil fuels and chemical fertilizers would lose market share to renewable alternatives.67
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GRDF urges hybrid heating for EU electrification plan

9 Oct 2025
Topic — This consultation seeks to address barriers to the electrification of energy demand.
Message — GRDF requests that smart hybrid heating be recognized in state aid rules. They also advocate for blending obligations for renewable gases. They suggest retail prices should reflect infrastructure costs through variable tariffs.123
Why — This preserves the strategic value of gas distribution networks in the energy transition.45
Impact — Electricity consumers face higher bills if heating is electrified without the flexibility of gas.67
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Response to Heating and cooling strategy

5 Oct 2025

GRDF, the largest French gas DSO, welcomes the ECs consultation on the heating and cooling strategy revision. Indeed, heating and cooling are good means to valorise available renewable electricity when greater than the specific demand. Nevertheless, balancing supply, demand and infrastructure capacity constraints make heating and cooling technically difficult and economically challenging to fully electrify. A holistic system consideration, coupling renewable electrons and molecules, will enable a much faster, safer, affordable and resilient transition, leaving no one behind. Affordability is a major concern to make the transition attractive. The fast growth of near zero or even negative electric spot price shows that, when greater than the specific demand, renewable electricity price can be very more competitive than fossil-based power. Electrification of non-specific uses, such as heat, would then help to valorise these affordable surpluses for the benefits of consumers. But a non-flexible heat electrification would fully transfer seasonal heat demand, such as several days or week of very cold snaps and Dunkelflaute to the electric infrastructure. This seasonal demand, today mostly covered by the gas infrastructure (grids and storages) represents about 3 times the present electric infrastructure capacity. Indeed, in terms of capacity, gas grids are very competitive, they are five to ten times more affordable than electric grids and gas storages are several thousand times more affordable than batteries for annual use. The challenge here is not to choose the best vector but to find the best way to combine them, and smart coupling providing decentralised flexible heat to consumers, gives access to the best of both worlds. Flexible electrification of heat generation via hybrid heating system, combining electric and gas heating appliances, such as a heat pump and a boiler or a cogeneration, enables a fast, affordable, safe transition leaving no one behind - Fast because smart hybrids enable that no fossil-CO2 is emitted when renewable electricity or gas are available, - Affordable because hybrid heating enables customers to use the most affordable and decarbonised energy available when they need it, and allows for staged renovation, - Affordable because hybrid solutions optimise infrastructures, - Safe because of the inherent resilience of a flexibly coupled energy system, - No one behind because coupling gives a much wider choice of solutions, including direct use of renewable gas for those that have no more cost-effective solution. For cooling, the growing uptake of decentralised PV production, combined with batteries to balance daily production and demand, seems an obvious solution to manage the cooling growing needs. Reversible heat pumps would help provide flexible heat electrification. We suggest the EC to consider a holistic energy system optimisation via flexible heat electrification. Here are some propositions: 1 Give customers access to retail prices reflecting the energy supply and infrastructure costs with variable and congestion tariffs, 2 Recognise smart hybrid heating solutions in state aids for their contribution to system optimisation and their capacity to provide growingly fossil free flexibility, 3 - Facilitate renewable gases decarbonisation in both buildings and industries, by recognising green contracts with shares of renewable gas certified by energy suppliers, 4 Support the uptake of renewable gas, to ensure that enough renewable gas is available to meet the EC climate targets. This can be done via blending obligation in the building sector to ensure that it is fossil free by 2050 and supporting growingly fossil free hybrid heating flexibility, 5 Ensure that integrated planning of all energy vectors, electricity, gas, heat, is done from the local level upward, taking full consideration of decentralised renewable energy productions, infrastructures, demand and flexibility capacities.
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Response to Towards a Circular, Regenerative and Competitive Bioeconomy

20 Jun 2025

We, GRDF, are the largest French gas DSO. Engaged for over a decade, along the bioeconomy stakeholders, in supporting the development of biomethane, we strongly support a circular approach of the bioeconomy, fostering synergies between renewable gas, organic recycling, and agricultural sustainable transition and resilience. Indeed, methanisation of biowaste and agriculture residues, produces renewable energy, renewable fertilisers, enable carbon capture creating value for bioeconomy stakeholders and Europe as a whole. I. Methanisation produces biomethane, a key asset for the energy transition and EU sovereignty Produceable all over Europe from local and sustainable biomass, biomethane is a renewable energy that aligns with EU climate goals. It brings a valuable value stream to the EU bioeconomy competitiveness and sovereignty. Methanisation fosters agroecological practices, by recovering organic waste and returning digestate, a sustainable fertilizer, to the soil. It reduces European sovereignty on imported synthetic fertilizers. EU-level R&D programs should support sector development through technological advances, reducing costs and accessing new, hard-to-digest biomass sources. II. Methanisation valorise local biowaste and biomass Methanisation is often the most efficient solution to valorise feedstocks (cf. attached study). Mobilizing sustainable biomass is key to scaling up biogas and digestate production should be facilitated. For example, methanation of livestock effluents should be facilitated through local targets, investment support, and logistics tools. Similarly, methanisation is an obvious means to valorise households biowaste, and should be encouraged over less sustainable waste management solutions. Cover crops, sown in between two main crops, provide many agroecological benefits: soil coverage, erosion prevention, water retention, carbon storage. They are a sustainable way to greatly increase biomass production without competing with food and land use. Their development must be supported. III. Methanisation produces digestate a renewable sustainable Fertiliser Digestate, a co-product of anaerobic digestion, is not sufficiently recognized as an organic fertilizer despite its proven agronomic value. The regulation on organic fertilizing products (RENURE/Nitrates Directive) must evolve to remove barriers to using digestate derived from livestock effluents. This evolution is crucial to fully leverage digestates benefits in agriculture. IV. Methanisation produces Biogenic CO that can be used in industries or captured and stored Anaerobic digestion produces biogenic CO2, a sustainable alternative to fossil carbon in industries and for storage strategies. The capture potential from methanisation is considerable: 46 Mt of CO per year by 2030, and up to 120 Mt by 2050. EU climate policies should enable to tap this potential, by example by of valorisation targets, or defining biogenic CO2 certification methodologies, in line with the RED Directive. EU should as well support R&D programs facilitating the deployment of operational and large-scale solutions and help create a dynamic market that strengthens Europes bioeconomy decarbonation and competitiveness. V. Green gases are an essential part a cost-efficient and resilient fossil free energy system Renewable gas value must be considered in a systemic approach, as a part of the bioeconomy and in complementarity with the other renewable energies, especially renewable electricity. Besides being a decarbonation solution, as it can use the existing gas infrastructures and equipment, biomethane is very cost-efficient to store for seasonal needs (in existing gas storages), and easy to use to provide the flexibility required to balance intermittent electricity and coming electric grids congestion. This can be achieved by producing electricity on demand or, even more cost efficient, provide heat via hybrid heating solution such as cogeneration or a hybrid heat pumps.
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Meeting with Christian Ehler (Member of the European Parliament) and EPIA SolarPower Europe and

13 Dec 2024 · Energy policy

GRDF urges biomethane exemptions and longer fuel traceability deadlines

7 Nov 2024
Topic — Extension of the Union database scope to track fuel raw material production.
Message — The group seeks to extend transaction recording deadlines from three days to one month. They also request exempting small producers and excluding local deliveries from registration.123
Why — Small operators avoid high administrative costs and technical burdens of database compliance.45
Impact — The Commission's push for total transparency is weakened by these requested exemptions.6
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Meeting with Arash Saeidi (Member of the European Parliament)

27 Sept 2024 · Visite de site départemental

Meeting with Laurent Castillo (Member of the European Parliament)

11 Sept 2024 · Politique énergétique

Meeting with Christophe Grudler (Member of the European Parliament) and France Hydrogène and Région Bourgogne Franche-Comté

30 Jan 2024 · Politiques énergétiques de l'UE

Meeting with Irène Tolleret (Member of the European Parliament)

10 Nov 2023 · Biocarburants

Meeting with Irène Tolleret (Member of the European Parliament)

17 Oct 2023 · Enjeux énergétiques

Meeting with Christophe Grudler (Member of the European Parliament)

17 Oct 2023 · Règlement CO2 Poids lourds

Meeting with Ditte Juul-Joergensen (Director-General Energy) and Bureau Européen des Unions de Consommateurs and

20 Jan 2023 · U.S.-EU Task Force: Best practices in Energy Savings and Flexibility Other participants: Cleantech-Cluster Energy, ELVIA, EU DSO Entity, California Energy Commission, ASE, AEE, ComEd, Octopus Energy, OPower, Uplight

Meeting with Riccardo Maggi (Cabinet of Executive Vice-President Frans Timmermans)

28 Nov 2022 · Energy efficiency

Meeting with Antoine Colombani (Cabinet of Executive Vice-President Frans Timmermans) and TotalEnergies SE and

25 Oct 2022 · Green Deal state of play

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

19 Oct 2022 · To inform about the result of the biomethane plant visit we organised on 30/09/2022

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

6 Sept 2022 · CO2 Standards for heavy duty vehicles

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

1 Mar 2021

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

16 Dec 2020
Topic — This consultation defines which economic activities qualify as environmentally sustainable for investment purposes.
Message — GRDF requests classifying natural gas network expansion as a transitional activity to replace coal. They demand aligning bioenergy criteria with existing rules rather than imposing stricter standards. The group also argues for recognizing biomethane-powered transport and heating as sustainable.1234
Why — The proposals would protect gas infrastructure investments and support continued network expansion.5
Impact — Electric vehicle manufacturers would lose exclusive access to green transport investment funds.6
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Response to Sustainable and Smart Mobility Strategy

17 Jul 2020

Mobility is an essential but hard to decarbonise sector and all sustainable, cost effective solutions must be promoted. Electricity and gas are offering complementary solutions to decarbonise all types of mobility: - They share the valuable advantage of an easy blending of fossil and renewable to pursue the progressive uptake for a fully renewable mobility by 2050. Renewable gas represents already 17% of gas mobility in Europe (up to 94% in Sweden), can be 40% in 2030 and 100% renewable by 2050 (Gas for Climate 2019 & ADEME 2018), - Electricity and Gas mobility impact on climate are coming from different parts of the lifecycle, which allows to choose the most adapted and cost-efficient solution according to the user needs, but makes solutions only comparable on a holistic (LCA) approach: o for electricity mobility, impacts mainly come from batteries production and recycling (cf. joined IFPEN Study), and from the fossil share of electricity production. o for methane-based mobility, impacts come from the combustion of the share of fossil gas in the fuel. The CO2 produced from the combustion of biomethane has no effect on climate as it is short cyclic – and do not add fossil carbon in the atmosphere. o for hydrogen-based mobility, impacts come from the production process. - Biomethane production comes with many positive externalities: o It is part of the circular economy, valorising biowaste into renewable fertilisers and biomethane. It’s an enabler of the transition to agro-ecology practices, good for the climate (carbon capture), environment (soil resilience, biodiversity, water protection) and create qualified jobs in rural areas. o the high energy density of methane-based fuel makes it an ideal carrier for heavy mobility to replace immediately diesel in all the transport sector and heavy mobility: trucks, buses, trains, waterways, sea-shipping, agriculture, Civil works. Retrofitting by gas engines can be done without major difficulties with immediate savings in CO2 and Euros. - Using both energy carriers can lead to an optimised solution for all segments of vehicles including light ones. A CO2 optimised light vehicle would be an electric-bioNGV hybrid, with an optimised (not oversized) battery for the daily needs and biomethane engine as a range extender. Ongoing studies show a huge potential for (bio)NGV to decarbonise the non-electrified railways. - Alternative fuel mobility relies on a well-functioning energy system. Large scale deployment of charging/refuelling infrastructure must be planned to avoid negative impact on system stability, security of supply and costs. The existing extended gas network facilitates an efficient deployment of (bio)NGV refuelling stations. For a faster, safer and affordable transition, policies should address the following points: 1. Leverage on all available sustainable solutions to accelerate the decarbonisation of the transport system, especially biomethane based solutions for methanisation positives externalities, technology maturity and its adaptation to heavy transportation, for example by setting targets in the revision of the Renewable Energy Directive. 2. Accelerate the development of infrastructures for gaseous and electric mobility, including combined solution to facilitate the uptake of hybrid solutions, for example by setting ambitious target in the coming revision of the Alternative Fuel Infrastructure Directive. 3. Amend the CO2 emissions standard regulation to ensure a level-playing field for solutions considering their whole effect on climate, environment and society and to start replacing massively diesel fuel carrier right now, as part of the COVID recovery plan 4. Boost R&D to improve and develop climate and environment efficient and cost-effective engines for renewable energy (electricity, methane, hydrogen, hybrids) 5. Development of charging/refuelling stations shall be integrated in the TYNDP to ensure system stability, security of supply and cost optimisation.
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Response to A EU hydrogen strategy

8 Jun 2020

GRDF welcomes the opportunity to answer the Commission’s roadmap on an “EU Hydrogen Strategy” and is convinced that renewable hydrogen will play a key role in the European Commission’s strategy for energy system integration. GRDF will focus its answer to the roadmap on the blending of renewable hydrogen in gas grids and on the production of synthetic methane by combining hydrogen with CO2 (Power-to-CH4). 1. Consider the advantages of blending renewable hydrogen in gas grids GRDF calls for the roadmap to include a chapter on blending hydrogen in gas grids. We have joined to our answer a report from the French gas infrastructures operators on the “Technical and economic conditions for injecting hydrogen into natural gas networks”. The work carried out by French operators shows that it is possible to integrate a significant volume of hydrogen into the gas mix by 2050, with limited infrastructure adaptation costs. In the short term, hydrogen can be blended in most networks at a rate of 6% in terms of volume. By 2030, we recommend setting a target capacity for integrating blended hydrogen into the networks of 10%, and 20% thereafter. Blending of hydrogen in gas grids with natural gas and an increasing share of biomethane can therefore contributes efficiently to decarbonisation without building new pipes. Ultimately, in specific areas, some pipes could be retrofitted to welcome 100% hydrogen. 2. Push for Power-to-CH4 GRDF believes that the EU Hydrogen Strategy must include a chapter on Power-to-CH4 (Methanation). Power-to-CH4 is the combination of hydrogen produced via electrolyses and CO2. The CO2 used can be of three origins. CO2 can be sourced and recycled from energy intensive industrial processes, therefore creating a link between energy production and the industrial sector. CO2 can also be of organic origin when sourced from biomethane plants. Biomethane, especially from agriculture, has a huge potential in Europe. The upgrading of biogas into biomethane makes available biogenic CO2, not valorised today. By combining this CO2 with hydrogen, the biomethane producer can produce a synthetic methane that can be injected in the gas grid with the same connection than biomethane. Methanation completes the biomethane plant by valorising the CO2 and by storing hydrogen in the existing gas grid. In a holistic approach, methanation avoids cost in the infrastructure and appliances as synthetic methane is perfectly substitutable to natural gas. In their report, French gas infrastructure operators demonstrated that the most cost-effective way of developing hydrogen based on pipes is achieved by combining complementary solutions: blending, methanation, dedicated hydrogen clusters. These complementary options enable to adapt the hydrogen development to different local settings. In conclusion, blending of hydrogen in the gas grids and Power-to-Methane are two important elements that should be included in the EU Hydrogen Strategy as well as in the “European Clean Hydrogen Alliance”. Those solutions must be included in the planning of energy infrastructures (TYNDPs) as they allow to reduce the construction of new pipes and limit the adaptation cost for the downstream equipment. Life-cycle benefits of blending and methanation need to be evaluated including the positive externalities (benefits for the agricultural sector, reduction of new infrastructures etc.). Finally, these technical solutions are still nascent so there is a strong need for R&D projects to kickstart the sector. GRDF is looking forward to the release of the strategy and the launch of the European Clean Hydrogen Alliance. We remain at the disposal of the Commission if needed.
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Response to Strategy for smart sector integration

5 Jun 2020

The Strategy on smart sector integration is an essential step to climate neutrality. GRDF fully supports these actions which are even more important in the context of the EU economic recovery plan. GRDF is convinced that gas solutions and renewable gases, including biomethane and hydrogen, are essential for a fast, safe, affordable and sustainable decarbonisation. Complementing electricity-based technologies, they bring much-needed contributions to flexibility and resource adequacy to the energy system. At the users’ level, smart hybrid appliances such as hybrid heat pump (coupling of an electric heat pump and high-performance gas boiler) will open the way for a dynamic management of the electric demand, with no impact on the end user’s comfort. This flexibility will increase the energy safety by giving the possibility to shave local/national electric peaks, thus saving on the high costs (in euros and CO2), of peak electricity production and grid capacity. To give an idea, cost per KW of new electric grids can be 10 to 20 times higher than gas ones, and gas grids are already built… This flexibility can as well be used to prioritize the most carbon efficient source of energy available, either renewable electricity or renewable gas. Finally, these appliances are no regrets solutions for the end user as they are cheaper and easier to retrofit than their full electric counterparts. At the production level, coupling optimises the renewable electricity production, either by avoiding the loss of renewable electric production when higher than demand, thanks to power-to-gas, or to meet peak demand by production from renewable gas. To be a decisive contribution to the success of the EU green Deal and economic recovery, an enabling framework for system integration should include the following measures: Secure investments in renewable gas supply with: - Binding EU-level targets for renewable gases, - Fair rules to increase gas injection and distribution in support of use of regional/local resources such as biomethane, - An EU-wide certification system for all renewable gases. Prepare the integration of low carbon hydrogen in the energy system: - Further explore the use of gas infrastructures for transmission and distribution of hydrogen, in blending with methane or not, - Synchronise decarbonisation of gas and market transformation of gas-using appliances under ecodesign and energy labelling - facilitate that these appliances can use hydrogen-methane blends or pure hydrogen, Optimise the use of existing infrastructures (gas & electric) to facilitate decarbonisation of transport, industry and buildings under a holistic approach of the energy system: a diversified mix based on electricity and decarbonized gases supports the penetration of renewable energy, reducing costs by optimising the dynamic use of existing infrastructures. - Couple electricity and gas infrastructure development plans - while ensuring full transparency on the underlying assumptions - to optimize the transformation of the energy system. - A holistic approach based on technology neutrality must prevail to enable the most efficient and relevant investment choices (power line, power-to-gas, promotion of smart hybrids, etc.) and to reconcile the economic, societal and environmental aspects, while ensuring robustness of the chosen transition path. - Create a European Gas DSO entity with a clear mandate and adequate representation of the sector – as the energy system is more and more decentralised. Tap the potential of innovative renewable gas technologies and foster hybridisation: Investments in heating technologies such as heat pump/gas hybrids with digital demand response capabilities are key enablers. They speed up the uptake of renewables, deliver large aggregated emission reductions and reduce energy bills. It is a no-regret for staged deep renovation. On the production side, power-to-gas is a promising solution for a 100% decarbonised energy mix.
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Response to Commission Communication – "Renovation wave" initiative for the building sector

5 Jun 2020

The renovation wave initiative, and its connection with the smart sector integration, is an important step to climate neutrality. GRDF is convinced that gas solutions and renewable gases are essential for a fast, safe, affordable and sustainable decarbonisation. Complementing electricity-based heating technologies, they bring much-needed contributions to flexibility and resource adequacy to the electric system, thus enhancing the energy system safety and reducing the high cost, in euros and CO2, related to electric peak management. This can be done through hybrid appliances using both energy carrier, the most common being hybrid heat pumps (electric heat pump combined with high-performance boiler). For the end user, hybrid heat pumps are cheaper than their electric counterparts as the expensive part, the heat pump, doesn’t have to be dimensioned for the coldest day, but for the highest annual efficiency. Hybrids have the extra advantage to be much easier to retrofit, as they do not require a deep renovation prior to their installation. They are very well adapted to a step by step renovation with high early benefits, increasing with every isolation works. Furthermore, the hybrid settings can be adjusted according to the evolution of energy prices to optimise the end-user energy bill. At the energy system level, hybrids bring energy efficiency (>30% compared to an obsolete boiler) and a very useful “passive flexibility” to the electric system: on the coldest days they switch to gas, reducing the need for peak power production. Their full benefit comes when they become smart, responding to electric grid signals. they bring then a much-needed flexibility to the energy system without any rebound effect of reduction of comfort for the end user. This flexibility can be used to optimise the energy supply with the lowest CO2 content (renewable electricity or gas) and to manage the demand on the electric grid at the local or national level. This “gas system back-up” will ensure the electric system safety and reduce the costs of peak electricity production back-up and electric grid reinforcements (network costs in EU households electric bills are already 4 times higher than in gas bills). Smart hybrids solutions are no regrets solutions, as they enhance: - sustainability, making the best use of all electric and gas renewables and increasing energy efficiency even without prior deep renovation - energy safety, bringing dynamic flexibility to the electric grids to reduce black-out risks, - affordability, reducing costs at end user and system levels To be a decisive contribution to the EU green Deal and economic recovery, an enabling framework should include the following measures: 1. Drive a diversified heating energy carrier mix including decarbonized gases for a cost-optimal decarbonization of the building stock by 2050 2. Optimize the use of existing gas infrastructures: a smart mix of heating based on electricity and decarbonized gases supports the electrification of transport and industry, reducing costs by optimizing the use of existing infrastructures 3. Tap the potential of innovative heating technologies: Investments technologies such as smart hybrids are key enablers to speed up the uptake of renewables, deliver large aggregated emission reductions and reduce energy bills. It is a no-regret for staged deep renovation 4. Secure investments in renewable gas supply with: • Binding EU-level targets for renewable gases • Fair rules for flexible gas injection and distribution in support of optimized use of regional/local resources such as biomethane 5. Prepare the integration of hydrogen in the energy system: • Further explore the use of existing gas infrastructures for hydrogen, in blending with methane or not • Synchronize decarbonization of gas and market transformation of gas-using appliances under ecodesign and energy labelling - facilitate that end-use appliances can process hydrogen-methane blends or pure hydrogen.
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Meeting with Pascal Canfin (Member of the European Parliament)

27 May 2020 · Green Deal

Response to Climate change mitigation and adaptation taxonomy

23 Apr 2020

GRDF welcomes the opportunity to give its contribution to preparation of the Delegated Act, highlighting the importance of this decision to the success of the EU Green Deal and the decarbonisation of the economy. GRDF remains at the disposal of the EC for detailed discussion. A-Scope of the taxonomy The range of the activities considered should be wide enough to include mature technologies and business models as well as emerging ones. In addition, criteria should not be excessively detailed in order to afford new, low-carbon and renewable innovation to be financed. For instance, the taxonomy should be able to include different models of Anaerobic Digestion, not limited to sewage sludge and predominantly biowaste-based models, as well as methanation. Similarly, the taxonomy should not impede investment in different types of biogas/biomethane production technologies, such as gasification of biomass and solid recovered fuels, and anaerobic digestion of algae, especially in the pre-commercial phase. B-Criteria and thresholds of the delegated act should be compliant with existing sectoral legislation, as required by the Taxonomy Regulation (Art. 19(1)d). The delegated act should not go beyond EU laws with tougher requirements that were not impact assessed nor agreed by EU Member States. This would create double standards and a dangerous unlevel-playing field between technologies, bringing uncertainty and administrative burden for investors and businesses. The taxonomy should abide by the “energy efficiency first” principle enacted in existing legislation, including the Energy Efficiency Directive. Many energy-related European laws are expected to be revised in the next three years in the framework of the EU Green Deal. The taxonomy, revised regularly according to Taxonomy Regulation (especially criteria on “transition activities”), could adapt easily to the updated legislation. C-The delegated act must be in line with the principle of technological neutrality, as set in the Taxonomy Regulation (Art. 19(1)a)). This would provide a level playing field for low-carbon and renewable technologies to emerge and compete. This is would also be more respectful of the Member states’ right to choose between different energy sources. Furthermore, the sustainability of an energy system requires an holistic approach. Therefore, the logic applying to gas networks and electricity networks should be the same when it comes to network maintenance, upgrade and expansion as well as equipment and activities enabling the increasing integration of decentrally-produced renewable gas (biomethane or hydrogen) or electricity. Life-cycle Assessment-based criteria should be consistently applied to different technologies across sectors, including in transportation. LCA criteria weighs the carbon intensity of the energy vehicles run on. It is fair to include, at a country level, the carbon intensity of electricity, hydrogen and methane (i.e. natural gas (NGV) and biomethane (bioNGV)), as national situations can differ a lot. D-The taxonomy should enable a phased energy transition by recognising the potential of CO2 emissions reduction of natural gas and, to a larger extent, biomethane, in production of electricity and heat, in cogeneration and transportation. Therefore, criteria should be tailored for activities running both on natural gas and biomethane, whether it is about the network, gas and hybrid appliances, vehicles and refuelling infrastructure. Taxonomy should take into account nowaday’s state of technologies and markets, knowing it will be reviewed regularly. That is why it makes sense to label as enabling activities the building of NGV/bioNGV vehicles in all categories and the running of NGV/bioNGV fleets as sustainable or transition activities. Taxonomy could set secondary criteria on fossil fuel-related activities to avoid any lock-in. For natural gas it could be the definition of a decarbonisation trajectory of the considered energy system.
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Response to Revision of the Energy Tax Directive

31 Mar 2020

GRDF welcomes the inception impact assessment on the revision of Directive 2003/96/EC restructuring the Community framework for the taxation of energy products and electricity. We welcome the Commission’s objective to align energy taxation with the EU 2030 targets and climate neutrality by 2050 in the context of the European Green Deal. The Commission has rightly understood several barriers within the present ETD hindering the development of an environmentally sound taxation framework. Since its adoption in 2003, the ETD has defined EU rules for the taxation of energy products used as motor fuel or heating fuel and of electricity. However, both energy markets and technologies have experienced significant developments, and the EU has increased its international decarbonisation commitments. Since 2003, the EU has also passed several landmark legislations such as the Renewable Energy (RED II) and Alternative Fuels Infrastructure directives. The ETD must be aligned with these legislations to secure a fair and coherent renewable energy taxation regime for all new technologies. In the inception impact assessment, the Commission has properly identified a set of policy options allowing to meet the above objectives: •The review of the fiscal base is the opportunity to align energy taxation with GHG emissions. The current Directive has stopped some Member States from passing CO2 taxation mechanisms. If the ETD increasingly moves towards a fiscal system based on CO2 and on energy content, this will allow Member States to legislate in favour of more efficient CO2 taxation regimes. •The review of sectoral tax differentiation is required to meet EU climate objectives, for instance, at the moment, only gas oil can get a differentiated tax rate depending on the private or commercial usage (article 7 §2). This option should be extended to all fuels listed under the AFI Directive. Likewise, all public transport passengers and not only local public transport passengers should benefit of a differentiated taxation rate (article 5) to drive the uptake of alternative fuels. •The Commission must review the scope of the energy products covered by the ETD to apply favourable taxation regimes to products which benefit the environment. For example, the fiscal charge on renewable gases used in all sectors (heating, industry, mobility) must be reduced based on the actual framework for renewable electricity (15 §1 §b). Also, products from biomass should benefit from exemptions or reductions even if their development are obliged by European targets (article 16 §§ 1, 6) such as the renewable energy objective for the transport sector in RED II. On biofuels, the taxation regime should be based on the sustainability of these fuels as defined in RED II. The Commission rightly identified the potential impacts of its policy options. Revising the energy taxation to back renewable energies will have positive economic impacts. It will stimulate investments in these technologies and ultimately create jobs. For example, in France, we estimate that 3 to 4 jobs are created per biomethane plants, and more than 95% of the value (jobs, supply) of a European biomethane plant comes from the EU, no matter the country. It will also help the EU to decrease its emissions of greenhouse gases and other pollutants, for instance, with BioNGV vehicles which emit 95% less particle matter, 50% less NOx and 80% less CO2. Finally, we would like to stress that the present ETD also contains useful measures for an environmentally positive taxation system. The exclusion of electricity used in the electrolysis process from the scope of the Directive will help the Power-to-Gas sector to grow. Likewise, the exemption or reduction of tax rates for energy products used to develop technologies is driving innovation. Also, the exemption or reduction of tax rates for energy products used for agriculture works will support alternative fuels to efficiently decarbonise this sector.
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GRDF urges EU to keep gas in alternative fuels definition

19 Mar 2019
Topic — The European Commission is evaluating the effectiveness of the Alternative Fuels Infrastructure Directive.
Message — GRDF requests that compressed natural gas remains classified as an alternative fuel. They advocate for a "well-to-wheel" evaluation of emissions to ensure technology neutrality. This would support a progressive transition using existing, affordable refueling systems.123
Why — This approach would protect GRDF's existing gas infrastructure and market relevance.4
Impact — Purely electric infrastructure providers lose if investment is diverted back to gas.5
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Response to Evaluation of the 2011 White Paper on Transport

7 Mar 2019

GRDF is the leading gas distribution system operator in France. It delivers gas to 11 million consumers through a network long of 198 000 km. It is an actor committed to the development of a cleaner mobility. It advocates for the use of NGV and BioNGV and facilitates the connection of NGV refuelling stations to the gas distribution network. Therefore, we are glad to be able to give our feedback on the Roadmap for the evaluation of the 2011 White Paper on Transport. GRDF very much welcomes the Evaluation Roadmap of the European Commission, its scope and methodology. We appreciate that the Commission is adopting a holistic approach for the evaluation of its White Paper. It underlines it will look at several indicators including economic performance, employment, emission performance, modal distribution and access to mobility. GRDF appreciates that the Commission will look at relevant indicators on energy and environment. On the emissions indicators, it is indeed important to not only look at CO2 emissions, but also NOx and Particle Matter emissions. We would like to share with the Commission the report from April 2018 of the Equilibre Project. This report presents the results of an analysis of the fuel consumption and of CO2 and NOx emissions of trucks powered by natural gas or diesel. As part of the Equlibre Project 15 heavy grid vehicles were fitted with a device analysing their environmental performance in real-conditions. The study found that 44-tonne natural gas tractors emit between 40% and 64% less NOx than 44-tonne diesel tractors depending on the type of road in question. CO2 levels, were up to -20% for natural gas vehicles. Link: http://www.projetequilibre.fr/le-projet/synthese-du-projet-equilibre/ Following the Europe on the Move package, the Commission has to present a well-to-wheel approach. The Clean Vehicles Directive obliges the Commission to come up with such an approach by 2021. A well-to-wheel analysis accounts for the energy consumed and GHG emissions produced to extract, transport, refine and distribute at the retail level the fuel from the primary raw feedstock source to the vehicle tank and to move the vehicle. It is the combination of all the steps that turns the natural resource into motion of the vehicle. It consists of a well-to-tank and a tank-to-wheel part that measures the energy consumed and GHG emissions produced to move the vehicle. This approach considering the fuel supply chain from extraction to use is fundamental to provide a more realistic comparison of the climate and environmental impact of different fuels. Therefore, GRDF underlines that the evaluation should look at emissions across the entire value chain. In this way, we welcome that the Commission plans to look at the recycling of vehicles and components. Regarding employment, we would like to share with the Commission the study from Frost & Sullivan “Natural Gas for vehicles (NGV) Industry impact on French employment”. This study found that 36.000 FTE could be created in France in the vehicle production and maintenance sector and 1.500 FTE in the refuelling station network installation and maintenance sector. To conclude, we are looking forward the next step of the consultation and remain at the disposal of the Commission should it require any additional information.
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Meeting with Dominique Ristori (Director-General Energy) and Gas Distributors for Sustainability and

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

Meeting with Miguel Arias Cañete (Commissioner) and

15 May 2017 · The Clean energy package, gas market design

Meeting with Dominique Ristori (Director-General Energy)

10 May 2017 · Energy policy