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Initiative Energien Speichern e.V.

INES

Die INES ist ein Zusammenschluss von Betreibern deutscher Gas- und Wasserstoffspeicher und hat ihren Sitz in Berlin.

Lobbying Activity

Response to Gas Storage

26 May 2022

On March 23, 2022, the Commission made a legislative proposal to regulate gas storage facilities. The proposal amends the EU Security of Supply Regulation (SoS Regulation) as well as the Gas Market Regulation. The Initiative Energien Speichern e. V. (INES) as the Association of Gas and Hydrogen Storage System Operators in Germany wants to make the Commission aware of the following aspects: Gas Market Regulation: - Mandatory Filling Levels for Gas Storage Facilities: It is understandable in the current situation that well-filled gas storage facilities with filling levels of 80 and 90 per cent, respectively, have to be ensured. A filling level of 40 per cent on February 1 should secure that protected customers are supplied even at the end of the winter period based on gas storage capacities. INES believes that these two obligations are sufficient. There is no need for a mandatory corridor. A filling level corridor that is predetermined at EU institutions does not reflect the technical abilities of gas storage facilities. Instead, fast cavern storage sites that were developed especially in Germany are unnecessarily put at a disadvantage. - Measures to Achieve Filling Levels (Art. 6b SoS-VO): INES welcomes the opportunity to obligate gas suppliers to put minimum amounts of gas in storage. The obligation of gas storage system operators to tender capacities is already well-established practice. INES opposes an expanded market role for gas transport system operators having regard to the essential unbundling rules applicable to internal market. It generally makes sense to use LNG terminals in such a way that Member States have equal opportunities to fill their gas storage according to politically desired minimum filling levels. INES opposes the use-it-or-loose-it principle; instead of depriving capacities INES proposes that storage system operators provide capacities on an interruptible basis to market area operators. - Measures to secure an economical operation of gas storage sites (missing in all legislative proposals): There is a need for regulatory instruments that secure a cost-covering operation of gas storage facilities. SoS Regulation: - Certification of Gas Storage System Operators: Certification of gas storage system operators within 100 working days should take into account average filling levels of gas storage facilities over the whole period between both target dates (not only filling levels on the single days of March 31). This way the fast-track procedure stays customized for relevant under-filled facilities. - Gas Network Tariff Discounts: Due to competitive reasons, discounts on entry and exit points should not only apply to gas storage facilities on transport network levels but also to storage facilities on distribution network levels. This way, a level playing field between different gas storage facilities is ensured.
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Response to Revision of EU rules on Gas

13 Apr 2022

INES thanks for the opportunity to participate in this consultation and hereby provides feedback on specific aspects of the Regulation that will directly and indirectly influence the gas storage sector. Key aspects of our feedback are: - Cross-subsidization hydrogen / natural gas networks: It seems quite absurd that the introduction of a so-called dedicated charge is proposed as it allows – even though in a limited way – for cross-subsidizing between hydrogen and natural gas networks. INES recommends avoiding this form of cross-subsidization through a dedicated-charge. - Rules on network tariff development: Comprehensive rules on the development of network tariffs should only be introduced under a “Network Code Tariff Hydrogen (NC TAR H2)”. - Introduction of an ENNOH: It is not quite understandable why the responsibility for a TYNDP for hydrogen is given to ENTSO-G. It should be made sure that the ENNOH is constituted on such a short-term that even the first TYNDP for hydrogen can be developed by ENNOH. If the European Commission does not include Storage System Operators in the term “system users and consumers” under Article 55, INES asks for clarification that Storage System Operators are explicitly to be included when developing network codes. - Market Evaluation of Renewable and Low-Carbon Gases: Article 8 formulates the task of Terminal and Storage System Operators (hydrogen and natural gas) to evaluate infrastructure demands for renewable and low-carbon gases every two years. These obligations should only be considered if the affected infrastructure operators are subject to a tariff regulation regime. - Transparency Rules for Terminal and Storage System Operators: INES assumes that with the exception of number 5 the transparency rules will only apply for regulated Storage System Operators. In addition, all considered transparency obligations should take into account existing platforms in order to ensure cost-effectiveness. - Security of supply through gas storage (Article 7b): INES considers obliging storage customers to store minimum volumes of gas [a)] to be ineffective as customers can avoid this obligation by not booking storage capacities. This puts the operation of storage facilities at risk. Tendering or auctions of the Market Area Operator to fill storages [b)] can provide effective market-based incentives to reach desired volumes in storage facilities. Managing strategic stocks of gas [c)] or taking over operation of storage facilities [d)] by network operators is absolutely concerning as this expansion of network operator tasks would unfold heavy negative implications for gas markets. - Harmonization of Gas / Hydrogen Qualities: To avoid cost-intensive adaptation necessities, INES recommends aiming for merely pure gas and hydrogen qualities at the level of gas transmission networks. In gas networks an admixture limit of maximum 1 per cent should be aimed for.
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Response to Revision of EU rules on Gas

12 Apr 2022

INES thanks for the opportunity to participate in this consultation and hereby provides feedback on specific aspects of the Directive that will directly and indirectly influence the gas storage sector. The central points of our feedback are: - INES proposes that certification of not only gases but all energy carriers should be regulated in a separate “Energy Certification Directive” (ECD). - INES understands that Article 33 formulating „ when technically and/or economically necessary” creates the liberty for every member state to decide that access regulation shall be introduced only at a later stage. Article 33 should be reduced to an access regulation (without tariff regulation). - INES welcomes that hydrogen networks can be developed in a market-based and competitive framework as long as hydrogen markets have not reached adequate maturity levels. - Member states should have sufficient liberties under Article 31 to decide upon further steps towards a tariff regulation. - INES welcomes the reporting rules for hydrogen networks as they constitute a well-balanced provision. - INES explicitly welcomes that network operators shall be unbundled not only vertically but also horizontally under Article 63. Unbundling operators of natural gas and electricity networks from operators of hydrogen networks provides for transparency on network tariff development, freedom of choice concerning connection customers, and a cost-efficient network development based on cost allocations that follow the costs-by-cause principle. - INES recommends that unbundling of accounts shall not be applied for hydrogen and gas storage system operators as they will not underly a tariff regulation regime in the medium- and long-term. - As recent academic studies and future modelling forecasts decreasing demands for natural gas networks, adding the aspect of decommissioning to the network development planning is imperative. - Transferring the binding, planned-economy approach of the TYNDP to the market-based storage sector would lead to fundamental contradictions.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

18 Nov 2021

Separate Legal Framework for Energy Certification The EU has committed to stronger action on climate change and reaching a carbon-neutral economy. This means greenhouse gas emission will not only have to be reduced in the energy sector but far beyond that. Against this background, resource efficiency and aspects of a circular economy become ever more important. INES believes that only certifying green electricity does not fulfil the requirements posed by this development. Even widening the scope of the current system to include certifications for carbon-neutral gases will not sufficiently allow for creating fact-based transparency on the usage of energy and resources, thereby laying the foundation for political action. INES recommends the introduction of a comprehensive energy certification system by means of an “Energy Certification Directive”. The systems should: - include all sources of energy, - assess them regarding all relevant climate and environmental externalities, - and ensure a full life-cycle assessment. In Article 21 a (union data base) the European Commission proposes to establish a union data base, which enables the backtracking of liquid and gaseous renewable fuels and recyclable fuels. The union data base is intended to collect and process information relevant for certification of energy carriers. From INES’ point of view, the idea of a union data base is too limited. Instead of the Union data base, a platform should be established at EU-level that makes it possible to operationalize a holistic certification system of all energy carriers without redundancy. This platform should function on the basis of the “book and claim” principle and serve the market. While the groundwork for certification should be defined, the operationalization (by appropriate service providers) can take place in the market itself. Life-Cycle Analysis to Assess Externalities To account for all relevant emissions of a life-cycle analysis (LCA) is necessary, that in addition to GHG emissions includes additional impact categories (see also analyses by ThinkStep) but remains simple and practicable. This also means setting uniform system boundaries. A complete LCA has to assess environmental effects in upstream chains (e. g. steel used in power plants) as well as energy flows and auxiliary materials. Assessing energy consumption could be simplified by using standard values – a procedure already carried out for implementing a carbon pricing scheme under the Fuel Emission Trading Act (Brennstoffemissionshandelsgesetz, BEHG) in Germany. Deletion of Certificates and Greenwashing Validity of certificates should be aligned with physical and chemical realities. A certificate should describe climate and environmental externalities per energy unit. When energy is consumed, certificates will be deleted accounting for the amount of energy consumed. Not every consumption will have to be attributed to the original energy, but deletion of certificates for the amount of energy consumption ensures that greenwashing is not an option. After all, certificates which are created by produced renewable energy, can only be deleted later, if energy is actually stored. As a result, a real value will be assigned to flexibility for renewable energies. Producing electricity from coal while commercializing it as green electricity, for example, would be ruled out. Conversion Losses and Differences in Efficiency Inevitable losses from conversions or storage will have to be taken into account by certification (deletion/conversion). An energy transformation will have to include deletion (e. g. wind power certificates) and renewal (e. g. green hydrogen) of certificates. Differences in efficiency are already addressed by the comprehensive framework for certificates (considering conversion losses, pricing externalities) described above- They would not have to be adjusted to technological developments by political correction factors as defined by law.
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Response to Revision of EU rules on Gas

10 Mar 2021

INES welcomes the opportunity to comment the combined Roadmap and Inception Impact Assessment on the Hydrogen & Gas Markets Decarbonisation Package. Please find attached INES Response to the consultation document.
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Response to Revision of the guidelines for trans-European Energy infrastructure

8 Mar 2021

Dear Sir or Madam, in the following I would like to give you an overview of our recommendations for the revision of the TEN-E-Regulation: - INES recommends, to accompany the conversion of gas storage facilities by subsidising in the initial phase of the market development, to avoid prohibitive prices and thus enable initial conversion of gas storage facilities. - INES welcomes the fact that hydrogen storage systems are principally covered by the TEN-E Regulation. However, from INES’ point of view it is incomprehensible why only those hydrogen storage systems, that are connected to the high-pressure hydrogen pipelines, are covered by the regulation. - According to Paragraph 1 (a), a PCI must be necessary for at least one of the “Corridors” and “Areas” in Annex I. However, there is no reference to hydrogen storage systems recognizable. INES recommends to create a reference to gas storage systems, for example in the “Areas” section. - According to paragraph 1 (c), a hydrogen storage facility must have a “significant cross-border impact” in accordance with Annex IV.1. Point (1) (e) is relevant for hydrogen storage systems. According to this, the requirement is: “the project aims at supplying directly or indirectly at least two Member States”. In this context the question arises as to when a hydrogen storage system supplies directly or indirectly at least two Member States. INES recommends, that a regulatory authority (e.g. ACER) defines under which requirements storage systems meet this criterion. - INES has taken note of the removal of natural gas infrastructures out of the TEN-E Regulation. The current discussions focus strongly on hydrogen as the promising future energy carrier. Nevertheless, the discussion should keep gas (in the terms of greenhouse gas neutral methane) in mind as an energy carrier. Via biomethane, existing gas infrastructure will still be able to play a role even in the context of a completely greenhouse-gas neutral energy supply. With regard to storage facilities, which do not have the prerequisites to accommodate pure hydrogen in the future, this is an important utilization path. In view of the two-thirds lower calorific value of hydrogen compared to gas (methane), the storage of methane offers advantages in terms of stored energy volumes. INES therefore recommends that in addition to the use of pure hydrogen, the energy potential of storing for example biomethane in gas storage facilities is kept in mind and the transformation is accompanied by subsidies as well. In our response attached you can find explanations in detail. Kind regards, Sebastian Bleschke
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