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International Association of Oil Gas Producers Europe

IOGP Europe

IOGP Europe represents the oil and gas industry and advocates for technology-neutral energy policies.

Lobbying Activity

Meeting with Elena Arveras (Cabinet of Commissioner Maria Luís Albuquerque)

26 Jan 2026 · Draft revised ESRS

Meeting with Florina-Andreea Pantazi (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs) and FuelsEurope and Concawe

22 Jan 2026 · REACH Universal PFAS Restriction

Meeting with Gabriela Tschirkova (Cabinet of Commissioner Valdis Dombrovskis), Nicolo Brignoli (Cabinet of Commissioner Valdis Dombrovskis)

21 Jan 2026 · Methane Emissions Regulation

Meeting with Lukasz Kolinski (Director Energy) and

20 Jan 2026 · Meeting with industry representatives on the EU Methane Regulation

IOGP Europe Urges Proportionate and Technology-Neutral EU Taxonomy Rules

5 Dec 2025
Topic — Commission initiative reviewing technical screening criteria to simplify the EU Taxonomy framework.
Message — The association requests outcome-based criteria and a proportionality principle to exempt activities with immaterial footprints. They seek technology-neutrality and the recognition of robust third-country regulatory systems as equivalent evidence.123
Why — This would reduce administrative burdens and provide better legal certainty for global operations.45
Impact — Entities currently transitioning from coal would lose their relative advantage over gas-fired operators.6
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Meeting with Mechthild Woersdoerfer (Deputy Director-General Energy) and

3 Dec 2025 · Implementation of the Methane Regulation 2024/1787 (EUMR)

Meeting with Pascale Piera (Member of the European Parliament, Shadow rapporteur)

25 Nov 2025 · Omnibus

Meeting with Michael Hager (Cabinet of Commissioner Valdis Dombrovskis)

24 Nov 2025 · Simplification: sustainability and energy omnibuses

Meeting with Ditte Juul-Joergensen (Director-General Energy)

21 Nov 2025 · Methane regulation

Oil and Gas Producers Call for Major Overhaul of Foreign Subsidies Rules

18 Nov 2025
Topic — Review of EU regulation on foreign subsidies distorting the internal market.
Message — The organization requests elimination or major simplification of merger notifications, significantly raised thresholds, and alignment with accounting standards. They argue the current system creates disproportionate burdens and should be replaced with existing FDI screening mechanisms.123
Why — This would substantially reduce their compliance costs and administrative burden from multiple overlapping regulatory processes.456
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Meeting with Andrzej Celinski (Cabinet of Commissioner Piotr Serafin) and Google and

18 Nov 2025 · Presentation on the state of play of the negotiations of the next MFF, with the special focus on communication activities.

Oil and Gas Industry Calls for Technology-Neutral EU Funding Framework

12 Nov 2025
Topic — European Competitiveness Fund design under the post-2027 EU budget framework.
Message — The organization requests a technology-neutral funding framework prioritizing proven decarbonization technologies like CCS and low-carbon hydrogen. They seek clear eligibility criteria for natural gas, predictable multi-year funding, and flexible implementation timelines for large-scale industrial projects.123
Why — This would secure funding for their CCS and hydrogen projects while maintaining gas infrastructure investments.45
Impact — Renewable energy advocates lose as fossil fuel infrastructure receives continued prioritization and funding.67
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Meeting with Elisabetta Gualmini (Member of the European Parliament)

4 Nov 2025 · ITRE Committee

Meeting with Kitti Nyitrai (Head of Unit Energy) and FuelsEurope and

3 Nov 2025 · EU Methane regulation import requirements

Meeting with Vita Jukne (Cabinet of Commissioner Jessika Roswall)

16 Oct 2025 · To discuss environmental omnibus (permitting)

Meeting with Andrea Wechsler (Member of the European Parliament)

14 Oct 2025 · Energy Policy

Oil and Gas Industry Urges EU to Preserve Market Flexibility in Energy Security Reform

13 Oct 2025
Topic — Revised EU energy security framework addressing gas supply, electricity resilience, and crisis preparedness.
Message — The organization requests that the EU avoid prescriptive diversification targets, preserve market-based approaches, and not make gas storage obligations permanent beyond 2027. They emphasize reducing regulatory complexity and ensuring natural gas plays a long-term role in supporting renewable integration.123
Why — This would preserve their access to global LNG markets and avoid compliance costs from prescriptive requirements.456
Impact — Climate advocates lose stronger measures to reduce fossil fuel dependency and methane emissions oversight.7
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Oil and Gas Industry Urges Broader State Aid Rules for Decarbonisation

6 Oct 2025
Topic — EU revision of rules exempting certain state aid from prior approval.
Message — The organization requests expanding exemption rules to cover all decarbonisation technologies, including low-carbon hydrogen and carbon capture. They seek higher aid intensities for up to 15 years and simplified approval processes through competitive bidding instead of detailed assessments.123
Why — This would unlock state aid for their fossil fuel transition investments without lengthy approval delays.456
Impact — Renewable energy projects lose preferential treatment as fossil fuel companies gain equal access to subsidies.78
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Oil and Gas Producers Seek Lighter Monitoring for Carbon Storage

22 Sept 2025
Topic — EU certification methodologies for permanent carbon dioxide removal activities.
Message — The organisation requests less strict monitoring requirements for storage sites, grandfathering of electricity rules for early projects, and clearer definitions of biogenic CO2. They argue current monitoring obligations are unnecessary and create barriers to investment.123
Why — This would reduce their compliance costs and provide investment certainty for early carbon capture projects.456
Impact — Environmental groups lose stronger safeguards against carbon leakage from storage sites and weaker permanence guarantees.78
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Meeting with Stefka Dzhumalieva (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

17 Sept 2025 · Discussions on Accelerating Permitting and on the proposed 2nd industry workshop on Industrial Permitting

Oil and Gas Industry Seeks Extended REMIT Data Reporting Deadlines

16 Sept 2025
Topic — Revision of EU wholesale energy market data reporting rules under REMIT.
Message — The organization requests at least 12 months implementation time after technical specifications are published, raising the exposure reporting threshold to 5 TWh/year, and extending OTC contract reporting deadlines to 20 days. They argue current timelines don't reflect operational constraints.123
Why — This would reduce their compliance costs and give them more time to adapt reporting systems.456
Impact — Market transparency suffers as delayed and limited reporting reduces regulators' ability to monitor trading activity.7
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Oil and Gas Producers Seek 12-Month Implementation Timeline for REMIT Changes

16 Sept 2025
Topic — EU rules on authorisation and supervision of energy market data reporting platforms.
Message — The association requests at least 12 months implementation time for all parties to make necessary changes, test and operationalize new data validation systems. They want commercial platforms to share updated technical specifications with clients on a clear timetable.12
Why — This would reduce their risk of improper inside information management and potential insider trading violations.3
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Oil and gas producers urge flexible CO2 market regulation

11 Sept 2025
Topic — EU initiative on developing competitive CO2 markets and transportation infrastructure.
Message — The organization requests a phased, flexible approach to CO2 infrastructure regulation that avoids premature rigid rules. They want light-touch early regulation allowing negotiated tariffs and exemptions, coordinated cluster-based public funding, and de-risking instruments like carbon contracts and loan guarantees.1234
Why — This would reduce regulatory constraints on early infrastructure projects and increase investment returns.567
Impact — Countries without storage sites face uneven access to decarbonization infrastructure and higher costs.8
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Meeting with Tatyana Panova (Head of Unit Financial Stability, Financial Services and Capital Markets Union) and Eurelectric aisbl and

1 Sept 2025 · JEAG position on commodity derivatives consultation

IOGP Europe seeks uncapped integration of carbon removals into ETS

8 Jul 2025
Topic — A review of the EU emissions trading system and the market stability reserve.
Message — The association calls for the direct and uncapped inclusion of permanent carbon removals into the carbon market. They also advocate for linking the EU and UK systems to improve market efficiency. Additionally, they support a technology-neutral bank to help finance large-scale decarbonization projects.123
Why — Uncapped integration of carbon removals would significantly reduce the industry's compliance costs.45
Impact — Environmental integrity could be compromised if temporary carbon removals are not strictly capped.6
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IOGP Europe Urges Increased Innovation Fund Budget and Technology Neutrality

7 Jul 2025
Topic — Evaluation of the Innovation Fund’s effectiveness in supporting industrial decarbonization technologies across Europe.
Message — IOGP Europe calls for a significant increase in the Fund's budget using carbon revenues. They request a technology-neutral approach that supports low-carbon hydrogen and carbon capture. They also demand reduced administrative complexity for applicants.123
Why — Technology neutrality would secure critical EU funding for members' capital-intensive carbon capture and hydrogen projects.45
Impact — Renewable projects may lose exclusive access to funding as resources are shared with low-carbon alternatives.6
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Oil and Gas Industry Seeks EU Recognition of International Carbon Schemes

1 Jul 2025
Topic — EU regulation establishing certification rules for carbon removals and storage verification.
Message — The organization requests that the EU recognize international carbon certification schemes like Puro.earth and Verra as equivalent to EU-approved schemes. They argue the current draft forces unnecessary recertification under separate EU schemes, creating administrative duplication without environmental benefit.12
Why — This would allow them to avoid recertifying under duplicate EU schemes while using existing international frameworks.34
Impact — EU regulators lose direct oversight over carbon removal verification standards and methodologies.56
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Meeting with Daniel Buda (Member of the European Parliament)

18 Jun 2025 · Omnibus packages

Meeting with Ondřej Krutílek (Member of the European Parliament)

17 Jun 2025 · Gas storage

Meeting with Beatrice Coda (Head of Unit Research and Innovation)

20 May 2025 · Exchange of views on possible support mechanisms for carbon capture and storage

IOGP Europe seeks Modernisation Fund expansion for gas and CCS

16 May 2025
Topic — This consultation evaluates the operating rules of the EU Modernisation Fund.
Message — The association requests including natural gas and carbon capture in funding eligibility. They also propose extending the fund's lifespan and allowing retroactive project financing.12
Why — Industry members would secure larger grants and financing for legacy gas assets.3
Impact — Pure renewable energy developers lose exclusive access to these specific climate funds.4
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Meeting with Cristina Lobillo Borrero (Director Energy)

13 May 2025 · Impact of the EU Methane Emission Regulation on EU security of gas supply

Meeting with Nicolo Brignoli (Cabinet of Commissioner Valdis Dombrovskis)

29 Apr 2025 · Simplification

IOGP Europe Urges Delay and Flexibility for CO2 Storage Goals

16 Apr 2025
Topic — New rules for oil and gas producers to contribute to EU CO2 storage targets.
Message — IOGP Europe seeks the postponement of the June 2025 deadline and a one percent threshold. They propose a structured dialogue to verify production data and the calculation factor used.123
Why — This would provide legal certainty and ensure companies are not penalized for infrastructure delays.456
Impact — Environmental advocates lose certainty because the proposal prioritizes investment decisions over actual operational capacity.7
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Oil and gas producers urge EU to slash reporting burdens

26 Mar 2025
Topic — The EU is consulting on simplifying sustainability reporting rules for companies under the Taxonomy.
Message — The group calls for removing financial data requirements for insignificant activities and making operational expenditure reporting optional. They also urge that reporting on partially aligned activities remain at the company's discretion.123
Why — This would significantly reduce the high costs and effort required to verify financial data.4
Impact — Investors lose detailed visibility into a company's smaller activities and overall sustainability performance.5
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Meeting with Elena Arveras (Cabinet of Commissioner Maria Luís Albuquerque)

19 Mar 2025 · Follow up to the omnibus

Meeting with Andreas Glück (Member of the European Parliament)

12 Mar 2025 · Climate and Energy Policy

Meeting with Jeannette Baljeu (Member of the European Parliament) and Uniper

11 Mar 2025 · CCS

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

5 Mar 2025 · Exchange on the Gas Storage Extension Regulation

Meeting with Kurt Vandenberghe (Director-General Climate Action)

5 Mar 2025 · “co-create” a roadmap that balances affordability, sustainability, and security

Meeting with Mariateresa Vivaldini (Member of the European Parliament, Shadow rapporteur)

4 Mar 2025 · Meeting conoscitivo

Meeting with Aura Salla (Member of the European Parliament)

20 Feb 2025 · Enhancing competitiveness by streamlining regulation and embedding a technology-neutral approach to drive innovation and cost-effective decarbonisation. Securing reliable and affordable energy + vital role of natural gas a transition fuel

Response to Delegated act on primarily used components under the Net-Zero Industry Act

19 Feb 2025

For IOGP Europe response, please consider the attached document.
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Meeting with Stefanie Hiesinger (Head of Unit Climate Action)

14 Feb 2025 · Discussion on Regulation 2024/1735 and an upcoming workshop organised by IOGP

Meeting with Ditte Juul-Joergensen (Director-General Energy)

14 Feb 2025 · Clean Industrial Deal and Affordable Energy Action Plan

Meeting with Adina Vălean (Member of the European Parliament)

6 Feb 2025 · Energy market in the EU and globally

Meeting with Kurt Vandenberghe (Director-General Climate Action)

6 Feb 2025 · Investissements en Europe

IOGP Europe urges technology neutrality and streamlined energy regulations

31 Jan 2025
Topic — This consultation seeks views on developing a single market for global competitiveness.
Message — The group requests a technology-neutral regulatory framework that prioritizes cross-border infrastructure and faster permitting. They also call for simplifying existing sustainability reporting rules and methane regulations.12
Why — These changes would reduce compliance costs and accelerate the deployment of their low-carbon technology investments.345
Impact — Transparency advocates and environmental groups lose if corporate sustainability and methane reporting requirements are reduced.6
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Meeting with Mirka Janda (Cabinet of Executive Vice-President Raffaele Fitto)

30 Jan 2025 · Presentation of the recommendations for the forthcoming Clean Industrial Deal.

Meeting with Eszter Lakos (Member of the European Parliament)

28 Jan 2025 · Energy policy

Meeting with Andrea Wechsler (Member of the European Parliament)

27 Nov 2024 · EU Energy and Industry Policy

IOGP Europe urges EU to prioritize domestic energy production

26 Nov 2024
Topic — The European Commission evaluates the effectiveness of current energy security legislative frameworks.
Message — IOGP Europe calls for the promotion of domestic oil and gas production. They request realistic demand outlooks and stable, non-prescriptive regulatory frameworks. The association argues that direct government interventions should be avoided.12
Why — Less regulation would reduce compliance risks and facilitate investment in gas infrastructure.3
Impact — Climate goals are threatened by a renewed focus on long-term fossil fuel infrastructure.4
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IOGP Europe seeks flexible methane and carbon storage rules

24 Oct 2024
Topic — A methodology for calculating life cycle greenhouse gas emissions for low-carbon fuels.
Message — The organization requests allowing actual values for methane intensity instead of default figures. They advocate for a grandfathering clause to protect projects past final investment decisions. Finally, they seek flexible alignment for carbon storage using international industry standards.1234
Why — This would reduce regulatory risk for massive infrastructure projects and lower compliance costs.5
Impact — Strict regulatory oversight may weaken if industry-led certification replaces direct government-to-government agreements.6
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Meeting with Pietro Fiocchi (Member of the European Parliament)

23 Oct 2024 · Oil and Gas

Meeting with Dan Nica (Member of the European Parliament) and ENEL SpA and

22 Oct 2024 · Debate on challenges and opportunities for the energy sector with focus on Romania and CEE Countries

Meeting with Ondřej Krutílek (Member of the European Parliament)

24 Sept 2024 · The role of natural gas and hydrogen in decarbonisation

Meeting with Andrea Wechsler (Member of the European Parliament) and BUSINESSEUROPE and

23 Sept 2024 · EU Energy and Industry Policy

Meeting with András Gyürk (Member of the European Parliament)

18 Sept 2024 · Overview of the priorities of the upstream oil&gas sector

Meeting with Jana Nagyová (Member of the European Parliament)

17 Sept 2024 · Meeting with IOGP

Meeting with Bart Groothuis (Member of the European Parliament)

16 Jul 2024 · CCUS

Meeting with Maroš Šefčovič (Executive Vice-President) and

16 Apr 2024 · IOGP Roundtable

Meeting with Nathalie Loiseau (Member of the European Parliament) and European Policy Centre and European Liberal Forum

3 Apr 2024 · Caucase du Sud

Meeting with Witold Jan Waszczykowski (Member of the European Parliament)

28 Feb 2024 · EU energy policy

Meeting with Daniel Mes (Cabinet of Commissioner Wopke Hoekstra)

23 Jan 2024 · industrial carbon management strategy

Meeting with Daniel Mes (Cabinet of Commissioner Wopke Hoekstra)

23 Jan 2024 · Industrial Carbon Management Strategy

Oil and gas producers urge 25% cut in EU reporting burden

1 Dec 2023
Topic — EU initiative to reduce administrative burden from reporting requirements by 25%.
Message — The organization requests streamlining the massive reporting framework, particularly for CSRD/ESRS obligations. They call for harmonization with international standards and company-level discretion on materiality assessments. They argue group-level reporting is preferable to avoid unrealistic value chain accountability.1234
Why — This would reduce their compliance costs by millions annually and cut staffing requirements.56
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Meeting with Kurt Vandenberghe (Director-General Climate Action)

25 Oct 2023 · 1. CCS in NZIA and beyond 2. Regulation on methane emissions reduction in the energy sector 3. IOGP Europe feedback on the DG CLIMA/DG ENER non-paper in light of the COP28 preparation

Meeting with Gerassimos Thomas (Director-General Taxation and Customs Union)

20 Oct 2023 · Physical meeting - Discussion on Commission report on the solidarity contribution (Council Regulation 2022/1854)

Meeting with Tsvetelina Penkova (Member of the European Parliament, Shadow rapporteur) and TotalEnergies SE and

11 Oct 2023 · Meeting with stakeholders (Exxon Mobile, Total Energies, Eni, IOGP)

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

25 Aug 2023 · Exchange on the Methane Regulation (staff level)

Oil and Gas Industry Urges Bold EU Carbon Capture Strategy

27 Jul 2023
Topic — EU strategy for deploying carbon capture, utilisation and storage to achieve climate neutrality.
Message — The organization requests trajectories without mandates, strong incentives including carbon contracts for difference, streamlined licensing procedures, and public funding. They want carbon management recognized across all sectors, not limited to residual industrial emissions.123
Why — This would attract global investment flows while reducing compliance costs and regulatory uncertainty.456
Impact — Environmental groups lose stricter limits on fossil fuel industry emissions and expansion.7
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Meeting with Frans Timmermans (Executive Vice-President)

18 Jul 2023 · Net Zero Industry Act proposal on CO2 injection target and oil and gas companies’ plans with respect to the need to transition to net zero emissions by 2050

IOGP Europe Urges Five-Year Delay for Sustainability Reporting Rules

7 Jul 2023
Topic — A consultation on mandatory European standards for corporate environmental and social reporting.
Message — The group requests delaying full reporting until 2030 and a five-year legal protection period. They also want to limit reporting to direct suppliers.123
Why — This would lower compliance costs and shield oil companies from potential legal liability.45
Impact — Transparency advocates and investors lose access to detailed data on corporate environmental impacts.6
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IOGP Europe warns CO2 storage targets must be achievable

19 Jun 2023
Topic — The consultation covers new legislation to scale up carbon capture and storage technologies.
Message — IOGP Europe requests that carbon storage targets remain objectively achievable and reasonable. They call for faster permitting and streamlined funding to de-risk investments.12
Why — Flexible mandates would prevent discriminatory costs and protect the industry's property rights.3
Impact — The public loses transparency if firms restrict access to essential geological data.4
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Meeting with Kurt Vandenberghe (Director-General Climate Action)

12 Jun 2023 · NZIA and the forthcoming Commission Communication on CCUS

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

24 May 2023 · Exchange on the Methane Regulation (staff level)

IOGP Europe Urges Simplification of EU Green Investment Rules

3 May 2023
Topic — The EU is establishing a classification system for environmentally sustainable economic activities.
Message — IOGP Europe wants the Commission to simplify rules to prevent confusion and inconsistent interpretations. They also request that reporting criteria recognize equivalent international laws for global activities.12
Why — Recognizing international standards would lower the cost of verifying green activities outside of Europe.3
Impact — Public oversight might suffer if simplification allows companies to use more aggressive reporting tactics.4
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Meeting with Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans) and ExxonMobil Petroleum Chemical and

25 Apr 2023 · Energy, environmental and digital challenges of our time

Meeting with Kurt Vandenberghe (Director-General Climate Action)

10 Mar 2023 · Green Deal Industrial Plan

Meeting with Peter Van Kemseke (Cabinet of President Ursula von der Leyen)

10 Feb 2023 · Exchange views on the Green Deal Industry Plan and present two studies on “Rebalancing Europe’s gas supply” and "Hydrogen4Europe study"

Meeting with Dimitri Lorenzani (Cabinet of Vice-President Maroš Šefčovič)

15 Dec 2022 · Discussion on strategic foresight

Meeting with Adina-Ioana Vălean (Commissioner) and

14 Dec 2022 · Study "Rebalancing Europe's gas supply"

Meeting with Frans Timmermans (Executive Vice-President)

24 Nov 2022 · Short and long-term perspectives for additional gas supplies for Europe in the context of the current energy crisis and future plans for CCUS technology deployment and the production of hydrogen in Europe

Meeting with Stéphane Séjourné (Member of the European Parliament)

22 Nov 2022 · Dossiers énergétique (équipe)

Response to Communication on revamping the SET Plan

2 Nov 2022

IOGP welcomes the proposal to update the Strategic Energy Technology (SET) Plan to align it with the Green Deal objectives and of REPowerEU. The current crisis requires adequate measures to support the existing energy infrastructure, increase security of energy supply and accelerate the deployment of low-carbon technologies such as low-carbon hydrogen and carbon capture use and storage (CCUS). In the following we share our views in particular on the role of CCUS and low carbon hydrogen for the update of the SET Plan. It is important that CCUS is kept in the scope of the SET Plan. CCUS is a proven technology that provides permanent and large-scale storage of CO2. Its scale-up is critical to achieve climate neutrality by 2050. CCUS allows emissions reduction especially in industrial processes with high mitigation potential like steel, cement, chemical and refining. We welcome the progress made by the CCU-CCS Implementation Working Group (IWG 9) where stakeholders and Member States identified key issues to accelerate the deployment of CCUS including issues related to Research & Innovation (R&I). We believe the work of the IWG 9 needs to continue and can also complement the activities under the EU CCUS Forum, including the upcoming Communication on the Strategic Vision on CCUS. We suggest that, while continuing to lay down specific targets for CCUS deployment and associated R&I priorities, the focus of the IWG 9 should include to track progress in Member States on CCUS deployment and to ensure that National Energy and Climate Plans (NECPs) are updated accordingly. We call the SET Plan to include a new workstream on hydrogen. Hydrogen, whether produced from renewable sources or from natural gas (using steam methane reforming with carbon capture and storage (CCS) or pyrolysis) will play an important role in the EU energy mix to achieve climate neutrality by 2050. In our view hydrogen produced from natural gas can have a key role in enabling a fast, low risk and cost-effective build-up of an hydrogen economy until renewable hydrogen is available at scale. For these reasons, we believe that an updated SET Plan should include a new dedicated workstream on Hydrogen which can would complement the work of the existing European Clean Hydrogen Alliance.Such a workstream can offer an institutional platform to Member States and relevant stakeholders to identify key issues related to R&I needed to scale-up hydrogen. In this context we strongly recommend to take an inclusive approach on all forms of hydrogen allowing a fair competition between all low-carbon technologies.
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Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans), Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans), Riccardo Maggi (Cabinet of Executive Vice-President Frans Timmermans)

13 Oct 2022 · IOGP study on gas supply diversification potential

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

14 Sept 2022 · Vorschlag einer Verordnung über die Verringerung von Methanemissionen im Energiesektor

Meeting with Milan Brglez (Member of the European Parliament)

7 Sept 2022 · EU gas policy

Response to Regulation on REPowerEU chapters

20 Jul 2022

Please find attached feedback from IOGP
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Meeting with Martin Hojsík (Member of the European Parliament, Shadow rapporteur)

8 Jun 2022 · Methane emissions, energy

IOGP urges EU to limit due diligence to direct suppliers

23 May 2022
Topic — The CSDDD proposal creates mandatory human rights and environmental standards for corporate value chains.
Message — IOGP suggests limiting due diligence to direct suppliers rather than the entire value chain. They request directors' duties cover only policy implementation and allow group-level compliance reporting.12
Why — Restricting scope avoids the unworkable burden of tracking fungible oil products through consumer markets.3
Impact — Communities harmed by indirect suppliers lose oversight if companies only monitor direct contractual partners.45
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Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans)

12 May 2022 · RePowerEU Plan and diversification of gas supplies

Meeting with Silvia Sardone (Member of the European Parliament, Rapporteur) and European Association for Coal and Lignite

3 May 2022 · Meeting on Methane Regulation

Meeting with Kadri Simson (Commissioner) and

28 Mar 2022 · Discussion on the 8 March Commission communication, the ongoing work to diversify gas supplies and diminish the fossil fuels supplies from Russia, IOGP ability to help in this process.

Response to Soil Health Law – protecting, sustainably managing and restoring EU soils

15 Mar 2022

Please find attached IOGP's feedback submission in response to the European Commission call for evidence on ´soil health – protecting, sustainably managing and restoring EU soils´.
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Response to Setting the Course for a Sustainable Blue Planet -Update of the International Ocean Governance Agenda

14 Feb 2022

Please find attached IOGP's feedback submission in response to the European Commission call for evidence on ´setting the course for a sustainable blue planet, an update of the international ocean governance agenda´.
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Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans), Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans) and GasNaturally

26 Oct 2021 · Energy transition

Response to Restoring sustainable carbon cycles

7 Oct 2021

IOGP supports the goals of the Paris Agreement and the EU’s ambition to reach climate neutrality by 2050. We recognize that there are many challenges on the road to meet this objective as the energy transition will require significant investments, new technologies, effective policies, and behavioural changes. To this end, IOGP welcomes the development of a long-term vision for sustainable carbon cycles and to kick-start the development of both technological and nature-based solutions to remove CO2 from the atmosphere, which should complement mitigation efforts under the European Green Deal. In order to reach the goal of climate neutrality by 2050, it is essential to capture CO2 from the atmosphere, and also directly from large point sources, and store it permanently. In this context, several modelling scenarios from the IPCC, International Energy Agency, Hydrogen4EU Study together with EU analysis have showcased that technology-based solutions, such as Carbon Capture and Utilisation (CCU) and Carbon Capture and Storage (CCS), as well as nature-based solutions are essential solutions for climate mitigation. As an example, the 2018 IPCC SR15 Report underlined that reducing emissions alone is no longer enough. The latest IEA Energy Technologies Perspective Report 2020 and the Net Zero by 2050 Report highlighted that CCU/S can make the fourth-largest contribution to the EU in reaching Net Zero Emissions. IOGP would like to share some key observations relevant for the upcoming Communication on carbon removal and carbon farming: 1. The Commission’s Communication should not only consider nature-based and technology-based carbon removal solutions but also carbon reductions/avoidance solutions, such as CCS and CCUS. Technologies such as CCS and CCUS are available at scale, proven and safe. They have the capacity to significantly contribute to negative emissions capture, possibly faster and more cost-effectively than nature-based solutions. Furthermore, a policy framework for storage for technology-based solutions, such as CCS through the CCS Directive, sets out transparent liability provisions. To this end, access to existing and new CO2 transport and storage infrastructure is needed and will accelerate the development of additional carbon dioxide removal (CDR), and carbon reduction/avoidance facilities. It is important that a framework, including financial incentives, is established for both nature-based and technology-based solutions to facilitate short deployment timelines encouraging activities leading to carbon reductions, removals and storage. 2. An EU-wide carbon removal certification (CRC) mechanism is needed which provides for a robust certification of carbon removals and should meet the following requirements: a robust Monitoring, Reporting, and Verification (MRV) framework; evolve over time accommodating new technologies, new carbon removal solutions and new MRV methodologies; transparent and harmonised framework across the EU. 3. Certified carbon removals must be valued to provide appropriate financial incentives to incentivise the uptake of CDR technologies. Under the current rules, the EU ETS does not recognise negative emissions. The establishment of a market for carbon removal certificates which recognises negative emissions and is compatible with the EU ETS is therefore needed to encourage a wider range of technology-based and nature-based technology investments. 4. We welcome the Commission’s proposals to account for all CO2 transportation modes in the revised EU ETS Directive, to establish provisions for accounting of CO2 within CCU processes, to introduce Carbon Contracts for Differences (CCfDs), and to bolster the Innovation Fund - which goes in line with recommendations laid out in the IOGP-coordinated Madrid Forum report on ‘The potential for CCS and CCU in Europe’. For further information, please see the attached document.
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Response to FuelEU Maritime

30 Sept 2021

The International Association of Oil & Gas Producers (IOGP) supports the goals of the Paris Agreement and the EU’s ambition to reach climate neutrality by 2050. We recognize that there are many challenges on the road to meet this objective as the energy transition will require significant investments, new technologies, effective policies and behavioural changes. We, therefore, welcome the proposed FuelEU Maritime Regulation that aims to take a technology neutral approach aiming to accelerate the achievement of lower-emission, climate-neutral shipping and ports by promoting the uptake of sustainable alternative fuels. In view of the European Commission proposal on the FuelEU Maritime Regulation, we would like to make the following recommendations: 1) Alignment with the international framework: IOGP recommends that any proposed changes are carefully aligned with the international framework in accordance with the approach under the International Maritime Organisation (IMO). As shipping is a global industry, it is important that any proposed changes under the proposal avoid having the effect of placing EU companies at a disadvantage by comparison with those outside of the EU. That could be done by ensuring coherence between regional and global measures. 2) Technology neutral GHG intensity targets: IOGP welcomes the goal-based and technology neutral approach recognizing that a basket of different fuels each evaluated on a “well-to-wake” can contribute to the proposed GHG intensity targets. This approach should ensure the valuable role of Liquified Natural Gas (LNG), which is a well-developed and market-ready fuel that can reduce carbon emissions in the immediate future. By investing in LNG-fuelled vessels now, ship-owners can realize immediate GHG benefits – up to 21% on a well-to-wake according to the CE Delft Study. Additionally, the European Maritime Safety Agency (EMSA) identified LNG as the cleanest option for maritime transport to significantly reduce its emissions which is available today. Furthermore, LNG has a low risk of creating a lock-in effect. In the longer run, the LNG based assets, with little or no modifications, can use non-fossil fuel methane such as liquified biomethane (LBM) and liquefied synthetic methane (LSM), initially as drop-in fuels. LNG could also be supplemented by other alternatives like hydrogen, methanol and ammonia. The value of LNG as a transitional fuel has been recognised in a recent joint report from EMSA and the EEA. In addition, the report highlights that LBM and LSM can be mixed with LNG, with the advantage that these alternatives can avail of technology and infrastructure that is already available. 3) Consider the benefits of low-carbon hydrogen: The proposal uses default emission values for hydrogen produced from natural gas without CCS (“grey” hydrogen). The proposal does not consider the emission benefits of “blue” hydrogen produced from natural gas with CCS, and should therefore be amended to include default values for “blue” hydrogen. For further information, please consult the attached document.
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Response to Updating the EU Emissions Trading System

30 Sept 2021

The IOGP supports the goals of the Paris Agreement and the EU’s ambition to reach climate neutrality by 2050. We recognize that there are many challenges on the road to meet this objective as the energy transition will require significant investments, new technologies, effective policies, and behavioural changes. IOGP supports carbon pricing as a primary tool to achieve emission reduction goals, as it incentivises the most cost-effective emission reductions. IOGP welcomes the Commission’s proposal to mandate Member States to use 100% of their EU ETS revenues for climate-related purposes and to further strengthen the Innovation Fund and the Modernisation Fund (MF). The Commission should be commended for its proposals to account for all CO2 transportation modes, to establish provisions for accounting of CO2 within Carbon Capture and Utilisation (CCU) processes, and to introduce Carbon Contracts for Differences (CCfDs) – which goes in line with recommendations laid out in the IOGP-coordinated Madrid Forum report on ‘The potential for CCS and CCU in Europe’. IOGP would like to make the following recommendations: Exclusion of natural gas projects from the scope of the MF would disregard the most cost-effective solution to support Member States on their respective transition pathways. In a 2050 perspective, investing in the production of natural gas and low-carbon gases, as well as in gradual technical adaptations of the EU gas infrastructure to carry hydrogen and other low-carbon gases, can contribute to climate neutrality while making use of existing infrastructure in a more cost-effective way. If the EU fails to take a technology neutral approach, the costs associated with MF projects risk becoming higher than necessary in relation to their GHG emission reduction potential, which could put an additional strain on beneficiary Member States. A comprehensive assessment should be carried out to determine if the proposed increase of the fund is proportionate to the tightening of the Linear Reduction Factor (LRF), and whether additional resources should be allocated to meet modernisation needs of beneficiary Member States. We welcome the increased EU climate ambition, however the associated price signals in the EU ETS resulting from the proposed increase of the LRF, the tightening of the Market Stability Reserve (MSR), as well as the gradual phase-out of free allowances will increase the need for an effective carbon leakage protection mechanism for the impacted EU ETS sectors to maintain a level playing field for EU producers when competing domestically and on export markets. Maintaining the current share of free allowances would enhance EU industries’ ability to foster investments necessary for the decarbonisation and would not affect the climate targets set out by the Fit for 55 package. Additionally, compliant entities should not be penalised for preparing for breakthrough technologies rather than investing in incremental energy efficiency improvements – therefore, acting on the results of energy audits should not be made obligatory through the EU ETS. This maintains R&D, employment and investment in the EU and safeguards the competitiveness of EU industry while avoiding carbon leakage. We support the near-term separation between the existing EU and the new ETS for road transport and buildings, given the different marginal abatement costs and market dynamics considerations. Longer term convergence to a uniform cost of carbon will enable emission reductions at lowest societal costs. However, considering the vulnerable character of households and the risk of mobility poverty as a result of proposed expansion of carbon pricing, we recommend the Commission to continuously assess the impact of proposed regulation on these sectors as well as adequacy of the proposed mitigation measures, and propose further mitigation measures if necessary. For further information, please see the attached document.
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Response to Carbon Border Adjustment Mechanism

30 Sept 2021

The IOGP supports the goals of the Paris Agreement and the EU’s ambition to reach climate neutrality by 2050. We recognize that there are many challenges on the road to meet this objective as the energy transition will require significant investments, new technologies, effective policies, and behavioural changes. The increased EU climate ambition and associated price signals from a revised EU ETS will increase the need for an effective carbon leakage protection mechanism for the impacted EU ETS sectors to incentivise emission reductions from a global perspective while avoiding deindustrialisation, loss of investment, and employment in the EU; as well as ensure a level playing field for EU producers when competing domestically and on export markets. Until global carbon pricing can be achieved, IOGP believes it is essential to adopt effective EU measures that avoid carbon leakage. We recognise that the CBAM proposal aims to establish a level playing field in an environment at a higher cost of carbon levels than in the current system based on the granting of free allowances and compensations for the increase in electricity costs under state aid rules. However, we highlight the need to safeguard EU industries from potential retaliation measures by 3rd countries and their consequent economic burden. Directly linking the pricing of CBAM to the EU Emissions Trading System (EU ETS), if designed well, can provide a level playing field that is fully transparent and demonstrates to 3rd countries how they can increase their own climate ambitions by adopting a comparable carbon price on their own products to avoid the CBAM. IOGP would like to make the following recommendations: An adequate carbon leakage protection mechanism needs to cover both imports and exports for the relevant EU ETS sectors as the granting of free allowances does today. Without free allowances, the absence of an export rebate mechanism in the proposed CBAM undermines not only EU export competitiveness, but can also undermine EU industry’s competitiveness on the EU internal market. Therefore, for CBAM to become an acceptable alternative to free allowances, the design will need to be expanded to include an export rebate mechanism. In the absence of a CBAM export rebate mechanism, a hybrid system needs to be put in place in order to continue providing a sufficient amount of benchmark-based free allowances while introducing an import-only CBAM on the emissions above the benchmark level. We emphasize that the primary objective of the CBAM must be to provide cost-effective carbon leakage protection in an environment of increasing carbon cost while minimizing trade distortion/tension. However, replacing the existing granting of free allowances with an inadequate CBAM as proposed (i.e. with no export rebate mechanism) will increase the cost of carbon to EU industries and thus also undermine the EU industry’s financial ability to address their full abatement costs. As the CBAM will generate additional revenues to the EU, these should be used in a technology-neutral manner to accelerate the development and deployment of climate change mitigation technologies, such as Carbon Capture Utilization and Storage (CCUS), and renewable and low-carbon gases. IOGP welcomes the European Commission’s proposal to include few selected sectors and implement the CBAM starting with a transitional period. This transitional period will allow the Commission, industry, and other stakeholders to learn and adapt the CBAM as needed. To address the carbon leakage risk better, and to avoid circumvention and a risk of a non-level playing field across industries, it is important to develop a comprehensive assessment of additional sectors, including complex goods that might be included in the scope of CBAM in the future phase. For further information, please see the attached document.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

30 Sept 2021

The International Association of Oil & Gas Producers’ (IOGP) supports the goals of the Paris Agreement and the EU’s ambition to reach climate neutrality by 2050. We recognise that there are many challenges on the road to meet this objective as the energy transition will require significant investments, new technologies, effective policies and behavioural changes. IOGP welcomed the Commission’s intention, as outlined in the EU Strategy for Energy System Integration, to establish a comprehensive terminology for all renewable and low-carbon fuels and a European system of certification of such fuels, based notably on full life-cycle greenhouse gas emission savings and sustainability criteria. In this context, we note that the scope the revised RED, following the Commission’s proposal, will remain limited to renewable fuels only, excluding other low-carbon fuels such as “blue” hydrogen. IOGP would make the following recommendations, to ensure that the EU energy and climate policy framework will enable all renewable and low-carbon fuels to play their role: 1) Introducing a certification system and incentives for low-carbon (including “blue”) hydrogen as part of the forthcoming Hydrogen and Decarbonised Gas Market package (gas package): IOGP proposes that the targets under the revised RED should be opened to both certified renewable and low-carbon fuels, or that a complementary system for incentives is put in place under the gas package with a view to allow for fair competition between “green” and “blue” hydrogen. In order to deliver on its commitments set out in the EU Strategy for Energy System Integration, the Commission should ensure that an EU certification system for low-carbon fuels is delivered through the gas package. This certification system should be carefully designed to be well compatible with the RED-based system for renewable fuels. 2) Taking a technology neutral approach to renewable and low-carbon hydrogen in order to achieve decarbonisation ambitions, including in the industrial and transport sectors: The RED’s proposal for sub-targets for RFNBOs to constitute 50% of all hydrogen used in industry and 2.6% of transport fuels creates potential challenges for the cost-effective development of hydrogen, and also for EU industry. IOGP recommends that all types of renewable and low-carbon hydrogen are enabled to meet the EU’s decarbonisation ambitions, including in the industrial and transport sectors. It is necessary for the gas package to complement the RED proposal, either by putting in place measures which would allow for low-carbon hydrogen to meet the targets set out in the RED, or by establishing a complementary and well-aligned system of incentives specifically for low-carbon hydrogen. Coherence between the RED and the forthcoming gas package must be ensured. 3) The renewables target in the heating and cooling sector should remain indicative: The Commission’s proposal for an annual mandatory increase of 1.1% on the national level, compared to the current 1.3% indicative target, may be economically and technically difficult to achieve and might also present a risk of destabilising the energy system in certain Member States. 4) The review of the RED presents a chance to further improve this policy instrument, enabling the EU to benefit from gases’ full contribution to the energy transition: IOGP believes that the review of the RED presents a chance to further improve this policy instrument in order to enable the EU to benefit from the contributions renewable and low-carbon gases can make to a successful and affordable energy transition. For further information, please consult the attached document.
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Response to Revision of the Energy Tax Directive

30 Sept 2021

The International Association of Oil & Gas Producers’ (IOGP) supports the goals of the Paris Agreement and the EU’s ambition to reach climate neutrality by 2050. We recognise that there are many challenges on the road to meet this objective as the energy transition will require significant investments, new technologies, effective policies and behavioural changes. The ETD should be an instrument that incentivises the use of all lower-emission and low-carbon energy technologies and fuels based on full life-cycle GHG emission criteria. It is essential that the tax treatment of natural gas and low-carbon gases in power generation, heating and transport reflect, inter alia, their contributions to reducing CO2 emissions. IOGP welcomes that the potential of these technologies has to an extent been taken into consideration in the Commission’s revision of the ETD. However, in order to fully capture their important role, IOGP would make the following recommendations: 1) Recognising the enabling role of natural gas throughout the energy transition: IOGP welcomes that the ETD proposal recognises natural gas as the fossil fuel with the lowest carbon intensity, which can contribute to reaching the EU’s energy and climate objectives. However, we regret that after a transition period (until 2033), the Directive will not distinguish between natural gas and other fossil fuels. In this context, we highlight that natural gas will still emit considerably less GHG than other fossil fuels also after 2033, and could continue playing a significant role. This should be reflected in the final revised ETD. The current ETD contains certain national exemptions for natural gas. We note that the Commission in its proposal seeks to remove these, and in this context we would highlight that restoring the possibility of applying total exemptions or reductions in the level of natural gas taxation could be important e.g. for the regions of Europe which will rely more strongly on natural gas in their energy transitions, as well as to ensure an energy transition which is affordable for consumers. 2) Equal treatment of hydrogen and electricity as clean energy vectors: IOGP welcomes that low-carbon fuels such as “blue” hydrogen are proposed to be eligible for a lower tax rate, equivalent to that of electricity. However, we regret that this lower rate would only be available to low-carbon fuels for a transition period until 2033, since the EU needs low-carbon fuels in its energy mix while it develops a market for hydrogen based on renewable power. Hence, we stress that in a cost-efficient pathway to climate neutrality, both electricity and low-carbon fuels will continue playing an important role in the energy system until 2050. The Hydrogen for Europe study estimates that the EU would save more than 2 trillion euros over the next thirty years in capital investments by allowing for a level playing-field between various technologies which can help deliver on the EU’s objectives. The study shows that – regardless of policy preference – large volumes of both blue and green hydrogen will be required to achieve net zero by 2050. In this context, IOGP would strongly advise that the final revised ETD treats hydrogen, as a clean energy vector, in the same way as electricity which is eligible for a lower tax rate regardless of its production method. As with electricity and in accordance with the EU Hydrogen Strategy, the emissions associated with hydrogen production may be expected to reduce over time. For further information, please consult the attached document.
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Response to Review of Directive 2012/27/EU on energy efficiency

30 Sept 2021

The International Association of Oil & Gas Producers’ (IOGP) supports the goals of the Paris Agreement and the EU’s ambition to reach climate neutrality by 2050. We recognise that there are many challenges on the road to meet this objective as the energy transition will require significant investments, new technologies, effective policies and behavioural changes. IOGP is aligned with the “energy efficiency first” principle. EU policymakers should, however, consider that in some sectors and regions it will be essential to support a more efficient use of fossil fuels. Furthermore, switching to renewable or low-carbon solutions will require more energy use, which is in contrast to the requirements of the energy efficiency target. In this context, IOGP is concerned that the EED proposal does not acknowledge the transitional role of natural gas or the potential of efficient natural gas-based technologies to contribute to the EU’s energy efficiency objectives. IOGP recommends that all technologies which can contribute to meeting the EU’s energy efficiency objectives, including natural gas, are recognised in the final revised EED. We deeply regret that Member States would not be able to rely on efficient natural gas-based technologies to meet their energy saving obligations following the Commission’s proposal. All technologies, including natural gas, which can contribute to meet the EU’s energy efficiency objectives while supporting emission reductions should be recognised in the final revised EED. Investments in more efficient natural gas-based technologies could also be beneficial in the future, if used with low-carbon gases such as hydrogen or biomethane. These technology options should not be excluded or discouraged. We furthermore regret that the proposal does not distinguish between natural gas and higher GHG intensity fossil fuels in its exclusion of all “direct fossil fuel combustion technologies”. The final revised EED should recognise natural gas as the fossil fuel with the lowest carbon intensity, in order to facilitate the energy transition in all regions of Europe and ensure consistency with other proposals under the Fit for 55 package which make this distinction. IOGP is concerned that the exclusion of natural gas, including highly efficient condensing gas boilers (which can reach an energy efficiency of up to 110%), and changing definitions for gas-based technologies such as district heating and CHP may impact in particular on the heating sector and the Member States’ ability to switch from coal to gas. In the EU, heating accounts for a third of EU GHG emissions and half of final energy demand. In Poland, half of the housing stock is still heated with coal, while the renovation rate needs to be improved to reach the desired 2.5% of floor area p.a. In their NECPs, a number of Member States outline that their heating sectors will rely, inter alia, on natural gas or natural gas-based CHP to reach 2030 targets. Member States face different challenges with reducing emissions from heating, and it is important to offer a wide range of realistic, affordable alternatives. Replacing inefficient and carbon-intensive heating technologies with condensing gas boilers is e.g. one solution that can immediately reduce CO2, NOx, SOx and PM emissions, improve air quality and increase efficiency at a significantly lower cost than alternatives. Using natural gas in district heating to replace coal or to provide back up to heat pumps in winter could also be a good transitional solution. Analyses by the IEA show that coal-to-gas switching in heating reduces emissions by 33%. An overview of scenarios for technology and market development for gas appliances in residential, commercial and industrial sectors is provided by GasNaturally. For further information, please see the attached document.
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Response to Revision of Non-Financial Reporting Directive

14 Jul 2021

Please find IOGP Europe's consultation response in the attachment.
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Response to Protecting the environment in the EU’s seas and oceans

5 May 2021

Please find attached IOGP's feedback submission in response to the Roadmap on 'Protecting the marine environment - review of EU rules'.
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Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans)

23 Apr 2021 · Preparation of the CCUS Forum and on-going work on hydrogen

Meeting with Mauro Raffaele Petriccione (Director-General Climate Action) and GasNaturally

13 Apr 2021 · Role of gas in decarbonisation

Response to Modification of the General Block Exemption Regulation for the Green Deal and the Industrial and Digital Strategies

1 Apr 2021

The International Association of Oil & Gas Producers’ (IOGP) member companies account for approximately 60-70% of oil and gas produced in Europe. IOGP supports the goals of the Paris Agreement and the EU’s objective of climate neutrality by 2050, and will work with policymakers to help create the measures which can enable the energy transition. Many challenges must be overcome to meet this objective, and the energy transition will require significant investments in low-carbon technologies, including corresponding infrastructure for producing, transporting and storing renewable and low-carbon gases, and effective policies driving their uptake. IOGP believes that the State aid framework, including the GBER, should facilitate investments in promising, innovative and scalable technologies that facilitate large-scale carbon emission reduction and management projects while maintaining the functioning of the internal energy market. Regulations and exemptions should be aimed at allowing for European industries to deliver the scale of projects required to meet the EU’s climate objectives, while, as a priority, maintaining competitiveness and a level playing field, and at the same time retaining key skills within the employment pool and attracting new talent. The State aid framework should reflect the needs arising from the transition period and the technological gap between the present state of the energy sector and its target configuration required to achieve the EU’s energy and climate objectives. Summary of recommendations: - The GBER should reflect new developments in CCS business models and related technologies, including by expanding its definition of infrastructure for CO2 to allow support for each component of the CCS value chain and for CO2 transport by all transport modalities. - Renewable and low-carbon gases, including hydrogen, should be incorporated in the GBER in a technology neutral manner to ensure that all renewable and low-carbon gases are enabled to compete on a level playing field, based on a standardised life-cycle assessment of their GHG emission performance. - The role of natural gas to support the transition should be recognised by maintaining scope in the GBER to support the use of natural gas to achieve emission reductions, e.g. as an alternative transport fuel, in displacing higher emitting coal plants, or in high-efficiency cogeneration. - Assess notification thresholds and aid intensities in consideration of the significant investments required, including research and innovation: Considering the significant investments required to meet the EU’s strengthened climate ambitions and the urgency with which action is required to transform into a climate neutral economy, the Commission should consider re-assessing notification thresholds and aid intensities in the areas of research and innovation and environmental protection to reflect new priorities. - Defining positive environmental benefits: Due to the significant legal uncertainty which would arise, IOGP advises against linking the State aid framework to the EU Sustainable Finance Taxonomy. - Modification of the definition of “energy infrastructure” in relation to gaseous fuels: A change in this definition is needed to enable the financing of infrastructure used for the transport of various types of gases and their blends. It is advisable to provide clarity in terms of gas installations and devices. They are crucial for the safe functioning of the system and results from the point of view of the end-users. - Modification of the Regulation as regards incentive effect: The provisions on the incentive effect should be amended to better take into account the specificities of large, linear infrastructure projects. Finally, IOGP believes that the revisions of the GBER’s Section 7 and the EEAG should be closely aligned to ensure consistency and complementarity. Please consult the attached document for further details.
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Response to Revision of EU rules on Gas

5 Mar 2021

IOGP response to the roadmap and inception impact assessment concerning revision of the 3rd Gas Package (Directive 2009/73/EC and Regulation No 715/2009) IOGP recommends that the impact assessment considers the following as the basis for its amendment consideration: • Ensure that the regulatory framework for decarbonisation of the gas sector builds on the achievements of the Internal Gas Market. • Enable gas-infrastructure-operators to develop and operate gas pipeline infrastructure for hydrogen and CO2 matching the gas sector key network regulatory requirements, including Third Party Access and unbundling. • Accommodate renewable and low-carbon gases in a technology neutral manner under the gas market rules. • Establish a credible, robust and manageable certification scheme based on voluntary guarantees of origin under RED II to valuing life cycle GHG intensity reduction of renewable and low-carbon gases. • Enable a competitive hydrogen commodity market irrespective of origin. • Strengthen consumer rights that mirror electricity market design. • Avoid undue gas quality restrictions at system entry points. • Recognise that for many applications electrification does not provide the best solution or a resilient energy system. • Ensure holistic infrastructure planning. • Recognise the significant role of TSOs and DSOs cooperation to take full advantage of opportunities to decarbonise gas sector. • Recognise the role that CCUS can play in reducing GHG emissions. For further details on each recommendation, please consult the attached document. The upstream oil and gas industry stands ready to provide further input to the upcoming consultations and play its role in delivering low-carbon solutions aimed at tackling climate change.
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Meeting with Mauro Raffaele Petriccione (Director-General Climate Action)

5 Feb 2021 · Hydrogen

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

19 Jan 2021

IOGP supports the development of standards, guidelines and, where appropriate, cost-effective and efficient regulation reducing methane emissions along the full energy (gas and oil, coal and biogas/biomethane) chains. We welcome the holistic approach, covering not only the energy sector, but also agriculture and waste. While voluntary efforts by individual companies are important, they do not on their own drive industry-wide change, and for that, full industry participation is required. When developing policy frameworks aiming at methane emissions reduction, it should be taken into account that technology to detect and measure methane emissions, despite recent progress, is in development stage; data on emissions is therefore not readily consistently available for all regions. As regards to the costs associated with mitigation measures, IOGP disagrees with the International Energy Agency statement that “indicates that around 40% of energy related methane emissions can be abated at no-net cost” as no in-depth economic analysis was provided. IOGP welcomes the Commission’s intention to deliver a legislative proposal on compulsory measurement, reporting, and verification (MRV) at company-level for all energy-related methane emissions, building on the Oil and Gas Methane Partnership (OGMP 2.0) methodology, as well as other methane regulatory requirements and incentives. IOGP regards a robust MRV standard of methane emissions as a vital element in policy frameworks that aim to reduce methane emissions along the energy chains, including those beyond the EU’s borders. When harmonizing the methane emissions reporting framework, overly additional administrative and technical burdens (such as double reporting) on the companies should be avoided. The Commission should drive toward not only internal EU consistency but the development of global consistency as well. Therefore, IOGP supports the EU to develop a credible MRV standard in cooperation with key global partners. IOGP also welcomes the Commission’s intention to deliver a legislative proposal on an obligation to improve Leak Detection and Repair (LDAR) on gas infrastructure, as well as any other production, transport or use of gas, including as a feedstock. IOGP member companies already have implemented LDAR programmes across many of their operations and several participate in voluntary industry initiatives. IOGP supports cost effective regulation which focusses on highest emission sources along the full supply chains of gas, oil and coal and biogas/biomethane. Where relevant, oil and gas industry is prepared to share learnings and experiences with other sectors. IOGP further recognizes that the Commission will consider legislation on eliminating routine venting and flaring in the energy sector covering the full supply chain. In this context we highlight that some EU member state regulations address routine venting and flaring already in detail taking into account complex safety and environmental aspects. Such existing regulations must be taken into account when developing EU wide regulations and care should be taken when defining the term “routine” and that new measures should proceed in support of, and alignment with, the World Bank’s flaring reduction initiatives.
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Meeting with Natalie Pauwels (Cabinet of Commissioner Janez Lenarčič)

15 Jan 2021 · Green Deal

Response to Revision of the Energy and Environmental Aid Guidelines (EEAG)

10 Dec 2020

The International Association of Oil & Gas Producers’ (IOGP) member companies account for approximately 90% of oil and gas produced in Europe. IOGP supports the goals of the Paris Agreement and the EU’s objective of climate neutrality by 2050, and will work with policymakers to help create the measures which can enable the energy transition. Many challenges must be overcome to meet this objective, and the energy transition will require significant investments in low-carbon technologies and effective policies driving their uptake. IOGP believes that the EEAG should facilitate investments in promising, innovative and scalable technologies that facilitate large-scale carbon emission reduction and management projects while maintaining the functioning of the Internal Energy Market. They should be aimed at allowing for European industries to deliver the scale of projects required to meet the EU’s climate objectives, while, as a priority, maintaining competitiveness, keeping existing and creating new jobs. This is essential both in the context of the European Green Deal and as the EU plans to recover from the COVID-19 crisis. We recommend adapting the EEAG to ensure that the future contributions of carbon capture and utilisation or storage (CCU and CCS) and low-carbon hydrogen from natural gas with CCS to the achievement of the EU climate neutrality objective by 2050 are adequately included. In addition, the EEAG should facilitate the safe, responsible and sustainable production of oil and gas in Europe, including allowing for support for emission reduction technologies. Continued oil and gas production in Europe will be required during the transition and provide the basis for the development of many necessary low-carbon technologies and their supply chains. Oil and gas from Europe is produced with a 40% lower carbon footprint compared to the global average. Maintaining oil and gas production also allows for the retention of the human and financial capital needed to develop CCS in Europe, as the technology relies on the same people, technologies and value chains. The attached paper includes IOGP’s recommendations for: 1) Adapting the EEAG to new developments in CCU and CCS 2) Incorporating low-carbon hydrogen from natural gas with CCS in the EEAG 3) Adapting the EEAG to facilitate the safe, responsible and sustainable production of oil and gas in Europe 4) Ensuring the eligibility of measures to reduce emissions from the production and use of oil and gas 5) Defining positive environmental benefits
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Response to Climate change mitigation and adaptation taxonomy

8 Dec 2020

The International Association of Oil & Gas Producers' (IOGP) member companies account for approximately 90% of oil and gas produced in Europe. IOGP supports the goals of the Paris Agreement and the EU's objective of climate neutrality by 2050 supported by adequate policies. One of them is a well-designed and inclusive sustainable finance framework. We welcome the EU's efforts to establish a set of coherent and consistent policy tools that will stimulate private investments required for projects and technologies aimed at reducing greenhouse gas (GHG) emissions, and support the transition to a sustainable future. Access to finance is critical for those investments and thus to maintain European competitiveness. IOGP congratulates the European Commission for the progress made in establishing a taxonomy for sustainable investments and appreciates the opportunity to provide this input to the development of the first Delegated Regulation: 1) This Delegated Regulation should ensure that "transitional activities" have their own dedicated Technical Screening Criteria (TSC) to reflect their transitional nature. 2) The Delegated Regulation should seek to be consistent with Article 19.1(a) of the Taxonomy Regulation, which highlights that the technical screening criteria should respect the principle of technological neutrality. 3) We welcome the Commission's proposals on low-carbon technologies such as carbon capture and storage (CCS) and hydrogen and recommend introducing some adjustments to ensure that the text is understandable and captures all projects and solutions devoted to these innovative technologies. 4) We endorse the TEG's recommendation to incorporate a section on carbon capture and utilisation (CCU) as also outlined by the Taxonomy Regulation (Article 10.1(e)). 5) Ahead of its publication, inconsistencies and clarity of different terms should be addressed to ensure that the Delegated Regulation will be user-friendly and understandable by all stakeholders: - To ensure that the Delegated Regulation is accessible to all users, its technical screening criteria for all economic activities should be defined coherently and understandably. 6) Alignment with existing recommendations and legislation is needed to comply with the Better Regulation principles: - We strongly call for the sustainability criteria for biofuels to be consistent and compliant with the whole body of existing EU legislation (e.g. the RED II, Directive 2018/2001). 7) Life-cycle analysis & usage of means of transport: Putting thresholds only on a tank-to-wheel (tailpipe) value is not at all appropriate and could even lead to more GHG emissions in real-world performance than shown by the reduction at the tailpipe. 8) Research, development and innovation will enable meeting the EU's climate neutrality objective by 2050: We welcome section 9.1 on R&D&I as innovation is a crucial driver to achieve a net-zero economy. We want to emphasise that reporting on taxonomy-compliant activities will require companies to review their reporting processes and establish new systems/reporting functionalities, and internal processes enabling changes in data collection, processing and assurance. Therefore, any disclosure must be material and create benefits for the users' of this data. Together with the timing of the Delegated Regulation on the technical screening criteria for mitigation and adaptation, and on the disclosure obligation by mid-2021, it will be extremely challenging to meet disclosure obligations for the financial year 2021 in the course of 2022. We, therefore, encourage the Commission to assess the possibilities to consider extending the timeframe for the implementation of the disclosure obligation or retain the principle of one or two pilot years. **** Please see attached further details of our comments to the draft Delegated Regulation.
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Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans)

8 Dec 2020 · TEN-E regulation

Response to Green Recovery for the Blue Economy (tentative)

4 Dec 2020

The International Association of Oil & Gas Producers’ (IOGP) member companies account for approximately 90% of the oil and gas produced in Europe. IOGP shares the world’s ambition to reach the Paris Agreement’s goals and supports the EU’s objective of climate neutrality by 2050 upon the implementation of enabling measures. Oceans and seas are important areas of operations for the European oil and gas industry, as more than 80% of its current oil and gas production takes place offshore. To protect the marine environment, exploration, drilling and production are conducted according to the highest industry standards and in line with the applicable EU legislation. IOGP also has access to a wealth of technical knowledge and experience with its members operating around the world in many different ocean governance frameworks, supporting goals of the 2030 Agenda for Sustainable Development, and in particular the Sustainable Development Goal on the Ocean (SDG14). We believe that the development of the EU’s more sustainable ‘blue economy’ should be based on cooperation of all relevant stakeholders, sharing knowledge and experience, and include all technologies that can contribute to the objectives of the EU Green Deal such as Carbon Capture and Storage (CCS), Carbon Capture and Utilization (CCU), renewable and low-carbon hydrogen, and Liquified Natural Gas (LNG). We therefore welcome this early opportunity to share our input and provide a set of recommendations that could be considered, while developing the sustainable blue economy: 1. A stable, predictable, and transparent regulatory framework. 2.New technologies to enable growth a)Carbon Capture Utilisation and Storage (CCU and CCS) b)Hydrogen (including low-carbon hydrogen produced from natural with CCS or pyrolysis) c)Re-purposing of existing offshore oil and gas infrastructure for CO2 and hydrogen transport and offshore renewable energy 3.Contribution to sustainable shipping sector 4.Industry and science collaborations Oil and gas industry is an important stakeholder in the blue economy. The sector’s long history of responsible operations in the maritime space and its experience, knowledge and skills should be used in building a sustainable blue economy for the future. To achieve the objectives of EU Green Deal, CCUS will be an integral part of meeting the ambitious GHG targets in 2030 and 2050, along with renewable and low-carbon hydrogen. Whereas, industry and science collaboration should play an important role in this process. We look forward to cooperating with all the relevant stakeholders, sharing our experience, knowledge regarding the ocean research and policy framework, and the outcomes of our many projects. Please refer to our attached paper for more information.
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Response to Protecting biodiversity: nature restoration targets

2 Dec 2020

The International Association of Oil & Gas Producers' (IOGP) shares the global ambition to reduce and reverse biodiversity loss in the framework of the UN Convention on Biological Diversity, the 2030 Agenda of Sustainable Development and supports the objectives of the EU's Biodiversity Strategy for 2030. IOGP, through the joint IPIECA-IOGP Biodiversity and Ecosystem Services Working Group (BESWG) has been working for 20 years to continuously improve Biodiversity and Ecosystem Services (BES) management with the oil and gas industry, including habitat conservation, restoration and (biodiversity) offsets. We support governments and civil society in achieving global and local restoration goals and contributing to enhanced scientific knowledge and science-based policy making. We are ready to continue working with all the relevant stakeholders, sharing our technical knowledge, experience, good practices, and assist in the improvement of the EU nature restoration regulatory framework. We would like to emphasize that it is essential to involve all relevant stakeholders in a transparent and inclusive consultation process throughout the policy making process establishing the nature restoration framework. We welcome this early opportunity to share IOGP views, including policy recommendations: Clarity of definitions and methodologies IOGP supports the proposal to establish legally binding EU nature restoration targets and an EU-wide legally binding methodology and provisions to map, assess and achieve a ‘good condition of ecosystems’. We believe that nature restoration is essential, and IOGP would support a regulatory framework setting realistic, science-based objectives that thoroughly take into account the limitations and implication of the different stakeholders. We would like to emphasize that clarity is required for industry regarding what this would entail and how the restoration target can be measured and monitored. To understand this objective, and therefore achieve it, a precise and clear definition of ‘good condition of ecosystems’ and how it can be reliably measured is absolutely necessary for all stakeholders. Any measures that are established in order to achieve the objective should be based on peer-reviewed scientific data. Habitat conservation Positive impacts on biodiversity conservation status through man-made infrastructure could also be considered in the revised EU regulatory framework. Empirical evidence is growing on the decommissioning of offshore man-made structures and their ecological benefits due to the construction of artificial reefs. The industry is involved in several ongoing work programmes evaluating the benefits to biodiversity of offshore structures. We would be glad to share the outcomes and ongoing research from one of them, such as INSITE Programme, with the EU institutions and other relevant stakeholders. IOGP is looking forward to collaborating with the EU institutions and all the relevant stakeholders, to sharing industry experience and knowledge from restoration projects in order to establish a realistic, and achievable restoration objectives.
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Meeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness), Peter Power (Cabinet of Commissioner Mairead Mcguinness)

18 Nov 2020 · EU Taxonomy Regulation

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

22 Oct 2020 · Sustainable Finance and Taxonomy

Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans), Damyana Stoynova (Cabinet of Executive Vice-President Frans Timmermans)

29 Sept 2020 · Energy System Integration – ideas for CCUS Forum

Response to Revision of the Renewable Energy Directive (EU) 2018/2001

21 Sept 2020

The International Association of Oil & Gas Producers’ (IOGP) member companies account for approximately 90% of oil and gas produced in Europe. IOGP supports the goals of the Paris Agreement and the EU’s objective of climate neutrality by 2050, and will work with the Commission to help create the essential measures to enable this energy transition. Many challenges must be overcome to meet the Green Deal’s ambition, and the energy transition requires significant investments, new technologies, effective policies and behavioural changes. On 8 July 2020, the Commission presented the Communications ‘EU Strategy for Energy System Integration’ (ESI Strategy) and ‘A hydrogen strategy for a climate neutral Europe’ (Hydrogen Strategy). The ESI and Hydrogen Strategies propose several actions that could require the modification of REDII which are addressed in the Commission’s inception impact assessment concerning the Renewables Directive review. IOGP welcomes the opportunity to provide feedback at this early stage in the legislative process. We have noted the Commission’s intention to promote the further development and use of renewable and other low-carbon fuels including gaseous fuels and hydrogen. In this context, we welcome the Commission’s plans to establish a comprehensive terminology for all renewable and low-carbon fuels and a European system of certification of such fuels, based notably on full life-cycle greenhouse gas emission savings and sustainability criteria. IOGP recommends that the impact assessment concerning the revision of REDII considers amending the Directive in order to: - Ensure that renewable and low-carbon gases can fully contribute to the achievement of the EU climate ambition - Establish a comprehensive terminology in a single legislative instrument that covers both renewable and low-carbon fuels applying a consistent EU wide methodology on a GHG life-cycle basis - Establish a robust certification system for renewable and low-carbon hydrogen by amending the provisions on Guarantees of Origin under REDII - Include life-cycle GHG performance for all low carbon and renewable fuels into the Guarantees of Origin information - Ensure a technology neutral approach in setting targets and providing support mechanisms - Enable all hydrogen production technologies which can deliver significant GHG emission reductions to compete on a level playing field - Provide regulatory predictability by avoiding that the possible changes to the Directive are disruptive to the long-term investment perspective provided under RED II Please see attached our explanation for the aforementioned recommendations.
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Response to Commission Delegated Regulation on taxonomy-alignment of undertakings reporting non-financial information

8 Sept 2020

The International Association of Oil & Gas Producers’ (IOGP) member companies account for approximately 90% of oil and gas produced in Europe. IOGP supports the goals of the Paris Agreement and the EU’s objective of climate neutrality by 2050 supported by adequate policies. One of them is a well-designed and inclusive sustainable finance framework. We welcome the EU’s efforts to establish a set of coherent and consistent policy tools that will unlock private investments required for projects and technologies aimed at reducing greenhouse gas (GHG) emissions, and support the transition to a sustainable future. Access to finance is critical for those investments and thus to maintain European competitiveness. IOGP congratulates the European Commission for the progress made in establishing a taxonomy for sustainable investments and appreciates the opportunity to provide this early input to the development of the Delegated Regulation on taxonomy-related disclosures by undertakings reporting non-financial information. This upcoming delegated act will be crucial for all corporates, including the oil and gas companies, to comply with the disclosure provisions during the forthcoming years. In this context, we take this opportunity to share our initial input to the ongoing work of the Commission: 1. Set workable timelines to achieve comprehensible reports 2. Ensure coherence between different tools 3. Adopt a flexible approach and include indicators for specific transitional activities 4. Adequate impact assessment and adherence to the Better Regulation principles need to be guaranteed Please find attached our further recommendations on this initiative.
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Response to EU Methane Strategy

28 Jul 2020

The European upstream oil and gas industry shares the world’s ambition to reach climate goals in the framework of the Paris Agreement and supports the EU climate neutrality objective by 2050. There are many challenges on the road to meet this objective. The energy transition will require significant investments and behavioural changes, and our industry is ready to contribute to these. Reaching the climate neutrality objective will require a considerable reduction of all greenhouse gases (GHGs), beyond carbon dioxide (CO2) emissions mitigation. In this context, we welcome the European Commission’s intention to present the EU Methane Strategy and appreciates the opportunity to provide our input at this stage. Indeed, methane (CH4) is the second most important GHG representing about 10% of total EU GHG emissions in 2017, which makes it a source to focus on when it comes to emissions reduction. The upstream oil and gas industry is strongly committed to and has already undertaken many steps to minimise GHG emissions, including flaring and venting from its own operations, and to support the mitigation of methane emissions elsewhere along the gas value chain. Oil and gas companies have successfully been working for many years to reduce methane emissions through mandatory and voluntary programmes (including through the World Bank GGFR). The attached paper outlines the IOGP (International Association of Oil & Gas Producers) views, including policy recommendations, in the context of the planned EU Methane Strategy. In some areas, the tools of the European gas market – including infrastructure regulation, network planning and sharing of Best Available Techniques (BATs) and equipment - can be leveraged to identify and mitigate emissions from natural gas value chain within Europe.
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Response to Revision of the EU Emission Trading System Monitoring and Reporting Regulation (MRR)

24 Jul 2020

Please see attached the feedback from the International Association of Oil & Gas Producers.
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Meeting with Aliénor Margerit (Cabinet of Commissioner Paolo Gentiloni)

22 Jun 2020 · Green Deal

Response to A EU hydrogen strategy

8 Jun 2020

The International Association of Oil & Gas Producers’ (IOGP) member companies account for approximately 90% of oil and gas produced in Europe. IOGP supports the goals of the Paris Agreement and the EU’s objective of climate neutrality by 2050 upon the implementation of enabling measures in particular to avoid carbon leakage. Many challenges must be overcome to meet this objective, and the energy transition requires significant investments, new technologies and behavioural changes. IOGP welcomes the European Commission’s intention to present the strategy on hydrogen in Europe and appreciates the opportunity to provide our input at this stage. We agree that clean hydrogen, as defined in the Roadmap, has strong potential to play a vital role in decarbonisation, in particular for hard-to-abate sectors (e.g. heavy-duty transport and energy-intensive industries) as they require high-temperate heat and cannot easily be electrified. We support a strategy which comprises all clean hydrogen production pathways, including from renewable electricity, natural gas reforming with CCS (carbon capture and storage) and methane pyrolysis. We also recognise that different technologies might play different roles depending on the timeline, with natural gas reforming to lead in the near term, allowing other emerging technologies to develop and scale up. What matters is the ability to cost-effectively reduce GHG (greenhouse gas) emissions at scale and contribute to reaching the EU 2050 climate-neutrality objective. It is in this perspective that 22 Member States’ National Energy and Climate Plans (NECPs) foresee a role for hydrogen in the decarbonisation of their energy systems. IOGP is in favour of using existing (e.g. the Madrid Forum, the Infrastructure Forums) and future platforms to share experiences and best practises and to further contribute to the definition of an integrated energy system which should include all forms of clean hydrogen. In this context, we welcome the Commission’s proposal to establish a European Clean Hydrogen Alliance as part of the EU Industrial Strategy and would be pleased to contribute to it with our ongoing research projects. Last year, we commissioned “the Hydrogen for Europe pre-study” which assessed the potential benefits of hydrogen in the energy transition. To build up on this work, with 17 industry actors from the oil and gas, gas transmission and hydrogen sectors, IOGP is participating in the Hydrogen for Europe study. ‘Hydrogen for Europe’ is a research project carried out over the course of 2020 by research institutes IFPEN and SINTEF and managed by Deloitte. The aim is to assess how hydrogen can contribute to the EU’s goal of reaching climate neutrality and the milestones on the path to 2050. We are certain that in addition to contributing to climate neutrality, hydrogen can also help to stimulate economic development. Today, 70% of hydrogen production comes from natural gas; if decarbonised with CCS, it will accelerate the establishment of clean hydrogen value chains. Such a development would create a new low-carbon industry and jobs, with the potential to account for 24% of final energy demand and 5.4m jobs by 2050. For this reason, IOGP calls on policymakers to create a solid framework that incentivises the development of clean hydrogen and other low-carbon gases. Scaling up all forms of clean hydrogen is an opportunity to demonstrate Europe’s commitment to decarbonising the economy while creating high-quality jobs for citizens.
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Response to Revision of the guidelines for trans-European Energy infrastructure

8 Jun 2020

The International Association of Oil & Gas Producers (IOGP) welcomes this opportunity to provide initial feedback on the upcoming review of the Regulation on guidelines for Trans-European Energy Infrastructure (TEN-E). The European upstream oil and gas industry shares the world’s climate ambition in the framework of the Paris Agreement and supports the EU’s ambition of reaching climate neutrality by 2050 upon implementing enabling measures. In the context of the European Green Deal, it is important that the framework for energy infrastructure is reviewed in order to take into consideration the transformation required by various sectors. Therefore, the priority should be to include the energy transition objectives while safeguarding the already substantial achievements of the internal gas market. As recently highlighted by EVP Timmermans, in the press conference presenting the Recovery Plan for Europe ‘the use of natural gas will probably be necessary to shift away from coal to sustainable energy’. In the short term, switching from coal to natural gas in power generation would significantly reduce up to 60% CO2 emissions (in the power sector). We recommend supporting early-stage deployment and development of new business models for technologies such as CCS (Carbon Capture Storage) and CCS-enabled hydrogen to achieve the Paris Agreement objectives. A number of planned CCS projects in Europe aim to transport CO2 from one country to another for storage, by pipeline or other modes of transport such as by ship or truck. They will take place in hubs and clusters where different industries will share infrastructure for transport and storage, allowing for economies of scale through a cross-sectorial and cross-border industrial system. In this context not only CO2 transport but also CO2 storage may have a cross-border dimension, therefore helping those and industrial players that cannot store CO2 locally. For this reason, it is key to have in place a robust policy framework enabling the entire CCS value chain. In a 2050 perspective, investing in i) the production of all forms of clean hydrogen (from natural gas reforming with CCS, renewable electricity, methane pyrolysis), and ii) technical adaptation of the EU gas infrastructure to carry clean hydrogen, will contribute to climate neutrality while making use of the existing infrastructure in a cost-effective way.
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Response to Commission Communication – "Renovation wave" initiative for the building sector

8 Jun 2020

The International Association of Oil & Gas Producers’ (IOGP) member companies account for approximately 90% of oil and gas produced in Europe. The European upstream oil and gas industry shares the world’s ambition to reach climate neutrality in the framework of the Paris Agreement and supports the EU’s objective to reach climate neutrality by 2050 upon the implementation of enabling measures. There are many challenges on the road to meet this objective, as the energy transition will require significant investments, new technologies, effective policies and behavioural changes. IOGP welcomes the Commission’s intentions as outlined in the Renovation Wave roadmap to draw on Member States’ National Energy and Climate Plans (NECPs) and Long-Term Renovation Strategies (LTRSs), to incorporate elements from other Commission initiatives, and to foster deeper renovation and decarbonisation rates in view of the 2050 climate neutrality objective. Achieving affordable, efficient heating with a lower carbon footprint will require investments in a wide range of technological solutions adapted to local needs. IOGP recommends to strengthen the Renovation Wave initiative by: 1. Focusing on cost-effectiveness in building renovation by ensuring competition between projects and technologies delivering energy savings, CO2 emissions reductions, improvement of air quality and other environmental benefits. 2. Incorporating elements of the Energy System Integration strategy to enable an increasing share of hydrogen and low-carbon gases in the existing gas infrastructure and contribute towards climate neutral residential, commercial and industrial heating in Europe. 3. Supporting the EU industrial sector and enabling the deep decarbonisation of the construction industry through incentivising the decarbonisation of industrial processes and the uptake of low-carbon construction materials. For further details, please consult the attached document.
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Meeting with Frans Timmermans (Executive Vice-President)

5 Jun 2020 · Clean energy investments and sustainable finance, solutions for transport decarbonisation, power generation and heating, hydrogen and CCS

Meeting with Adina-Ioana Vălean (Commissioner) and

2 Jun 2020 · Green deal

Response to Strategy for smart sector integration

29 May 2020

The International Association of Oil & Gas Producers’ (IOGP) member companies account for approximately 90% of oil and gas produced in Europe. IOGP supports the goals of the Paris Agreement and the EU’s objective of climate neutrality by 2050 upon the implementation of enabling measures. Many challenges must be overcome to meet this objective, and the energy transition requires significant investments, new technologies, effective policies and behavioural changes. IOGP welcomes the European Commission’s intention to present an EU Strategy for Energy System Integration, and appreciates the opportunity to provide our input at this stage. Today’s energy sector in the EU is the result of the completion of the Third Energy Package, which for natural gas meant the development of an internal market for natural gas in Europe. With respect to the market for natural gas, this objective has largely been achieved at the wholesale market level for the major gas-consuming markets in Europe. Where there are still gaps in individual Member States, these should be addressed under the existing regulatory framework in terms of better implementation of the existing legislation and binding network codes. In some regions across Europe, additional efforts might be necessary to continue diversification of natural gas supply sources. Nevertheless, we believe that it is the right time to develop an energy system which would build on this success in a cost-effective manner, leading to decarbonisation by integrating various energy sources, increasing energy efficiency and linking them to the existing internal energy market(s) and end users. The upcoming Strategy should safeguard the achievements in the internal gas market, maximise the use of market-based and technology-neutral instruments for achieving EU climate objectives while minimising potential distortive effects from regulatory measures. Please read more in the attached document and here: https://www.oilandgaseurope.org/wp-content/uploads/2020/05/IOGP_Energy-Sector-Integration-__response-consultation.pdf
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Meeting with Mauro Raffaele Petriccione (Director-General Climate Action)

19 May 2020 · Hydrogen and CCS

Response to Climate Law

30 Apr 2020

The International Association of Oil & Gas Producers’ (IOGP) member companies account for approximately 90% of oil and gas produced in Europe. IOGP shares the world’s ambition to reach the Paris Agreement’s goals and supports the EU’s objective of climate neutrality by 2050 upon the implementation of enabling measures. There are many challenges on the road to meet this objective, as the energy transition will require significant investments, new technologies, effective policies and behavioural changes. IOGP welcomes the long-term predictability that the Climate Law aims to provide. The climate neutrality target, as well as interim targets on the pathway to 2050, need to be accompanied by an enabling policy framework. EU policies, including EU financing and funding mechanisms, should facilitate a cost-efficient energy transition which leaves no one behind. A holistic, technology-neutral approach will be necessary to reach decarbonisation objectives at least cost. This will help safeguard the EU’s global competitiveness and ensure continued long-term public support for addressing climate change. Implementation of the EU’s current climate targets requires each Member State to bear costs as outlined in previous impact assessments accompanying EU energy and climate policies. Adjusting the EU’s trajectory towards 2050 will impact on these policies, and adjustments which result in increased costs will necessitate additional support for those Member States facing the highest transition challenges. Thorough and transparent impact assessments will, therefore, have to be carried out regularly between now and 2050, with benefits, costs and trade-offs clearly communicated to the public. Broad stakeholder consultation will ensure a practical pathway for implementation and avoid unintended consequences and inefficiencies. IOGP welcomes the opportunity to provide feedback to the proposed Climate Law, and encourages the Commission to consider the below recommendations: 1. Using the NECPs as a basis for EU-level planning: The European Climate Law should draw on the National Energy and Climate Plans (NECPs) in the process of setting the EU’s trajectory towards the 2050 target. This would ensure support for the decarbonisation efforts of each Member State and for EU policies that enable an affordable and just energy transition. 2. Ensuring thorough, transparent and regular impact assessments towards 2050: The European Climate Law should take into account that detailed, thorough and transparent impact assessments will need to be carried out regularly between now and 2050 to ensure that all objectives are being progressed during the energy transition. 3. Enabling all solutions and energy carriers on the pathway to climate neutrality: The European Climate Law should ensure that future EU policies enable all technology solutions and energy carriers to contribute to the EU climate neutrality target as well as the interim targets on the pathway to 2050. 4. Taking a global approach: The European Climate Law should allow for cooperative approaches and international transfers of mitigation outcomes. This would enable the achievement of greater global ambition over time by helping countries to meet their climate pledges faster and more cost-effectively. For further details, please consult the attached.
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Response to FuelEU Maritime

24 Apr 2020

The International Association of Oil & Gas Producers’ (IOGP) shares the global ambition to tackle climate change in the framework of the Paris Agreement and supports the EU’s objective of climate neutrality by 2050. There are many challenges on the road to meet this objective as the energy transition will require significant investments, new technologies, effective policies and behavioural changes. We, therefore, welcome the EU’s initiative to accelerate the achievement of lower-emission, climate-neutral shipping and ports by promoting the uptake of sustainable alternative fuels. Furthermore, we appreciate the European Commission’s recognition of the critical challenges to decrease greenhouse gas (GHG) emissions from the shipping industry, such as the current lack of regulatory predictability and high risk of investment choices, technological aspects, price factors, interdependency issues and avoidance of carbon leakage. In its upcoming assessment, the European Commission should, therefore, consider a wide range of existing and emerging solutions that could assist with decreasing carbon in the sector and help reduce overall emissions. Our industry is looking forward to working closely with all relevant stakeholders in the future to offer sustainable and cost-effective solutions. We further elaborate on this below as a response to the inception impact assessment of the FuelEU Maritime initiative with a focus on liquefied natural gas (LNG) and hydrogen, as these technologies could contribute to a reduction of emissions in the maritime sector. Overall, IOGP supports a holistic approach to the decarbonization of shipping through the deployment of a wide range of low-carbon and low-emission fuels (like LNG/bio-LNG, synthetic LNG, ammonia, methanol, liquids such as bio- and e-fuels or hybrid options). Any approach to reduce shipping emissions should consider societal costs of GHG abatement along the full value chain (from ship design to port infrastructure and fuel R&D) and the carbon leakage potential. As the CO2/GHG released during the production of fuels/energy carriers can differ significantly, regardless of whether they are fossil, bio, synthetic or non-carbon, the lifecycle assessment of all considered fuels needs to be appropriately performed to reflect the holistic GHG emission reduction potential correctly. In this context, the oil & gas industry is rapidly mastering its methane emissions, with best performers spreading their good practices in the entire sector (through initiatives like OGCI, IPIECA, Methane Guiding Principles), while the methane slip in new generation motors is divided by two. Finally, we believe that global solutions to lowering CO2 emissions from the shipping industry should be sought. We, therefore, encourage any measures introduced by the EU to be compatible with and complementary to IMO measures. This approach should not in any way be taken as a reason to slow down the EU’s ambition, but rather a design consideration to ensure transparency and future integration of any European measure back into a global system (i.e. by using IMO based definitions and using the same baselines and accounting methodologies). Further details of our views are elaborated in the attached response.
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Response to Climate change mitigation and adaptation taxonomy

20 Apr 2020

FuelsEurope (representing the EU refining sector) and IOGP (the International Association of Oil & Gas Producers) welcome the EU’s efforts to establish a sustainable finance framework that unlocks private investments in projects and technologies to reduce the impact on the environment, reduce greenhouse gas (GHG) emissions and support the transition of industry to a sustainable future. IOGP supports the goals of the Paris Agreement and the EU’s objective of climate neutrality by 2050. The energy transition will require significant investments and behavioural changes, supported by enabling policies. The more the EU can steer investments towards the least-cost pathway to net-zero emissions, the further and faster it is likely to drive decarbonisation across Europe, maximising the EU’s contribution to the delivery of the Paris climate goals. For this reason, we call for alignment between the taxonomy and its thresholds with the least-cost pathway to climate neutrality recognising all technologies available to reduce emissions. We congratulate the European Commission and the Technical Expert Group (TEG) on the progress made so far in establishing a taxonomy for sustainable investments, and we welcome the opportunity to provide our input at this stage. We would also like to express our interests in participating in the Platform on sustainable finance to contribute to the development of the future delegated acts. We take this opportunity to make the following recommendations: 1. The principle of GHG emission reduction based on a life-cycle analysis & technology neutrality should drive the development of the Taxonomy delegated acts 2. The delegated acts should clearly define “transitional activities” 3. The delegated acts should introduce gradual thresholds 4. Delivering the energy transition with CCUS (carbon capture, utilisation and storage) and hydrogen 5. Inclusive approach is key to the EU Taxonomy success Additionally, we encourage you to read our detailed comments to the TEG Technical Annex available under the following link: https://www.oilandgaseurope.org/wp-content/uploads/2020/04/IOGP_Initial_Comments_to-TEG-Technical-Report.pdf
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Response to 2030 Climate Target Plan

15 Apr 2020

The International Association of Oil & Gas Producers’ (IOGP) member companies account for approximately 90% of oil and gas produced in Europe. IOGP shares the world’s ambition to reach the Paris Agreement’s goals and supports the EU’s objective of climate neutrality by 2050. There are many challenges on the road to meet this objective as the energy transition will require significant investments, new technologies, effective policies and behavioural changes. The EU 2030 and 2050 GHG reduction targets need to be accompanied by an enabling and coherent policy framework that provides a business case to invest in the low-carbon technologies needed to deliver the ambitious objectives. EU policies, including EU financing and funding mechanisms, should, therefore, facilitate a cost-efficient energy transition while ensuring that no one is left behind. It is also essential that EU policies provide a predictable investment climate and security for investors and the real economy actors as their decisions are based on the long-term investment cycles. Current climate targets for 2030 are the results of intensive negotiations and their implementation requires each Member State to bear the costs specified in the impact assessments accompanying the ETS Directive, RED II, EED or “Clean Planet for All”. Any change to the current targets will involve a detailed assessment of all these policy tools. We, therefore, support the Commission’s intent to take a holistic approach towards the impact assessment of the “2030 Climate Target Plan” as it is of utmost importance to ensure complementarity between different legislative instruments while avoiding any overlap. As stakeholder input across all industries will ensure a practical pathway for implementation and avoid unintended consequences and inefficiencies, IOGP welcomes the opportunity to provide our initial feedback to the Impact Inception Assessment “2030 Climate Target Plan”, and encourage the Commission to consider the following recommendations: 1) International context should be considered in the upcoming impact assessment 2) National plans should be considered as the main input in the development of the impact assessment 3) Reviving the EU economy and industry post-COVID-19 while reducing emissions should be the backbone of the upcoming impact assessment 4) There is no silver bullet to achieve the 2030 climate targets: all solutions & carriers should be taken into account 5) Involvement of stakeholders throughout the process and social aspects are needed to ensure a successful implementation of policies The European upstream oil and gas industry stands ready to provide further input to the upcoming consultations and play its role in delivering low-carbon solutions aimed at tackling climate change. **** Please find attached our detailed feedback to the Impact Inception Assessment “2030 Climate Target Plan”.
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Response to Fast-track interservice consultation on the 'SEIP including a JTM and the JTF"

9 Mar 2020

The International Association of Oil & Gas Producers’ (IOGP) member companies account for approximately 90% of oil and gas produced in Europe. The European oil and gas industry contributes €420 billion per year to European government revenues, equivalent to 2.7% of EU GDP, and employs over 600.000 people in the extraction of crude petroleum and natural gas, support activities for petroleum and natural gas extraction, and the manufacture and distribution of gas. The European upstream oil and gas industry shares the world’s ambition to reach climate neutrality in the framework of the Paris Agreement and supports the EU’s objective to reach climate neutrality by 2050. IOGP welcomes the opportunity to provide feedback to the Proposal for a Regulation establishing the Just Transition Fund (JTF), and to underline the importance of natural gas and low-carbon technologies such as carbon capture and storage or utilisation (CCS and CCU) to an affordable and just transition. We note that the JTF proposal excludes from its scope of support “investment related to the production, processing, distribution, storage or combustion of fossil fuels;” failing to adequately: a) Distinguish between the use of high-carbon resources such as coal and lower-carbon resources such as natural gas on the pathway to decarbonisation; b) Consider the potential use of natural gas in combination with low-carbon technologies in a climate neutral economy. In this context, we encourage the Commission to take into consideration the below recommendations: 1) Recognising the role of natural gas in transitioning to a lower carbon economy. The JTF should support Member States on their pathways to decarbonisation and a gradual and affordable transition by including in its scope fuel-switching to natural gas in a transitional phase. 2) Recognising the role of all low-carbon technologies required to reach climate neutrality. In order to effectively mobilise investments in all technologies and solutions for low-carbon energy and GHG reductions required to achieve the EU’s climate neutrality goal, the scope of the JTF should be clarified to include both renewables and low-carbon gases (such as hydrogen), as well as both nature-based carbon management and CCS and CCU applied in the industrial and energy sectors. 3) Including analysis and assessment of impacts on both employment and government revenues. In addition to taking into account impacts on employment, it would be important within the framework of the territorial just transition plans and/or NECPs to take into account the impacts of the transition on government revenues and to manage these responsibly through identifying new opportunities for revenue. For further details, please consult the attached document.
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Response to Revision of Non-Financial Reporting Directive

27 Feb 2020

The International Association of Oil & Gas Producers’ (IOGP) member companies account for approximately 90% of oil and gas produced in Europe. IOGP welcomes the world’s ambition as laid out the framework of the Paris Agreement. There are many challenges on the road to meet this objective, and the energy transition will require significant investments, new technologies, effective policies and behavioural changes. Our industry is ready to contribute to this change and to the EU’s ambition of reaching climate neutrality by 2050. The overarching goal of meeting growing energy demands while lowering emissions is driving a structural change in the industry, which is keen to show to the outside world how it is contributing to the energy transition. In this context, our industry supports meaningful corporate reporting policies relating to disclosure of non-financial information pertaining to sustainability issues. IOGP members have contributed to the development of the Task Force on Climate-related Financial Disclosures (TCFD) recommendations and many members are using them already. We are convinced that effective non-financial reporting is in the interest of the industry’s shareholders as much as in the interest of society. For this reason, we welcome the opportunity to provide our initial feedback to the Impact Inception Assessment on the revision of the Non-Financial Reporting Directive (NFRD) and have the following recommendations: 1) Disclosures should focus on ‘material’ and relevant information, in order to enable socially responsible investment analysis and sustainable investment decisions. 2) A flexible approach is needed. 3) A reporting framework should enable companies to improve their reports and ultimately their performance.
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Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans)

17 Feb 2020 · Green Deal work programme: TEN E review, smart sector integration

Response to Climate Law

6 Feb 2020

The International Association of Oil & Gas Producers' (IOGP) member companies account for approximately 90% of oil and gas produced in Europe. The European oil and gas industry shares the world's ambition to reach climate neutrality in the framework of the Paris Agreement. There are many challenges on the road to meet this objective, and the energy transition will require significant investments, new technologies, effective policies and behavioural changes. Our industry is ready to contribute to this change and to the EU's ambition of reaching climate neutrality by 2050. IOGP welcomes the long-term predictability that the Climate Law aims to provide. It needs to be accompanied by an enabling and coherent policy framework to provide a business case to invest in the low-carbon technologies needed to deliver on climate neutrality, as well as the milestones on the way to 2050. We welcome the opportunity to provide our initial feedback to the Climate Law Roadmap, and encourage the Commission to consider the below recommendations: 1. The development of a European Climate Law allowing cooperative approaches and international transfers of mitigation outcomes would enable the achievement of greater ambition over time by helping countries meet their climate pledges faster and more cost-effectively. 2: The European Climate Law should support Member States in their decarbonisation efforts and recognise the crucial role of natural gas in transitioning to a lower carbon economy. Alongside other EU policies, including EU financing and funding mechanisms, the European Climate Law should enable a gradual, affordable energy transition. 3: The European Climate Law should provide a stable, long-term framework for EU policies that drive investments in low-carbon technologies such as carbon capture, utilisation and storage (CCU and CCS) and low-carbon fuels (both gases and liquids), and recognise the role that solutions provided by the oil and gas industry can play in reaching a climate neutral EU economy. 4: The European Climate Law should take into account that thorough and transparent impact assessments will need to be carried out regularly between now and 2050 to ensure that all objectives are being progressed during the transition. For further details, please consult the attached paper.
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Meeting with Dara Murphy (Cabinet of Commissioner Mariya Gabriel)

31 Jan 2020 · European Green deal implications for oil and gas producers

Meeting with Kurt Vandenberghe (Cabinet of President Ursula von der Leyen)

29 Jan 2020 · European Green Deal

Meeting with Kyriacos Charalambous (Cabinet of Commissioner Johannes Hahn)

29 Jan 2020 · Green deal, Investment Plan, Renewable Energy

Meeting with Catherine Sustek (Cabinet of Vice-President Margaritis Schinas)

16 Jan 2020 · Green Deal

Meeting with Ditte Juul-Joergensen (Director-General Energy)

17 Dec 2019 · Green Deal, methane emissions and decarbonisation

Response to European Partnership for Clean Hydrogen

27 Aug 2019

IOGP's member companies accound for around 90% of oil and gas produced in Europe. The oil and gas industry is committed to support the EU in reaching its energy and climate objectives, and has already started an evolution along different low-carbon pathways. IOGP commends the Commission's support of coordinated action in the area of hydrogen R&I, and welcomes the proposed European Partnership for Clean Hydrogen building on the success of the existing FCH 2 JU but with a significantly revised scope. In order to secure a partnership that delivers on creating a clean hydrogen sector in Europe that is strong, innovative, competitive and capable of supporting and enabling the energy transition as outlined in the Commission Communication 'A Clean Planet for all', IOGP encourages the Commission to consider the below recomendations: 1. Opening up for the use of hydrogen in all sectors; 2. Allowing for a wide range of clean hydrogen technologies, including technologies based on natural gas, carbon capture and storage (CCS) and carbon capture and utilisation (CCU); 3. Involving a wide range of stakeholders along the hydrogen value chain, including providers of natural gas feedstock and CO2 capture, transport and storage solutions; 4. Including innovation in business models, processes and market creation for clean hydrogen. For further details, please consult the attached document.
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Response to Commission Delegated Regulation establishing the Innovation Fund

11 Jan 2019

IOGP welcomes the opportunity to provide input to the European Commission on the Draft delegated regulation establishing the Innovation Fund. IOGP’s member companies account for around 90% of oil & gas produced in Europe. The oil & gas industry is committed to help the EU reach its energy and climate objectives, and has already started an evolution along different low-carbon pathways. We welcome the European Commission’s work in building the future Innovation Fund – a key tool to enable the implementation of CCS and other low-carbon technologies allowing the European economy to remain competitive. We welcome the Draft delegated regulation, which already includes important lessons learned from the NER300 experience. Still, in order to secure an Innovation Fund that delivers, IOGP asks the European Commission to consider the recommendations for key design proposals to keep, design proposals to consider changing and points for clarification in the attached document.
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Meeting with Elina Melngaile (Cabinet of Vice-President Valdis Dombrovskis) and FuelsEurope

12 Nov 2018 · Sustainable Finance and Taxonomy

Meeting with Mauro Raffaele Petriccione (Director-General Climate Action)

15 Oct 2018 · Long-Term Strategy and Carbon Capture and Storage

Meeting with Dominique Ristori (Director-General Energy)

13 Sept 2018 · energy policy

Response to Institutional investors' and asset managers' duties regarding sustainability

22 Aug 2018

The International Association of Oil & Gas Producers (IOGP) is following with great interest developments in the area of sustainable finance and appreciates the opportunity to provide our input at this stage. We are convinced that the following recommendations will contribute to the establishment of a robust, credible, efficient and technology-neutral taxonomy to reach its goal i.e. encouraging the needed investments to address the risks of climate change and other pressing global challenges highlighted by the United Nations (UN) Sustainable Development Goals (SDGs): • Establish a flexible approach towards defining “green/sustainable projects” by developing a graduated rating scale instead of a binary and simplistic approach for the “taxonomy”. • In the upcoming metrics, consider the socio-economic impact of a given investment: competitiveness, total government revenues and job creation are main prerequisites to create a prosperous European Union, while protecting environment. • Create a “Talanoa Platform on sustainable finance” comprised of and leveraging from representatives from major economic sectors to provide multi-sectorial technical expertise to the newly created expert group on this matter. • One size doesn’t fit all: national differences need to be taken into account. • All current or future-oriented and promising technologies that could help in reducing CO2 emissions should be considered when developing the framework on “taxonomy” and follow up implementing rules. • Given the global investment flow, any rules on sustainable finance should be discussed and implemented within the UN, OECD and at G20 level.
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Response to Institutional investors' and asset managers' duties regarding sustainability

22 Aug 2018

The International Association of Oil & Gas Producers (IOGP) is following with great interest developments in the area of sustainable finance and appreciates the opportunity to provide our input at this stage. We are convinced that the following recommendations will contribute to the establishment of a robust, credible, efficient and technology-neutral taxonomy to reach its goal i.e. encouraging the needed investments to address the risks of climate change and other pressing global challenges highlighted by the United Nations (UN) Sustainable Development Goals (SDGs): • Establish a flexible approach towards defining “green/sustainable projects” by developing a graduated rating scale instead of a binary and simplistic approach for the “taxonomy”. • In the upcoming metrics, consider the socio-economic impact of a given investment: competitiveness, total government revenues and job creation are main prerequisites to create a prosperous European Union, while protecting environment. • Create a “Talanoa Platform on sustainable finance” comprised of and leveraging from representatives from major economic sectors to provide multi-sectorial technical expertise to the newly created expert group on this matter. • One size doesn’t fit all: national differences need to be taken into account. • All current or future-oriented and promising technologies that could help in reducing CO2 emissions should be considered when developing the framework on “taxonomy” and follow up implementing rules. • Given the global investment flow, any rules on sustainable finance should be discussed and implemented within the UN, OECD and at G20 level.
Read full response

Response to Institutional investors' and asset managers' duties regarding sustainability

22 Aug 2018

The International Association of Oil & Gas Producers (IOGP) is following with great interest developments in the area of sustainable finance and appreciates the opportunity to provide our input at this stage. We are convinced that the following recommendations will contribute to the establishment of a robust, credible, efficient and technology-neutral taxonomy to reach its goal i.e. encouraging the needed investments to address the risks of climate change and other pressing global challenges highlighted by the United Nations (UN) Sustainable Development Goals (SDGs): • Establish a flexible approach towards defining “green/sustainable projects” by developing a graduated rating scale instead of a binary and simplistic approach for the “taxonomy”. • In the upcoming metrics, consider the socio-economic impact of a given investment: competitiveness, total government revenues and job creation are main prerequisites to create a prosperous European Union, while protecting environment. • Create a “Talanoa Platform on sustainable finance” comprised of and leveraging from representatives from major economic sectors to provide multi-sectorial technical expertise to the newly created expert group on this matter. • One size doesn’t fit all: national differences need to be taken into account. • All current or future-oriented and promising technologies that could help in reducing CO2 emissions should be considered when developing the framework on “taxonomy” and follow up implementing rules. • Given the global investment flow, any rules on sustainable finance should be discussed and implemented within the UN, OECD and at G20 level.
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Response to Strategy for long-term EU greenhouse gas emissions reductions

9 Aug 2018

The International Association of Oil & Gas Producers (IOGP) welcomes the opportunity to share its input to the Roadmap “Strategy for long-term EU GHG emissions reductions”. With the following set of recommendations, we believe this Strategy can be successful and meet the objectives of the Energy Union. A cleaner & more efficient energy system • By using flexible natural gas combined with variable renewables in power generation. • By supporting economy-wide policies which will incentivise the most cost-efficient solutions to reduce GHG emissions, including carbon pricing mechanisms. • By using LNG and CNG in road and maritime transport to allow public entities and businesses to improve air quality. A more secure energy supply • Support exploration & production of untapped domestic oil & gas resources. • Foster collaboration between regulators and industry to remove operational and commercial barriers. • Ensure the effective implementation of the existing Offshore Safety Directive, before developing new rules. • Implement existing Internal Gas Market rules across all EU Member States • Enhance diversification, security of supply and market interconnectivity through continuing the Connecting Europe Facility (CEF) and European Projects of Common Interest (PCIs). A more innovative energy union • Expand Research, Development and Innovation programmes for all promising non-mature technologies with long-term carbon reduction potential. Include technologies such as natural gas-to-hydrogen, low-emission liquids, and CCUS. • Make CC(U)S development an EU energy & climate and industrial policy priority by setting up a CC(U)S Alliance. • Focused support by the Commission and Member States is required to enable investment in full scale CCUS projects. This includes the deployment of the Strategic Energy Technology CCS and CCU Implementation Plan, the ETS Innovation Fund, and Horizon Europe. A holistic approach to methane emissions • The upcoming EU strategy on methane emissions should address all sectors emitting CH4 and also take into account the oil & gas industry's proactive efforts to address methane emissions.
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Response to Evaluation of the Directive on safety of offshore oil and gas operations

30 May 2018

Please find attached IOGP's feedback submission in response to DG Energy's Offshore Safety Directive Review Roadmap. Thank you Christian Schwarck
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Response to Fitness check on public reporting by companies

7 Mar 2018

"Delays in transposition of Accounting Directive makes Chapter 10 review premature at this stage" The International Association of Oil & Gas Producers (IOGP) brings together some of the world's leading publicly-traded, private and state-owned oil and gas companies, industry associations and major upstream service companies. IOGP has closely followed the development of the European Commission’s and other multilateral institutions policies related to the improvement of the transparency principles. We believe that good governance in resource-rich countries is crucial for the delivery of long-term development. The EU Accounting Directive has now been transposed into national law by all EU Member States and our members have been or are preparing to report according to Chapter 10 provisions. In addition, a number of members are reporting according to other international regulations, primarily Canada’s ESTMA, and await the draft implementing rule on section 1504 from the SEC in the United States. IOGP developed industry guidance “The Reports on Payments to Governments Regulations 2014” (http://www.iogp.org/bookstore/product/the-reports-on-payments-to-governments-regulations-2014-industry-guidance/) to support a more harmonised interpretation of the Accounting Directive (Chapter 10) in the UK. Our experience has shown that: - Transposition by Member States was slow, with some missing the implementation deadline. - This means reporting obligations stemming from Chapter 10 of the EU Accounting Directive and the Transparency Directive for EU-listed companies remain in their infancy. To date reports have been published, for instance, by the UK, France based companies. In case of the UK, the reports were published in 2015 and 2016. - More time is needed to allow lessons to be learned from initial reports, from obligations stemming from other international reporting legislation. For the reasons outlined above, we would advise to review the Accounting Directive (Chapter 10) at a later stage, when more experience is acquired under the current rules.
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Meeting with Dominique Ristori (Director-General Energy)

12 Feb 2018 · Energy policy

Response to Commission proposal for a Directive amending Directive 2009/73/EC

31 Jan 2018

The feedback of the International Association of Oil and Gas Producers (IOGP) can be found in the attachment.
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Response to Commission Delegated Regulation establishing the Innovation Fund

19 Jul 2017

IOGP welcomes the Commission’s work in building the future Innovation Fund and we would like to share our views on the key technology features and criteria to be taken into consideration in the future implementing Regulation in particular for the development of CCS.
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Meeting with Dominique Ristori (Director-General Energy)

6 Dec 2016 · Energy policy

Meeting with Jos Delbeke (Director-General Climate Action)

9 Nov 2016 · Revision of the EU ETS post-2020

Response to Interservice consultation on a Commission proposal for the GES Decision

12 Oct 2016

IOGP welcomes the opportunity for Oil and Gas operators to share their views on the draft amendment to MSFD Annex III and on the draft GES Decision. We welcome the clarification of the relationship between the Descriptors, the characteristics, the pressures and the impacts elements (Annex I and III MSFD) on the one hand and the criteria and indicators (GES Decision) to be used, on the other. Same is true regarding the importance of a risk-based approach for criteria, the need to focus on “main anthropogenic pressures” (Rec. 6) and the fact that threshold values should be set at appropriate geographic scales and not necessarily at EU level to better reflect regional characteristics (Rec. 13 and Art. 4c). IOGP recommends however to amend the Decision as follows: • Rec 13 - “Thresholds values should reflect, the quality level that constitutes a significant adverse effect for a criterion …”; • Art. 4 par. 1b - “distinguish the quality level that constitutes an significant adverse effect for a criterion and be set in relation to a reference condition”; • and the criteria for D11 as: ”The spatial distribution, temporal extent and levels of anthropogenic impulsive sound sources do not exceed values that have significant adverse impacts on marine animals populations”. Similar adaption is recommended for D2, D5, D6, D7 and D10. IOGP finds it necessary to amend the above vocabulary for the following reasons: • It is important to focus on “predominant pressures and impacts” (Art. 8 par.1 MSFD and Decision Rec. 6); The collective pressure of human activities needs to be kept within levels compatible with the criteria and indicators of good environmental status, ensuring that the capacity of marine ecosystems to respond to human-induced changes is not compromised (Decision Rec. 14). • To ensure consistency with other EU legislation like Birds & Habitats Directives or Environment Impact Assessment Directive and the Environment Liability directive, pressures not having a significant adverse effect, i.e. pressures allowing that “species are maintaining themselves on a long-term basis as a viable component of their natural habitats (…)” (Natura 2000 legislation) should not be considered as predominant pressures. • The magnitude of the adverse effect, i.e. “significant”, should be stated in the criteria, in Rec. 13 and in Art/ 4 par.1 as Decision provisions are binding and should not conflict with other legislation mentioned above. Only in those circumstances will the setting of thresholds values help to determine the extent to which GES is achieved (Rec. 6, 12 and 15). In line with the Convention on the Biodiversity - decision XII/23, our recommendation is to enable quantification of “impact” severity, and distinguish significant from non-significant adverse effects, by means of including the word “significant”. For eg. mortality of a reproductive female in an endangered population is by far more significant than a minor behavioral response such as a change of movement of said animal. IOGP also recommends ensuring better consistency between Regional Sea Conventions provisions. For example in the last phrase of Decision Rec. 3 the words” where relevant” should be replaced by “in their absence, upon” to be consistent with Rec. 12 and 18. The first phrase of Rec. 12 should be replaced by “In cases where no criteria, methodological standards, specifications and standardized methods for monitoring and assessments, Member States should endeavor to use those developed through regional and subregional cooperation …” to ensure consistency with Rec. 3 and 18. The reference to best available science foundation should not be deleted in the Decision Rec. 13 and to better ensure consistency with Rec. 20 it is recommended to amend GD Rec.13 as follows: “ Where a scientific foundation is not available, thresholds values should be set on the basis of the precautionary principle (…)”.
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Meeting with Friedrich-Nikolaus von Peter (Cabinet of Commissioner Violeta Bulc)

24 Feb 2016 · issues related to the Energy Union objectives

Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)

18 Feb 2016 · upcoming winter package

Meeting with Mathieu Fichter (Cabinet of Commissioner Corina Crețu)

11 Feb 2016 · Winter Gas Package

Meeting with Emma Udwin (Cabinet of Vice-President Johannes Hahn)

11 Feb 2016 · security of gas supply

Meeting with Daniel Giorev (Cabinet of Vice-President Kristalina Georgieva)

3 Feb 2016 · Energy Union Policy

Meeting with Kilian Gross (Digital Economy)

2 Feb 2016 · upcoming winter package

Meeting with Soren Schonberg (Cabinet of Commissioner Margrethe Vestager)

29 Jan 2016 · Energy Union

Meeting with Daniel Calleja Crespo (Director-General Environment)

26 Nov 2015 · Hydrocarbons BREF

Meeting with Dominique Ristori (Director-General Energy)

13 Apr 2015 · Oil & Gas

Meeting with Karl-Friedrich Falkenberg (Director-General Environment)

1 Apr 2015 · Hydrocarbon BREF and LCP BREF

Meeting with Maroš Šefčovič (Vice-President)

12 Jan 2015 · Energy Union

Meeting with Gonzalo De Mendoza Asensi (Cabinet of Vice-President Miguel Arias Cañete), Joachim Balke (Cabinet of Vice-President Miguel Arias Cañete), Maria Cristina Lobillo Borrero (Cabinet of Vice-President Miguel Arias Cañete)

16 Dec 2014 · Hydrocarbons BREF; new production of energy in Europe