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NaTran

NaTran

NaTran (formerly GRTgaz) operates gas transport networks in Europe and develops infrastructure for renewable gases, hydrogen and CO2 transport to support energy transition.

Lobbying Activity

Meeting with Jens Geier (Member of the European Parliament)

10 Dec 2025 · Exchange on Hydrogen Grid Development

Meeting with Christophe Grudler (Member of the European Parliament)

9 Dec 2025 · Politique énergétique européenne

NaTran urges EU to support gasification in circular economy

27 Oct 2025
Topic — The EU is developing a Circular Economy Act to improve resource efficiency.
Message — NaTran requests that gasification be included in renewable targets and funding schemes. They want these technologies recognized for turning waste into low-carbon energy.123
Why — This would provide essential financial support for their transition to low-carbon infrastructure.4
Impact — Incineration firms may lose waste feedstock as gasification is presented as cleaner.5
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Meeting with Joachim Balke (Head of Unit Energy) and Enagás S.A. and Teréga

24 Oct 2025 · The participants presented the state of play and next steps in the development of the the South-West Hydrogen Corridor.

NaTran Urges EU to Prioritize Digital Sovereignty in Energy

17 Oct 2025
Topic — The consultation explores leveraging digital technologies and artificial intelligence within the energy sector.
Message — NaTran requests support for operators to meet regulatory requirements and calls for a harmonized framework for energy data. They also advocate for reducing reliance on non-European suppliers by promoting sovereign digital solutions.123
Why — EU funding and sovereign tools would lower compliance costs and modernize gas networks.45
Impact — Non-European technology providers may lose market access as the EU favors local sovereign solutions.67
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NaTran Urges Integration of Hydrogen Networks into Electrification Plan

9 Oct 2025
Topic — The EU is identifying barriers to switching energy demand from fossil fuels to electricity.
Message — NaTran calls for closer cooperation between hydrogen and electricity sectors to support decarbonisation. They argue integrated planning of energy grids is essential to unlock cost savings.12
Why — Using hydrogen infrastructure allows the organization to optimize its networks and reduce hydrogen costs.34
Impact — Electricity grid operators face reduced investment as hydrogen infrastructure reduces power grid capacity needs.5
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NaTran Advocates for Regulated CO2 Networks and Multi-Gas Synergies

9 Sept 2025
Topic — EU initiative for developing competitive markets and infrastructure for CO2 transportation.
Message — NaTran proposes dual planning and mandatory third-party access to ensure fair competition. They suggest financing models combining anchor user commitments, private investment, and government guarantees.12
Why — Leveraging existing gas infrastructure and operational synergies would significantly reduce deployment costs.3
Impact — Smaller industrial players might be excluded if infrastructure requires long-term commitments they cannot provide.4
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NaTran urges integrated planning for hydrogen and CO2 networks

23 Jul 2025
Topic — The European grid package aims to modernize and expand energy infrastructure across the EU.
Message — NaTran advocates for the full inclusion of hydrogen and CO2 networks alongside existing gas infrastructure. They request public guarantees and new funding mechanisms to support the development of these projects. They also suggest simplifying permitting procedures to reduce administrative burdens for project promoters.123
Why — This would protect their financial returns and reduce the risks of early-stage investments.4
Impact — Public institutions would take on greater financial risk by providing guarantees for projects.5
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Meeting with Arthur Corbin (Cabinet of Executive Vice-President Stéphane Séjourné) and TotalEnergies SE and

10 Jul 2025 · Clean industrial deal Financement Simplification

Meeting with Teresa Ribera Rodríguez (Executive Vice-President) and

24 Jun 2025 · Hydrogen Infrastructure Development

Meeting with Christophe Grudler (Member of the European Parliament)

14 Jan 2025 · Politique énergétique européenne

Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans) and Enagás S.A. and

4 Jul 2023 · H2Med corridor

Meeting with Kadri Simson (Commissioner) and

4 Jul 2023 · Latest state of play of H2MED project; development of hydrogen demand, supply and infrastructure.

Meeting with Seán Kelly (Member of the European Parliament) and European Energy Forum and GAZ-SYSTEM S.A.

18 Oct 2022 · Dinner debate: Biomethane: how to scale up production and foster integration into the network?

NaTran Urges Flexibility and Proportionality in Methane Rules

15 Apr 2022
Topic — Proposed EU legislation aims to monitor, report, and reduce methane emissions in energy.
Message — NaTran requests flexibility to prioritise actions and define multi-year mitigation plans with authorities. They recommend aligning with industry standards while avoiding site-level quantification requirements until technologies mature. Operators should also be permitted to set their own leak detection intervals based on specific practices.123
Why — Operators would minimize operational costs and avoid restrictive, standardized administrative requirements.45
Impact — Environmental progress may be slowed by allowing longer repair times and flexible detection schedules.67
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Response to Revision of EU rules on Gas

13 Apr 2022

GRTgaz welcomes the revision of the EU gas legislation which, along with the revised rules for the EU electricity market, should enable the clean energy transition and the resilience of the energy sector by building on the synergies between electrons and molecules. GRTgaz brings its full support to the objectives of the hydrogen and gas market decarbonization package and, seeking a pragmatic approach, proposes the following improvements. Developing a hydrogen dedicated infrastructure essential for the expansion of a competitive hydrogen market: The future unbundling rules for the hydrogen networks should not be stricter than those applied to gas and electricity networks. In particular, concerning the vertical unbundling, all three models, including ITO, should be applicable in order to allow the numerous current ITO gas TSOs to contribute to the development of an EU hydrogen backbone in a cost-efficient way by repurposing part of their gas networks. When it comes to the horizontal unbundling between gas and hydrogen networks, while the separation of accounts is necessary, the legal separation should not be mandatory and allow for the creation of combined operations between gas and hydrogen networks. This should allow for synergies in terms of planning, expertise and resources mutualization and minimize risks of delays and administrative burdens for the hydrogen network development and the costs for the hydrogen consumers. Such synergies should be subject to regulatory conditions and NRAs oversight. Facilitating the access of renewable and low carbon gases to the existing gas network: - The definition of low-carbon gases should not be delayed and their certification scheme should be compatible with the characteristics of the union-wide gas market. - Any gas that can be safely injected into the network should be defined simply as “gas” and avoid the term “natural gas” that has fossil origin, which is not the case of renewable gases, such as biogas, and low-carbon gases. - The integration of renewable and low carbon gases in the networks would be more efficiently promoted through reduction of costs of injection to and connection with the network, instead of discounts on infrastructure access tariffs in order to avoid complexity and uncertainty regarding compensations. - The choice of requiring the integration of the distribution level into the entry-exit system definition is disproportionate in comparison to the objective that volumes of renewable and low carbon gases of the distribution level can be taken into account for grid balancing reasons and can be traded at the wholesale gas markets. Arrangements are already developed in several member states. - Provisions for setting an EU blending cap of hydrogen should leave sufficient flexibility to take into account national markets specificities and acceptability and impacts on end-users. Improving the resilience and the security of supply: - In order to keep gas prices as low as possible during winter periods, the introduction of harmonized measures at EU level for storage (subscription and filling) should be promoted, taking as an example the French regulation for storage. - Such provisions shouldn’t be redundant or interfere with national policies proven to be efficient. It should be left up to the Member States to decide whether strategic stocks are necessary and which entity should manage them.
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NaTran urges EU to allow combined gas and hydrogen networks

12 Apr 2022
Topic — Revision of EU gas rules to support renewable and low-carbon gas market entry.
Message — The organization requests that hydrogen network rules permit combined operations with gas networks to ensure cost-efficiency. They advocate for replacing the term "natural gas" with "gas" and harmonizing storage regulations at the EU level.123
Why — This allows the company to repurpose existing gas infrastructure for hydrogen without costly legal separation.4
Impact — New hydrogen market competitors lose a level playing field if legacy operators manage both networks.5
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Response to Revision of Alternative Fuels Infrastructure Directive

18 Nov 2021

GRTgaz welcomes the revision of the current AFID, which will contribute to the decarbonisation of the transport sector. In order to ensure the coherence of the Fit for 55 package, the definitions of the types of fuels produced and used for vehicles should be harmonised. The definition of “renewable fuels” in Article 2(3) of the AFIR should reflect the REDII definitions and explicitly include biogas and advanced biofuels (such as bio-CNG and bio-LNG). On the other hand, the sub-definition of “alternative fossil fuels” should be renamed “transitional alternative fuels” as it includes transitional alternative fuels like CNG and LNG. GRTgaz welcomes the mandatory deployment of hydrogen refuelling stations for Member States every 150 kilometres on TEN-T network. Nevertheless, the distance requirement could be more ambitious. Also, this infrastructure target is set by 2030 whereas the Strategy for Sustainable and Smart Mobility sets a 500 hydrogen refuelling stations by 2025. Therefore, this target should be advanced to 2025. Moreover, AFIR should not anticipate the outcome of the revision of the CO2 standards for cars and heavy-duty vehicles by phasing out support for certain key infrastructure fuels that are essential for decarbonising road transport. The AFID revision should be based on the principle of fuel and infrastructure neutrality, considering all types of fuels that can enhance decarbonisation. In that regard, the proposal does not sufficiently take into account the potential of CNG and LNG infrastructure to decarbonise and the necessity to foster bio-CNG and bio-LNG. Two main concerns are the lack of a target for CNG refuelling stations and the limited timeframe for LNG infrastructure. The European network of gas fuelling stations has reached 4.000 CNG and 400 LNG stations this year, which is crucial to support the decarbonisation of today’s and tomorrow’s gas vehicles in Europe. CNG and LNG, although transition gases, are essential for the decarbonisation of the road transport. Bio-CNG and bio-LNG will gradually replace CNG and LNG to further decarbonise transport. Advanced biogas can indeed help to achieve zero or even negative emissions, as the production of these gases consumes more emissions than their combustion emits. As indicated by the recital 19 of the proposed regulation, “The TEN-T core network should remain the basis for the deployment of LNG infrastructure, and progressively for bio-LNG”. Thus, GRTgaz strongly supports the inclusion of an infrastructure target for CNG, as instituted by Article 6(8) of the AFID. The network of CNG stations needs to develop, especially around cities, where CNG is a relevant solution to preserve air quality while ensuring the autonomy of coaches, buses, garbage trucks, etc. While CNG stations installations are growing, distribution across Europe is still uneven and investments are needed to have a comprehension CNG refueling network. In addition, the infrastructure target required for LNG (Article 8 of AFIR) and the new target set for CNG should be met by 2025 and be kept beyond, in order to provide the core network for the deployment of bio-CNG and bio-LNG.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

18 Nov 2021

The revision of the Renewable Energy Directive is a significant step forward in the accomplishment of the decarbonisation of the European economy. The objective of the Directive would be reinforced with a clear definition of low carbon gases. Low-carbon gases should be defined in an equivalent way to the definition of renewable gases and RFNBOs in the RED and its revision proposal, setting a comparable minimum GHG reduction threshold as required in the RED II. GRTgaz welcomes the revision to the Directive insofar as it requires the issuing of the guarantee of origin (GO) for renewable energy receiving public financial support (new Article 19§2). Additionnally, the extension of the GO system to low carbon gases should be mandatory and not left to the discretion of each Member State, as this would avoid fragmentation of the Union energy market and allow greater visibility of the energy source used for the industry and consumers. GO is the preferred option for traceability of renewable energy sources, as it already exists in the gas sector and is already commonly used in the electricity sector, and should include sustainability and GHG information. A possible sub-optimal option could be to trace sustainability and GHG through a dedicated system (taking into account mass-balancing) until the injection of the renewable gas into the gas system and, after that, to use the GO scheme. The 13% greenhouse gas intensity reduction mandatory target to the transport sector by using renewable fuels and renewable electricity by 2030 (new Article 25§1 (a)) is a positive incentive for companies to move to renewable gases. To further encourage such switch, a global target of 11% of renewable gases in the total energy consumption should be added, on top of the sectoral targets (like the 2,2% target of advanced biofuels and biogas in transport by 2030). Finally, the additionality principle on RFNBO should be achieved by policy measures of Member States, such as incentives for increasing the renewable electricity used for the electrolysis. The actually planned additionality criteria to be applied by electrolysers would create obstacles to the deployment of renewable hydrogen through electrolysis.
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Response to Revision of the CO2 emission standards for cars and vans

8 Nov 2021

GRTgaz acknowledges that this Regulation is an important step in the decarbonisation of light land transport. While we welcome its high level of ambition, we consider that a different approach would be more effective in achieving its objectives. One of the objectives of the modified 2019/613 Regulation is the respect of the Paris Agreement objectives. Therefore, this legislation should consider as a priority the absolute reduction of the overall emissions and not just the ones coming out of vehicles. The switch from internal combustion engine (ICE) vehicles to electric vehicles (fuel cell or battery) may have unintended effects given that the Fit For 55 package does not require the electricity sector to be decarbonised or hydrogen to be produced from renewable energy sources by 2035. Switching from current ICE vehicles to vehicles powered by electricity generated from coal or fossil fuel would indeed comply with the provisions of the Regulation though it would increase overall emissions. On the other hand, switching from ICE vehicles to biomethane ones would be prohibited by 2035 however it would significantly reduce emissions. Moreover, vehicles powered by third-generation renewable fuels would be banned as they emit CO2 from their tailpipe, while the production of such fuels consumes more CO2 than their combustion (negative emissions). The development of ICE vehicles running on low or negative carbon fuels would significantly limit the cost of the transition as the technology is already available. It will also limit workforce reconversion, as the technology required is the same as for current vehicles. This would make the transition more cost-effective and fairer. Also, the regulation stipulates that the approach should be “technology neutral in reaching the fleet-wide targets” (recital 9). However, it does not respect the technology neutrality principal as it de facto prohibits certain technologies, such as ICE or third generation renewable fuels, that could contribute to ambitious emissions reduction. GRTgaz is in favour, like many other stakeholders, of a voluntary crediting system between fuel suppliers and automotive manufacturers. They should partially benefit from the use of sustainable renewable fuels for compliance with their targets, provided that it takes into account defined responsibilities between these sectors and avoid double counting. Even if the most cost-effective and efficient approach would be a well-to-wheel approach, the proposed mechanism allows to the benefit of biofuels to be taken into account for decarbonisation while retaining the tailpipe approach within the Regulation. In light of the above, the introduction of the crediting scheme mentioned will be effective in reducing emissions across Europe, without undermining the principle of technological neutrality and favouring the most cost-effective technologies.
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Response to Detailed implementing rules for the voluntary schemes recognised by the European Commission

27 Jul 2021

GRTgaz fully commits to the Paris Agreement and supports the European Commission’s ambition to reach carbon neutrality by 2050. As GRTgaz, we are convinced that we must act now, leveraging all efficient solutions already available to decarbonise the energy market and economy. This goal will not be reached without renewable and low carbon gases used as fuels in an integrated energy system. We welcome the opportunity to provide feedback in view of the implementation of the RED II with regard to voluntary schemes standards. General comments related to the Implementing Act (“the IA”): • GRTgaz supports that energy carriers are subject to sustainability and GES criteria, whose application need to be workable and not create undue administrative burden. The text should provide voluntary schemes and economic operators with the necessary guidance for demonstrating compliance with the sustainability criteria. • Nevertheless, the IA adds in complexity because the provisions for the implementation of the voluntary certification schemes and the mass balance system have been designed with liquid fuels in mind; application of such provisions to gaseous sector could hinder its development and trade in a single EU internal gas market. GRTgaz recommends the inclusion of a dedicated set of rules. • The IA includes several deviations from the Renewable Energy Directive text and could result in excessive administrative burden for market operators. Further detailed comments are listed in the attachment.
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Meeting with Filip Alexandru Negreanu Arboreanu (Cabinet of Commissioner Adina Vălean)

18 May 2021 · The energy and ecological transition, and the key role that the energy infrastructure can play in making the shift to a low-carbon economy a reality, including the deployment of sustainable mobility and transport solutions in Europe.

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

23 Mar 2021 · Views from the gas TSO on the upcoming Fit for 55 Package

Response to Revision of the NIS Directive

18 Mar 2021

GRTgaz is fully committed to the Paris Agreement and as a leading gas infrastructure operator, we are ready to assume our responsibility and put our infrastructure to good use in service of the energy and ecological transition. The objective of climate neutrality goes hand in hand with the need for a digital transformation of the energy sector. The COVID crisis, revealed that information systems are highly significant and their security and resilience need to be enhanced. GRTgaz, as an operator of essential services, welcomes the European Commission's objective to make “Europe fit for the digital age”, part of which is the proposed revision of the NIS Directive. A timely proposal setting the path towards a resilient and secure Union wide information systems GRTgaz supports the clarification and expansion of the scope of the Directive and the further harmonisation especially when it comes to the cross-border cooperation of authorities and operators of essential services, risk management and systematic share of information. Cybersecurity reinforced measures need to apply in a harmonised way across operators of essential services, the same value chain and borders. 1. Allow for a distinction between “essential” and “less critical” parts of the network or information systems of the essential operators We welcome the distinction between “essential” and “important” operators introducing a gradual approach of the compliance measures to be put in place per operator, minimising the costs for smaller operators. However, it would make sense for essential operators to benefit from a lighter ex-post supervisory regime or total exemption of the provisions of the Directive for some parts/assets/equipment of their network or information systems, when those parts do not represent high risks for disruption of the essential service. 2. Introduce a gradual approach for reporting obligations depending on the significance of the incidents GRTgaz welcomes the strengthening of the reporting obligation, their harmonisation cross border and especially the effort to define what incident could be considered as “significant”. However, the definition still leaves important room for interpretation. Obligations for overreporting following a rather burdensome process could entail unnecessary and disproportionate efforts and expenses. Reporting obligations should be necessary only where they are relevant for the avoidance of any inconvenience or disruption of the essential services. GRTgaz suggests that this provision is reconsidered to provide for lighter reporting obligations or no reporting obligations for incidents related to the less critical parts of the network or information systems as per GRTgaz first policy ask. 3. Reconsider the possibility of Member states to ask for certification of the essential operators GRTgaz believes that the provision of article 21 on the certification of operators could be counterproductive by leaving the flexibility to Member States to transpose it in a non-harmonised and inconsistent way. On top of that, this would create difficulties of implementation cross border, potentially discriminations between certified and non-certified products, services and processes and fragmentation of the internal market. Besides, imposing such certification presupposes the reinforcement of the cybersecurity framework with clear and harmonised obligations for operators and authorities, which should be the priority. GRTgaz calls for the clarification of such provision so that it provides directly that all essential operators of a specific category should be submitted to certification in a non-discriminatory way, provided that such certification certifies the compliance with harmonised rules and does not entail unnecessary and disproportionate costs for those parts of the network or information systems that do not necessarily need to be subject to constant ex ante supervision, risk assessments and reporting obligations.
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Response to Revision of EU rules on Gas

10 Mar 2021

GRTgaz welcomes the opportunity to provide its feedback to the combined evaluation roadmap related to the “Hydrogen and Gas Markets Decarbonisation Package” initiative. Making our infrastructure futureproof to fully contribute in the EU climate neutrality objective is the way forward while also representing a real paradigm shift for the gas industry and our company. GRTgaz therefore strongly supports the EC's overall objective “to ensure a suitable market framework” for the achievement of increased EU climate ambitions in 2030 and to translate into legislative measures where appropriate the Energy System Integration and the Hydrogen strategies. Rules for fostering hydrogen and gas infrastructure and markets For hydrogen (H2) to become a commodity, and to be truly integrated in the energy system by 2030, the main principles of a regulation at EU level need to be defined in the coming years. In particular, strategic, technical and policy planning is essential to prepare the future-proofing of infrastructure and consumption applications to H2, even if a large network infrastructure is not immediately needed at European level. • Define from the onset the future H2 market framework by leveraging the key principles underpinning the Internal Energy Market for gas and electricity with additional features reflecting the specificities of this nascent market. - Rely on the principle of third party access to infrastructure in a non-discriminatory and transparent manner for establishing the H2 framework. • Define a target market model compatible with electricity and gas models to prevent market fragmentation and implement it gradually. Exemptions shall be designed according to the respective market development stage to accompany the start-up phase of the H2 market. They shall support visibility for all players of the value chain and be granted at Member State level. • Favour a close cooperation between planning process for gas, H2 and electricity infrastructure under the ENTSOs and at national level to start early the coordinated network planning for these energy carriers. The coupling between gas and electricity systems shall be enhanced relying on the ongoing work between ENTSOE and ENTSOG. • Establish an adequate level of standardisation of H2 quality to support cross-border trade and enhance interoperability. • Allow gas TSOs to own, plan, finance, build, operate, organise and provide non-discriminatory access to H2 infrastructure alongside gas infrastructure. Gas TSOs and ENTSOG already have the expertise required to support the network planning and market development of H2 and renewable and low carbon gases. Integration of renewable and low carbon gases in the existing gas infrastructure GRTgaz welcomes the options the EC foresees to facilitate the integration of methane and H2 derived renewable and low carbon gases into the energy system. To that respect GRTgaz would like to highlight three policy priorities: • Political messaging on the long-term outlook for renewable and low-carbon gases in the EU energy system is important. It should recognise and value all environmental and economic benefits linked to those gases production and uses. An unambiguous political support is needed, provided of course that bioenergy complies with sustainability criteria. Otherwise investors might shy away and prevent the EU from being a valuable and affordable solution for decarbonisation. • Clear definitions and EU wide system for guarantees of origins for renewable and low carbon gases to provide clarity to stakeholders willing to invest in those technologies. • Specific targets to foster the role of low carbon and renewable gases in decarbonisation. Based on our French experience, we support Gas for Climate proposal to introduce a 11% binding target for renewable gases in 2030. Eurogas view is also interesting: a binding 20% greenhouse gas intensity reduction target in addition to an 11% EU-wide binding target on renewable gas by 2030.
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Response to Revision of the guidelines for trans-European Energy infrastructure

8 Mar 2021

GRTgaz fully supports the European Commission’s ambition to reach climate neutrality by 2050. As a leading gas infrastructure operator, we welcome the proposed revision of the TEN-E Regulation setting the path towards a future-proof gas infrastructure contributing to the energy transition in a sustainable and affordable way. Based on our ground knowledge and expertise, we put forward the following suggestions aimed at improving the effectiveness and functioning of the revised Regulation. Towards a future-proof gas infrastructure We fully support the inclusion of hydrogen (H2) infrastructure and smart gas grids under the status of PCI. Meanwhile H2 infrastructure will play a critical role in decarbonising the economy, digitalisation will be complementary by increasing the overall network’s performance, and the share of renewable and low carbon gases into the grid. GRTgaz also endorses the integration of H2 transmission infrastructure in the TYNDP of gas infrastructure, which will strengthen energy system integration. Besides, we acknowledge that infrastructure projects should contribute to sustainability as a prerequisite to qualify as PCI. Sustainability criteria should take into account the CO2 emissions savings of projects based on a Life Cycle Assessment applicable across sectors and based on technology neutrality. A particular attention should also be given to the cross-border criteria that needs to be more flexible. Clarify the scope and selection process of investments for smart gas grid projects We welcome an increased focus on digitalisation, which provides data for better collaboration, network control and informed production and consumption decision-making processes. We would like to stress the need to ensure that equipment enabling reverse flows of renewable gases is covered by the category. These equipment are essential to enable the reinjection of gas surplus into the network from distribution to transport level when the production is greater than consumption at local level. Ensure early implementation of smart gas grids and hydrogen infrastructure projects With the review of the TEN-E regulation and the adoption of the 5th and 6th PCI lists running in parallel, it is essential to start immediately the planning process. As ENTSOG has already included H2 projects in the upcoming TYNDP 2022, GRTgaz calls for the Energy Transition Projects incorporated in this TYNDP to be eligible for PCI status and be included in the 6th PCI list. Build an integrated offshore network development relying on both renewable electricity and gas, including hydrogen The new category for offshore grids only focuses on an integrated offshore network development plan, and the cost-benefit and cost-sharing methodology applied for electricity. However, H2 pipelines and gas production facilities are expected to play a significant role in developing offshore networks. Therefore, GRTgaz suggests to reconsider this provision to include offshore networks based on H2. Adopt an agile governance approach for the development of joint scenarios by the ENTSOs GRTgaz recognises the importance of objectivity and transparency in the process of the joint ENTSOE and ENTSOG scenario development and the relevance of additional measures in this regard. A formal approval by the Commission, combined with ENTSO-E / ENTSOG suggestion of a Joint Stakeholder Forum for Scenarios, would greatly improve transparency and stakeholder involvement. Include the CO2 storage projects in the scope of the regulation The exclusion of CO2 storage facilities other than buffer storage is inconsistent with the need to develop a full-chain CCS technology. Moreover, it seems pointless to ensure that pipelines are developed if there are no or inadequate safe storage sites. GRTgaz calls for the inclusion of CO2 storage facilities under the CO2 projects that can qualify as a PCI under the TEN-E Regulation, unless they are eligible for support under other mechanisms.
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Response to Proposal for a legislative act on methane leakage in the energy sector

26 Jan 2021

As a leading gas infrastructure operator fully committed to the Paris Agreement and to the European Commission’s ambition to reach climate neutrality by 2050, GRTgaz welcomes the opportunity to provide its views on the forthcoming proposal to reduce methane emissions in the energy sector. Based on our expertise and experience as a French TSO, GRTgaz would like to highlight several points for consideration under the preparation of the forthcoming legislative proposal. Current best practices GRTgaz already takes many actions to reduce its own emissions and contributes to decrease emissions of sectors such as waste and agriculture with the development of renewables such as biomethane. In this context, GRTgaz settles targets to cut down its methane emissions and our first objective to divide by 3 these emissions between 2016 and 2020 has been achieved. Such action demonstrates our ambition and voluntarism to contribute in solving this issue. To achieve this objective, LDAR campaign are conducted regularly. For GRTgaz, these campaigns are supported by a strong involvement in trainings for on-site operators that are essential to ensure the best available techniques are used once they have been developed. Our research centre, Rice, is actively working on innovative solutions to detect and repair leaks, to improve the efficiency of LDAR campaigns, and to capture and reinject emissions on-site. The availability of data on methane emissions is critical to the reinforcement of such best practices. In this regard, GRTgaz welcomes the ambition and efforts of the Commission to reinforce the availability and accuracy of data on methane emissions. We strongly support the adaptation of the OGMP 2.0 framework, to which we already contribute. GIE and Marcogaz are developing several tools and technical recommendations we are supportive with and believe should serve as a basis for developing new rules on preventing methane emissions. Policy asks • Establishing a fit-for-purpose MRV (measurement, reporting and verification) system in the EU by translating the OGMP framework into EU legislation. It will enable to improve the accuracy and credibility of the reporting by encompassing the whole energy supply chain, from upstream to downstream (excluding utilisation), in the MRV system. • Exploiting the work led by GIE and Marcogaz on methane emissions proposal on LDAR programmes, venting and flaring. This work is led in cooperation with several gas operators, and reflects the voluntarism of those operators in the reduction of methane emission. Relying on it will be essential to achieve our climate objectives by maintaining the cooperation framework between operators and regulators • Recognising investments and spending in MRV, LDAR and mitigation measures taken by infrastructure operators within the scope of regulated activities. This aspect is critical to ensure these investments (CAPEX and OPEX) can be made by operators and are recognised as part of the fundamentals of their activities and responsibilities.
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Response to Revision of Regulation on Union guidelines for the development of the trans-European transport network (TEN-T)

18 Dec 2020

GRTgaz fully commits to the Paris Agreement and supports the European Commission’s ambition to reach carbon neutrality by 2050. As GRTgaz, we are convinced that we must act now, and take into account all the effective solutions already available to decarbonise transport. This goal will not be reached without renewable and low carbon gases used as fuels in an integrated energy system. We welcome the opportunity to provide feedback in view of the revision of TEN-T guidelines, which we believe is essential to deliver on this ambition. Whereas e-mobility will be key for decarbonisation of some parts of the EU’s vehicle fleet, molecules also have a strong potential to help decarbonise mobility. In comparison with petrol and diesel, natural gas generates already a GHG emission reduction of up to 23% from Well-to-Wheel (WtW). The GHG emissions of NGVs even decrease by 80%, when considering biomethane. Furthermore, NGV, hydrogen (H2) and biomethane bring low carbon alternatives to light and heavy-duty vehicles, especially for delivery, passenger and freight transports. The IFPEN study analysing the full-life carbon footprint of different types of vehicles concludes that with a 40% incorporation rate of bioCNG in natural gas, NGV vehicles are as efficient as electric vehicles, having in mind the French decarbonized electricity mix (56 gCO2 eq/kWh). These complementary solutions to e-mobility enable quick GHG savings in a cost-efficient way. While bioGNV is cheaper than H2 for mobility, we note that a centralised H2 production combined with transport via pipeline significantly divide the cost for users. The affordability of GNV and bioGNV will also enable to act on the decarbonisation of mobility in all Member States, even when their energy mix does not contain enough renewable electricity for a quick uptake of e-mobility. Policy rasks • Support the deployment of new infrastructure for sustainable mobility, both for electric and vehicles fuelled with renewable and low carbon gases, (e.g. bioCH4 and H2). This principle should apply to road transport, railway, inland waterway and maritime transport. It especially concerns the need to increase charging and refuelling stations across Europe via the introduction of binding requirements for recharging and refuelling infrastructure. In this respect, it is essential to base any GHG emissions consideration on a life-cycle approach. • Support the repurposing or retrofitting of existing assets: existing gas infrastructure can be converted to renewable and low carbon gases, and their location can strengthen the deployment of infrastructure for clean mobility. The TEN-T regulation should acknowledge the cost-efficiency of relying on gas infrastructure and centralised production compared to on-site production for the uptake of H2 mobility. • Strengthening multimodality across Europe, notably via an increased coverage of refuelling stations at ports where LNG can serve shipping, road and rail transports • The principle of neutrality of the infrastructure should be maintained in the revision: as enabler of the decarbonisation process, infrastructure should remain neutral. The regulation should remain open to the wide range of available technologies ensuring cost-efficient GHG emissions savings. • Ensure synergies between the TEN-T regulation, Alternative Fuels Infrastructure Directive (AFID) and the TEN-E Regulation: synergies should focus on fostering an integrated and coordinated planning of infrastructure for sustainable and smart mobility. This holistic approach is key to deliver on a cost-efficient transition. This planning should enable to identify the most relevant clean mobility technologies to develop along the TEN-T corridors in terms of energy efficiency and carbon footprint based on a life-cycle analysis. Mobility uses widely differ between urban, rural or industrial areas and require different clean fuels to be considered and combined. Such planning should also focus on multimodality
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Response to Climate change mitigation and adaptation taxonomy

16 Dec 2020

GRTgaz fully commits to the Paris Agreement and to the EU’s ambition to reach climate neutrality in 2050. As a leading gas infrastructure operator, we are ready to assume our responsibility and put our infrastructure to good use in service of the green transition. We welcome the opportunity to provide feedback on the first two delegated acts (DA) complementing the Taxonomy Regulation (TR), which we believe is essential to deliver on climate neutrality. Whilst the draft proposal counts several positive improvements, attention should be paid to significant shortcomings that still need to be overcome (see document attached). Technological neutrality The proposed DA do not fully reflect the principle of technological neutrality (Article 19.1 TR). We recall the importance of treating all technologies equally without any bias towards few technologies based on political choices rather than best available technologies. This is fundamental to support the emergence of promising technologies with significant abatement potential for a cost-efficient transition. • Hydrogen: include the technologies necessary for the production of hydrogen, notably SMR/ATR with CCUS and pyrolysis, alongside with electrolysis. • Bioenergy: current TSC fail to capture the environmental benefits of bioenergy and reflect a biased approach. It should be considered on an equal foot with its counterpart to ensure a level playing-field. • Mobility: the TSC should be based on life-cycle approach rather than on tailpipe, which fails to entail the environmental benefits of renewable and low carbon gases to decarbonise mobility. • Create a new category for liquefied renewable and low carbon gases import facilities. • Expand the category on storage of hydrogen to all renewable and low carbon gases. Consistency with the EU energy and climate policies GRTgaz also notes a lack of consistency between EU regulations and the proposed TSC. The DA should respect relevant EU acquis, and not set forth new, revised methodologies and metrics, nor more restrictive GHG emissions savings and sustainability criteria other than those already applicable under existing EU regulation. Otherwise they will create legal confusion, risk disrupting the proper market functioning, impact investors’ trust and distort competition in the EU. In these conditions, the taxonomy will not be able to meet its main goal, which is to incentivise sustainable investments. • Ensure that both electrons and molecules can contribute to more sustainable and reliable models: retrofitting and repurposing of existing assets and investments in new assets should also be taxonomy eligible when a substantial improvement can be demonstrated. • Bioenergy: ensure compliance with the Renewable Energy Directive via labelling bioenergy activities as sustainable and not as transitional activities. • Mobility: ensure compliance with the Clean Vehicles Directive where vehicles propelled by renewable and low carbon gases qualify as a clean. The proposed threshold (50g CO2e/pkm) currently excludes renewable and low carbon gases by using a tailpipe approach. Feasibility While the TSC needs to be ambitious to be consistent with the EU decarbonisation pathways, they also have to be achievable and consistent with the Best Available Techniques. • Properly recognise transitional activities with a dedicated and credible threshold. It should reflect a credible path towards climate neutrality, and be averaged over the economic lifespan of the asset (Art. 10.2 of TR and 2019 EIB revised energy lending policy). • Better acknowledge the role of power generation from gaseous and liquid fuels in the energy transition by slightly rising the proposed threshold (100gCO2e/kWh). The growing share of renewable and low carbon gases will decarbonise the gas grid preventing any lock-in risk. Once gas assets are 100% greened, this activity should be fully recognised as sustainable.
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Response to Revision of the CO2 emission standards for cars and vans

26 Nov 2020

GRTgaz is fully committed to the Paris Agreement and supports the European Commission’s ambition to reach carbon neutrality by 2050, and as such welcomes the forthcoming initiatives on climate and environmental action under the Green Deal. As GRTgaz, we are convinced that we must act now, and take into account all the effective solutions already available to decarbonize transport. This goal will not be reached without renewable and low carbon gases used as fuels in an integrated energy system. We welcome the opportunity to provide feedback in view of the revision of CO2 emission standards for cars and vans, which we believe is essential to deliver on this ambition. Acknowledging the role of renewable and low carbon gases in decarbonising mobility: Whereas electric mobility will be key for decarbonisation of some parts of the EU’s vehicle fleet, molecules also have a strong potential to contribute to decarbonise mobility. In comparison with petrol and diesel, natural gas generates already a GHG emission reduction of up to 23% from Well-to-Wheel (WtW). The GHG emissions of NGVs even decrease by 80%, when considering biomethane. While NGVA and EBA reckons an incorporation rate of 17% today, they consider feasible to reach a 40% rate of biomethane into NGV by 2030, to decarbonize efficiently mobility usages. Furthermore, NGV, hydrogen and biomethane bring low carbon alternatives to light and heavy-duty vehicles, especially for delivery, passenger and freight transports. Thus, in 2019, sales of CNG vans in Europe increased by more than 30% according to ACEA statistics. Electric vehicles cannot be the only solution for these usages, especially because of both too short using time length allowed by batteries and too long recharging time. The current CO2 emissions standards on mobility do not recognise life cycle analysis methodology. Therefore, it fails to capture the environmental benefits and cost-efficiency of renewable and low carbon gases by focusing on a tailpipe approach. The carbon content of each energy products shall not only be calculated at the consumption but along the lifecycle (extraction, production and transport) of the fuel, from WtW. The tailpipe approach cannot reflect the environmental cost of a transport means: • The electricity consumed by a “zero-emission” battery vehicle (BEV) depends on the carbon content of the electricity mix: if the EU average carbon intensity of the electricity is 295g CO2eq/kWh, it is 773 g in Poland, 440 g CO2eq/kWh in Germany and 56 in France. The e-mobility in Poland and Germany would be worse than diesel while in France it is better • A bioNGV vehicle is considered to emit as much CO2 as a NGV vehicle in a tailpipe approach, while biomethane is recognised, especially by RED II as being much less emitting. A battery electric vehicle powered with the current EU electricity mix relies on close to 50% contribution from fossil energy. However, a bioCNG vehicle is considered fully fossil, despite providing in some cases even a negative GHG emissions balance • The IFPEN, a French public body, analysed the full-life carbon footprint of different types of vehicles (NGV, bioNGV, diesel, gasoline, electric vehicles, battery and hybrid) for segments (light vehicles, buses, heavy-duty…): with a 40% incorporation rate of bioCNG in natural gas, NGV vehicles are as efficient as electric vehicles, having in mind the French decarbonized electricity mix (56 g CO2 eq/ kWh). It reveals the importance to reasoning both in WtW approach to be consistent in the carbon footprint assessment in mobility Therefore, we support a revision of CO2 emission standards enabling to fully take advantage of the decarbonisation potential and environmental benefits of renewable and low carbon gases uses in mobility.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

21 Sept 2020

GRTgaz welcomes the opportunity to provide its feedback on the European Commission’s (EC) inception impact Assessment to review the Renewable Energy Directive (RED). GRTgaz fully supports the EC’s view that achieving the European Green Deal (EGD) objectives will require fundamental changes in many areas including the energy sector. However, unlike EU electricity production, where clear progress has been achieved in developing renewable sources to lower its carbon footprint, some sectors such as industry, transport (road, air, maritime) and buildings are currently lagging behind. The decarbonisation of those hard to abate sectors should now become a priority leveraging the broad range of sustainable solutions available, taking into consideration both renewables sources and low-carbon sources. In line with the Green Deal ambition on increasing circular economy, energy produced from (non-biogenic) wastes should also be carefully considered. In that respect, GRTgaz therefore welcomes the focus put on those sectors and the ambition of the EC to further promote the use of renewable and low carbon fuels in those reflecting the Energy System Integration and Hydrogen Strategies. For this reason, GRTgaz supports a revision of RED based on option 4 of the inception impact assessment, ie. “a revision of the RED to translate into legal measures the actions proposed in other strategies of the EGD” and considers that solely raising the ambition level of the REDII would not be sufficient. GRTgaz considers as fundamental to ensure consistency between EU legislation (such as ED, EU ETS, taxonomy regulation, Energy Taxation Directive, electricity and gas directives as well as the future regulatory framework for hydrogen) and between energy carriers, with carbon footprint and sustainability as guiding principles. Such approach should allow the contribution of some nascent technologies such as synthetic methane and low-carbon hydrogen (including produced from SMR associated with CCUS) that along with biomethane and renewable hydrogen are poised to have a key contribution. Key elements to be included in the revision of the RED: • Specific targets on a minimal share of renewable gas in the overall gas consumption, as well as on lowering the greenhouse gas (GHG) intensity of the gaseous energy consumed in the EU. • A clear terminology for all energy carriers, reflecting their origin (renewable or non-renewable), level of compliance with sustainability criteria, their level of GHG emissions based on a Life Cycle Analysis. The sustainability criteria should take into consideration both direct and indirect land-use changes (eg linked to raising biomass as well as to installing photovoltaic field). The Life Cycle Analysis parameters would need to be regularly updated by the European Commission in line with the evolution of the technologies (for instance, parameters for biogas appear as outdated). • An EU-wide, mandatory, guarantees of Origin (GO) system for both renewable and low-carbon energy carriers. GOs should become the sole media to inform customers about the origin of the energy they purchase on the one hand, but also on its carbon content and the sustainability on the other hand. This “enhanced GO” (encompassing GHG emissions savings) could be used for reporting purpose in the framework of the EU ETS (and its future extension), as well as for Member States for monitoring and reporting their national targets as stemming from RED.
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Response to Revision of the EU Emission Trading System Monitoring and Reporting Regulation (MRR)

22 Jul 2020

GRTgaz welcomes the opportunity to provide a feedback on the European Commission proposal amending the « implementing Regulation on the Monitoring and Reporting of greenhouse gas emission » (« MRR ») related to the EU Emissions Trading System (« ETS ») following the adoption of Renewable Energy Directive 2018/2001/EU (« RED II »). Our proposals mostly focus on issues related to biogas, which contribution has been highlighted by the European Commission in its strategy for the integration of the energy system published on July 8th 2020. GRTgaz fully supports the European Commission proposition to consider biogas as a decarbonized fuel, which can be granted with a zero emission factor, provided that it complies with the sustainability and GHG criteria defined in RED II. However, the proposal to determine the biomass fraction of pipeline gas as set in the revised article 39 paragraph 4 and 5 raises heavy concerns. The possibility to choose between two methodologies from one member state to the other would create major market distortion issues between industries within the internal market. To our knowledge, such choice does not exist in the EU ETS regulation for any other energy source. EU ETS defines common rules applicable across Europe and GRTgaz recommends setting forth one single methodology. The second methodology, as proposed in paragraph 5, should be abandoned as it raises particular concerns. First, the fact that this methodology relies on an average rate of biogas determined at national level makes it inconsistent with the accuracy that is required from each operator as set forth in article 7 of the MRR, since they shall seek « the highest achievable accuracy ». Second, this method would place industries in a lock-in situation, as they would no longer be able to willingly decarbonize their gas mix -and save ETS quotas- by purchasing extra biogas. The distortion created by this methodology appears unjustified. Deterring industries from decarbonizing their gas mix would be counter-productive and would expose gas-intensive consumers that have no alternative to gas to serious competitiveness issues, in addition to jeopardizing the nascent European biogas industry. GRTgaz considers that an implementing regulation setting a single methodology based on actual purchase of « sustainable biogas » as proposed in paragraph 4 is an essential condition to achieve the decarbonisation of gas-consuming industries, at an affordable cost and with fair competition rules across the whole European Union. Indeed, this methodology would put all industries across Europe on an equal footing, while incentivizing gas-consuming industries to decarbonize their gas mix, and stimulating additional biogas production beyond those benefiting from public support. GRTgaz would also like to propose the below additions that we think would improve the first methodology: - Tracking biogas purchase by means of Guarantees of Origin (« GO ») that would bear the information about compliance with RED II « sustainability and GHG criteria» should be explicitly privileged as such a scheme is currently working and prevents double-counting. Only for those countries having elected not to grant GO to subsidized biogas production (as per Article 19 of RED II), and in order to overcome any compliance issue, GO could be replaced by alternative « purchase records of biogas ». - The connection of ETS operators and biogas producers to « the same gas grid » deserves being clarified and should encompass the entire European interconnected gas network. Indeed, provided one single common methodology is valid across the European Union, there would no longer be any competition distortion risk. Please find in the file attached our detailed proposals to amend the MRR.
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Meeting with Kadri Simson (Commissioner) and

10 Jul 2020 · Exchange of views on energy system integration and hydrogen strategies.

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

8 Jun 2020

GRTgaz fully supports the European Commission’s ambition to reach climate neutrality in 2050. As a leading gas infrastructure operator, we welcome the opportunity to provide feedback in view of the revision of the guidelines for the TEN-E regulation, which we believe is essential to deliver on this ambition. EU policies and legislation have strived towards ensuring security and diversification of supplies, interconnectivity and fair & transparent competition. For the gas infrastructure, an unprecedented wave of investments occurred to create a fully interconnected and integrated European internal gas market that is diverse, secure and competitive. With the exception of a few missing links in eastern and south-eastern Europe, European gas infrastructure is both well-interconnected and mature. This infrastructure is a “strategic asset” and should continue to be treated as such: -Utilisation of the existing gas infrastructure together with electricity, in a hybrid system, provides a smart and cost efficient solution for achieving the energy transition. -Gas infrastructure and storage can act as batteries of the new energy system by enabling the storing of large amounts of renewable power. -It can also foster the integration between various sectors and geographies: electricity & gas, and across sectors (industry, agriculture and transport). -It also fosters the production of renewable energies at local level and contributes to create jobs, reviving economies in territories. Align TEN-E priorities with the Green Deal objectives The TEN-E regulation should foster the futureproofing of the energy infrastructure that will become more decentralized and digitalized, and allow it fully contribute to the Green Deal objectives. First of all, a coordinated and holistic approach for European TYNDP between electricity and gas grids is essential to optimise the investment efforts required for the energy transition. It will also be fundamental to ensure a meaningful coupling between distribution and transmission grids to enable reverse flows from DSO to TSO for storage and transportation of renewable gases. Eligibility criteria to the PCI status need to be adapted to fully reflect the EU’s vision for an integrated energy system, acknowledging the role of renewable and low carbon gases in relation with electricity: • Extending the eligibility to the PCI status to projects facilitating the integration of renewable and low carbon gases, including hydrogen. • Allowing the retrofitting/future-proofing of existing infrastructure to be considered as eligible projects to the PCIs status to answer the energy efficiency first principle. • Including sustainability criteria to the PCI status to better reflect the direct contribution towards decarbonisation and additional positive externalities of renewable and low carbon gases and related infrastructure (job creation, circular economy, etc.). • Reducing the 10% threshold for the growth of cross-border capacity. Thus, local projects that contribute to the decarbonisation of European energy mix could be eligible. It would also reduce the need for cross-border interconnection making more existing gas infrastructure available for a European hydrogen backbone. Infrastructure categories, priority corridors and thematic areas should also be revised to enable the deployment of renewable and low carbon gases: • Creating a domain for projects related to the development of a Hydrogen backbone in Europe. • Creating a domain for projects contributing to sector coupling and energy conversion. • Extending the smart grid domain to the gas sector as only electricity projects are currently eligible to it, while it can bring significant energy efficiency gains to the gas sector. • Creating a domain for gas projects contributing to sustainable mobility, especially for freight and maritime transports. • Extending the CCS (capture and storage of CO2) domain to include CCU (Capture and utilisation of CO2)
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Response to Strategy for smart sector integration

8 Jun 2020

In this period of unprecedented public health challenges and economic tensions, GRTgaz is convinced that climate change mitigation and economic recovery cannot be separated. Beyond meeting climate objectives, the Green Deal should drive economic growth and create sustainable local jobs. It should foster public and private investments in energy efficiency, renewable energy, but also in new low carbon gas technologies and in the future proofing of grid infrastructure. As GRTgaz, we are convinced that renewable and low carbon gases, and complementarity between electricity and gas systems will be key to enable energy system integration and deliver the energy transition in an affordable and socially acceptable manner. With a view to forthcoming exchanges on the energy system integration, GRTgaz would like to submit the following propositions: Prepare the hybrid energy system of tomorrow • Loosen some of the constraints linked to unbundling, enabling network operators to support the transition by allowing them to engage in certain conversion activities that have not yet reached a sufficient stage of maturity to stabilise a business model or that have been marked by a lack of commitment by market players. • Establish a regulation applicable to hydrogen infrastructure building on the legislative acquis developed for gas infrastructure with particular emphasis on third party access to the networks in line with the rules and principles of non-discrimination and regulated economic conditions. • Establish a regulation of power-to-gas assets which is open to experimenting with different models in the first instance. Network operators must be able to invest and operate power-to-gas assets according to the principles of third-party access, especially in case of a market failure. Enable sectoral integration • Introduce life-cycle assessment methodology as a basis for future CO2 emission standards and take into account the environmental benefits of bioCNV when reviewing CO2 standards regulations for cars and heavy-duty vehicles. Furthermore, the EU’s liquefied natural gas strategy ought to be revised to take into account the role of bio-LNG as well as hydrogen. • Recognise the contribution of biomethane injected into networks to decarbonise industry, in particular through the emissions trading system, in order to promote the role of gases in this sector. Foster the development of renewable and low carbon gases • Amend relevant European legislations to enable network operators to operate several categories of gas including CO2. • Introduce an EU wide headline target for renewable gases, including sector-specific targets. • Introduce a European hydrogen target for infrastructure and equipment users using gas to 10% in 2030 and 20% beyond, thus minimising blending costs. Gas infrastructure is capable of integrating hydrogen at limited adaptation costs. Complete and maintain a secure, integrated and competitive EU internal energy market • Review the TEN-E Regulation to allow projects facilitating the development and integration of renewable and low-carbon gases to become projects of common interest (PCI) and eligible for European support. PCI eligibility criteria should recognise the direct contribution towards decarbonisation through the integration of renewable gases in the European market or smart gas grids. • Coupled development of both European (TYNDP) and national electricity and gas infrastructure development plans to optimize the investment effort required for the transformation of the energy system. A holistic approach based on the principle of technology neutrality must prevail to enable the most efficient and relevant investment choices. • Introduce a carbon border adjustment mechanism to complement a reinforced ETS with a wider scope and send clear signals to incentivise no-regret quick wins (e.g. switch from coal to gas enabling early savings for the EU carbon budget).
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Response to Climate change mitigation and adaptation taxonomy

27 Apr 2020

GRTgaz is fully committed to the Paris Agreement and supports the European Commission’s ambition to reach climate neutrality in 2050. As a leading European gas infrastructure operator, we are ready to assume our responsibility and put our infrastructure to good use in service of the energy and ecological transition. As such GRTgaz welcomes the work undertaken by the TEG to define a taxonomy of sustainable investments. Acknowledging the improvements of the final TEG report, GRTgaz considers several points need to be addressed via the delegated acts establishing the technical screening criteria (TSC) for implementing the taxonomy regulation: 1. Ensure the TSC allow the development of renewable and low carbon gases by being labelled as sustainable activities under the Taxonomy Regulation. Indeed, the gas infrastructure can foster the use of renewable and decarbonised gases (hydrogen, biomethane, syngas, etc.) in various sectors from mobility to the most polluting industries, thereby significantly reducing CO2 emissions. It has been partially recognised by the TEG as some technologies are still missing. Technologies such as pyrolysis, hydrothermal gasification and methanation should be considered when establishing the TSC for the manufacture of renewable and decarbonised gases. 2. Support infrastructure for renewable and low carbon gases. In this regard, inconsistencies remain in the final TEG report while manufacture of hydrogen and biomethane are better included. Indeed, the TEG excludes extension of the gas grid while the development of renewable and low carbon gases significantly relies not only on retrofitting pipelines but will in also require dedicated pipelines for hydrogen and new connection pipelines between production facilities and existing transportation or distribution infrastructures. These considerations also supports sector integration. Thus, the operation of these infrastructures transporting renewable and low carbon gases should be categorised as sustainable. In France the existing gas infrastructure already transports increasing volumes of biomethane with the objective to reach a 10% share by 2030. Such categorisation has been defined by the TEG for the transmission and distribution of electrons and should also be defined for molecules and the corresponding mitigation criteria established. 3. Ensure consistency with existent regulations on emissions standards for mobility (CO2 Emissions Regulation for Cars and Vans, the Renewable Energy Directive, the Alternative Fuels Infrastructure Directive (AFID) or the Clean Vehicles Directive (CVD)). GRTgaz supports the greater focus on hydrogen mobility granted in the final TEG report. However, the contribution of alternative fuels such as bioLNG and LNG to climate change mitigation and adaptation should also be better considered. Based on the CVD, vehicles propelled by natural gas in forms, renewable and fossil, gaseous and liquefied qualify as a clean vehicle. The threshold proposed by the TEG (50g CO2e/pkm), based on a tailpipe approach, fails to capture the benefits provided by natural gas as fuel and to a greater extent by biomethane. In comparison with petrol and diesel, natural gas generates already a GHG emission reduction of up to 23% from well-to-wheel. GHG emissions of NGVs become close to zero, or even negative, when considering biomethane. Thus, the TSC should rely on a life-cycle analysis focusing on a well-to-wheel approach and be consistent with current legislation on mobility. 4. Ensure a better cross-sectorial industrial representation in the Sustainable Finance Platform. GRTgaz would like to stress the importance of a balanced representation of stakeholders that will ensure technology neutrality and consistency between regulation, implementation and feasibility of the TSC.
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Response to European Partnership for Clean Hydrogen

26 Aug 2019

GRTgaz welcomes the opportunity to give feedback on this inception impact assessment. We believe that the impending Horizon Europe Programme should build on the success of Horizon 2020 and in particular the ‘Fuel Cells and Hydrogen 2’ Joint Undertaking (FCH 2 JU). Specifically, we support the use of an Institutionalized European Partnership (IEP) – option 2 – based on Article 187 TFEU. An IEP would provide a ring-fenced budget over a long period, enabling the development and implementation of long-term strategies, bringing all industry and all research actors together and enabling them to define and implement long term strategies as a coordinated group. In addition, we believe the scope of this new IEP should be revised and enlarged. Any new partnership on Hydrogen e.g. “Clean Hydrogen for Europe JU” should not limit its scope to storage and transport. R&D funds should prioritise aspects related to infrastructure since hydrogen needs an appropriate infrastructure to connect production to consumption. As such, European gas infrastructures have a major role to play in developing the hydrogen economy and integrating hydrogen into the Internal Energy Market. Today, existing European gas storage capacity amounts to 1,200TWh (see Hydrogen Europe Vision on the Role of Hydrogen and Gas Infrastructure on the Road Toward a Climate Neutral Economy, April 2019). Indeed, gas infrastructure and hydrogen have an important role to play in promoting sector coupling and sectoral integration, thus contributing towards decarbonisation across the economy and various sectors. The future IEP should also establish closer links with other European initiatives e.g. Important Projects for Common European Interest (IPCEI) and Trans-border European projects, in particular those supported under the TEN-E programme. To reach a global energy system approach, governance of Hydrogen Europe could be enlarged to members of European Gas transmission infrastructures; and expertise within the FCH JU should also integrate gas transmission infrastructures as there is already a Gas Grid Working Group within Hydrogen Europe. This will allow a technology neutral approach of hydrogen integration scale-up based on CO2 emissions limitations first. European gas transmission infrastructures provide the links to involve a growing number of entities whose core business is not yet related to hydrogen.
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Response to Evaluation of the effectiveness and policy coherence of the guidelines for trans-European Energy infrastructure

12 Jul 2019

GRTgaz is a gas TSO operating more than 32 000 km of pipes in France. Its network is interconnected with the German, Belgian, and Swiss networks, the Norwegian gas fields’ grid as well as with the Teréga network that is itself connected to Spain. GRTgaz notably owns Elengy, a company operating 3 LNG terminals in France, as well as German TSO GRTgaz Deutschland. As a major operator of gas infrastructure, GRTgaz welcomes the opportunity to provide feedback on the TEN-E regulation and contribute to its evaluation. Through its support to PCIs, this regulation has been effective in fostering a high level of security of supply and integration of the European gas market. Only a few major PCI projects still need to be implemented, such as the adaptation of the network from low to high calorific gas in France and Belgium. In a context of energy transition, the need to ensure optimal use of existing gas infrastructure implies thorough CBAs taking all externalities into account before taking any decision on a major gas project such as an interconnection. In that respect, and taking into account the urgent need to foster renewable and low carbon gas development, we consider that the TEN-E regulation should give priority to projects facilitating the integration of renewable and low-carbon gases (including hydrogen). Priority to decarbonation of gas grids would contribute to the EU energy transition objectives in a smart and cost-efficient way. It would also ensure that upcoming investments are futureproof, avoiding the risk of stranded assets and cost impacts harming the affordability of energy. Evolutions of the TEN-E regulation would be more than welcome to ensure the integration and timely development of renewable gas projects which tend to be predominantly of local dimension. Financial support from CEF made possible by PCI status is critical in a transition phase to help kick-start projects supporting the integration of renewable gas and of the electricity and gas systems, needed to reach long-term climate targets but not yet mature enough to trigger sufficient market interest. In light of their contribution to decarbonation and their systemic role supporting the European energy system, solutions necessary to integrate renewable and low carbon gases into the internal energy market should be allowed to become PCIs. This includes for instance P2G projects, hydrogen/methane conversions, connections of renewable gas production to the grid, facilities allowing reverse flows of renewable gas from the distribution to the transmission network or collecting biogas and upgrading it before injection into the grid. As is the case with CO2 projects, cross-border hydrogen transmission projects should be eligible to PCI status, with a view to implementing third-party access, especially when they enable conversion of existing gas pipes whose usefulness is not ensured anymore. In order to make sure that infrastructure indispensable to the energy transition is built, a flexible reading of the current TEN-E regulation would be beneficial until it is revised. In this case, the CBA process and/or eligibility criteria for PCIs should consider contribution to decarbonation as the main criterion for future projects. In anticipation of the implementation of a hybrid energy system, PCI criteria should also enable to value sector coupling projects, for which principles on allocation of costs between electricity grid and gas network tariffs should be defined.
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Meeting with Dominique Ristori (Director-General Energy)

9 Jul 2019 · La sécurité et la sûreté des infrastructures critiques énergétiques en Europe, en particulier dans le domaine du gaz

Meeting with Telmo Baltazar (Cabinet of President Jean-Claude Juncker)

29 Apr 2019 · Energy Union

Meeting with Dominique Ristori (Director-General Energy)

26 Mar 2018 · clean energy transition and role of gas

Meeting with Dominique Ristori (Director-General Energy)

12 Jan 2015 · Gas infrastructures