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NATURGY ENERGY GROUP

Naturgy Energy Group is a Spanish multinational energy company providing gas and electricity services.

Lobbying Activity

Meeting with Miguel Gil Tertre (Cabinet of Executive Vice-President Teresa Ribera Rodríguez), Thomas Auger (Cabinet of Executive Vice-President Teresa Ribera Rodríguez)

11 Dec 2025 · Perspectives on global energy markets, diversification and clean transition

Naturgy urges EU to include biomethane grid injection in Taxonomy

5 Dec 2025
Topic — The initiative reviews technical screening criteria to update the EU taxonomy's environmental standards.
Message — Naturgy proposes creating a dedicated activity for upgrading biogas to biomethane for grid injection. They also suggest impact assessments for emission limits to ensure they remain economically viable.12
Why — This would allow the company to secure sustainable classification for more gas infrastructure projects.3
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Meeting with Jonás Fernández (Member of the European Parliament)

2 Dec 2025 · Competition policy

Meeting with Andrea Wechsler (Member of the European Parliament) and Europex - Association of European Energy Exchanges

15 Jul 2025 · EU Energy and industry policy

Meeting with Laia Pinos Mataro (Cabinet of Executive Vice-President Stéphane Séjourné)

3 Jul 2025 · Geopolitical challenges affecting the European industrial sector, and ways to overcome technological and regulatory hurdles to support a smooth energy transition.

Meeting with Elena Nevado Del Campo (Member of the European Parliament)

23 Jun 2025 · Introduction

Meeting with Cristina Lobillo Borrero (Director Energy)

6 Jun 2025 · Proposal for a Regulation on phasing out Russian natural gas imports, improving monitoring of potential energy dependencies and amending Regulation (EU) 2017/1938.

Meeting with Nicolás González Casares (Member of the European Parliament)

20 May 2025 · energy transition

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

20 May 2025 · LNG supply diversification, gas market developments

Meeting with Jessika Roswall (Commissioner) and

19 May 2025 · Working lunch on Commission Priorities and Circular Economy

Meeting with Raúl De La Hoz Quintano (Member of the European Parliament)

19 Mar 2025 · Introduction

Meeting with Stefano Sannino (Acting Director-General Middle East, North Africa and the Gulf) and

12 Mar 2025 · Exchange of views on energy cooperation

Meeting with Raül Hernández Sagrera (Cabinet of Commissioner Dubravka Šuica)

12 Mar 2025 · New Pact for the Mediterranean.

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

12 Mar 2025 · European Union’s energy market and Clean Industrial Deal.

Meeting with Cristina Lobillo Borrero (Director Energy) and

27 Jan 2025 · Exchange on global gas markets

Meeting with Cristina Lobillo Borrero (Director Energy) and

16 Jan 2025 · Exchange on gas supply contracts

Meeting with Raúl De La Hoz Quintano (Member of the European Parliament)

20 Nov 2024 · Introduction

Meeting with Nicolás González Casares (Member of the European Parliament) and SkyNRG B.V.

19 Nov 2024 · Energy policy

Meeting with Javi López (Member of the European Parliament)

19 Nov 2024 · Green transition

Meeting with Jonás Fernández (Member of the European Parliament)

2 Oct 2024 · Introduction

Meeting with Héloïse Auplat (Cabinet of Executive Vice-President Margrethe Vestager), Michele Piergiovanni (Cabinet of Executive Vice-President Margrethe Vestager)

4 Jul 2024 · Future electricity capacity mechanism in Spain

Meeting with Maroš Šefčovič (Executive Vice-President) and

5 Feb 2024 · High-Level roundtable with Suppliers

Meeting with Günther Sidl (Member of the European Parliament, Shadow rapporteur)

10 Oct 2023 · Methan emissions reduction; staff level

Meeting with Günther Sidl (Member of the European Parliament, Shadow rapporteur)

24 May 2023 · Methan emissions reduction; staff level

Meeting with Nicolás González Casares (Member of the European Parliament, Rapporteur)

9 May 2023 · Electricity Market Design

Meeting with Ditte Juul-Joergensen (Director-General Energy) and TotalEnergies SE and

20 Dec 2022 · Energy Platform. Bulgargaz, SPP, EPH, DEPA, Geoplin, Eesti Gaas, Enovos, DEFA, Conexus Baltic Grid and GOGC participated as well.

Meeting with Maroš Šefčovič (Executive Vice-President) and

20 Dec 2022 · EU Energy Platform; Bulgargaz, SPP, EPH, DEPA, Geoplin, Eesti Gaas, Enovos, DEFA, Conexus Baltic Grid, GOGC participated as well.

Meeting with Kadri Simson (Commissioner) and

26 Oct 2022 · Joint purchasing options.

Meeting with Ditte Juul-Joergensen (Director-General Energy) and Shell Companies and

21 Oct 2022 · Commission proposal on measures on energy prices and security of supply. Innogy Česká republika and Bulgargaz also participated.

Meeting with Kadri Simson (Commissioner) and

10 Oct 2022 · Investment opportunities in Algeria for EU companies.

Naturgy urges delay for SF6 equipment phase-out until 2030

21 Jun 2022
Topic — Reviewing EU rules to reduce emissions from fluorinated greenhouse gases.
Message — Naturgy proposes postponing mandatory replacement of existing facilities until 2030. They argue that current green alternatives lack the standardization needed for reliable grid operation.123
Why — This delay would help the company avoid equipment costs currently triple the conventional price.4
Impact — Environmental interests lose as potent greenhouse gas emissions continue for another decade.5
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Meeting with Tatiana Marquez Uriarte (Cabinet of Commissioner Kadri Simson)

14 Jun 2022 · REPowerEU Interconnections Gas Supply and relations with South America and North Africa

Meeting with Jerzy Buzek (Member of the European Parliament, Rapporteur) and EPIA SolarPower Europe and

2 Jun 2022 · Meeting on gas and hydrogen regulation

Naturgy urges flexibility in EU methane rules for gas operators

7 Apr 2022
Topic — EU regulation on methane emissions monitoring, reporting and reduction in energy sector.
Message — The company requests different rules for transmission and distribution operators, warning that uniform requirements ignore technical differences. They want cost-benefit analysis to determine inspection frequencies and repair times, rather than fixed intervals.12
Why — This would avoid significant cost increases from mandatory fixed inspection intervals.3
Impact — Climate goals lose from slower methane reductions through flexible enforcement schedules.4
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Response to Revision of EU rules on Gas

6 Apr 2022

• Overall, the Directive and Regulation proposals are much in line with Naturgy’s observations during the consultation process. • We welcome the increased efforts, targets and instruments announced to ensure an early deployment of renewable hydrogen technologies. Hydrogen will be a critical lever in all LT scenarios. Considering the forecasted volumes for 2030, however, we don’t foresee an urgent need to adapt transmission infrastructure or LNG plants to hydrogen in most Member States. The EU and Member States should monitor carefully the development of the hydrogen market to plan for the adaptation of existing gas infrastructure – hardly before 2030 –. In the long term, a commercially-driven growth of the hydrogen market could develop in various EU neighbouring countries which could eventually lead to an established international trade. • Like the original Regulation 715/2009, the main subject of this Regulation should address the access to natural gas and hydrogen transmission infrastructure (e.g. EU hydrogen backbone), LNG plants/hydrogen terminals and storage, because of their critical importance for the well-functioning of the internal market. • The definition of hydrogen network operator in the Directive and the associated unbundling rules -which mirror the existing scheme applicable only to TSOs- creates large uncertainty about the potential development of hydrogen networks or sub-systems stemming from existing natural gas distribution networks. The role and market depth of hydrogen at distribution level is still highly uncertain, and will vary widely among MSs. The regulatory framework should be future-proofed by enabling a distinct regulatory framework for hydrogen networks at distribution level, facilitating a cost-efficient and coordinated hydrogen planning (incl. staged network sectorization). Establishing a separated model could only undermine a cost-efficient gradual development of necessary hydrogen infrastructure. The existing definition of DSOs should be broadened to entitle them to meet the eventual demands for the distribution of gases (both NG + H2), subject to the unbundling provisions in force. • Considering the important technical differences between distribution network operators, we advocate for the creation of separate entities for gas and electricity distribution system operators. As the number of gas and electricity DSOs varies widely, a common governance structure risks minimizing the voice of gas DSOs in strategic decisions across the energy sector (e.g. coordinated network planning, cybersecurity, etc). • The admixtures of gases could rise to 9% of hydrogen at interconnection points to accommodate the development of hydrogen technologies, considering the capabilities of transmission and distribution infrastructure. Blending provides hydrogen producers with a ready source of demand, delivering short term carbon savings, supporting market uptake and hence initial technology developments. It could be an appropriate option for countries with greater hydrogen production potential, enabling the cross border of gas with lower accepted emissions without being hindered by technical criteria. At the same time, we welcome that the proposed European regulatory framework is compatible with the setting of higher blending thresholds at national level or even regional agreements.
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Response to Revision of EU rules on Gas

6 Apr 2022

• Overall, the Directive and Regulation proposals are much in line with Naturgy’s observations during the consultation process. • In the REPower EU, the EC has recently proposed a longstanding request of the EU gas industry by defining a 35bcm biomethane gas target for 2030, together with the strengthening of the renewable hydrogen goals. The industry now requires a practical legislative landing of these EU-wide targets into country specific objectives or contributions as part of the 2023 review of the NECPs, mandated in the Regulation (EU) 2018/1999. • We welcome the increased efforts, targets and instruments announced to ensure an early deployment of renewable hydrogen technologies. Hydrogen will be a critical lever in all LT scenarios. Considering the forecasted volumes for 2030, however, we don’t foresee an urgent need to adapt transmission infrastructure or LNG plants to hydrogen in most Member States. The EU and Member States should monitor carefully the development of the hydrogen market to plan for the adaptation of existing gas infrastructure – hardly before 2030 –. In the long term, a commercially-driven growth of the hydrogen market could develop in various EU neighbouring countries which could eventually lead to an established international trade. • Grid connection costs can represent a significant share of projects (~20-25% of injection infrastructure costs), but the proposal doesn’t include any reference to them or to their possible cost allocation model (e.g. shared between the producer and the gas system). We call on the EC to assign a new task to the national regulatory authorities related to the definition of appropriate connection regimes to facilitate the integration of renewable gas at a reasonable cost for producers and consumers. They should be based on common principles to ensure that connection costs don’t constitute an undue barrier to the integration of renewable gas. • The proposed unbundling obligations may become a barrier to the repurposing of gas networks, and to the materialization of synergies between gas & hydrogen operators. Beyond the provisions on separate accounting between NG and H2 activities, requiring legal unbundling provisions wouldn’t have been properly justified. Consequently, we advocate for the elimination of Article 63 on horizontal unbundling. • The proposed definition of hydrogen network operator and the associated unbundling rules -which mirror the existing scheme applicable only to TSOs- creates large uncertainty about the potential development of hydrogen networks or sub-systems stemming from existing natural gas distribution networks. The role and market depth of hydrogen at distribution level is still highly uncertain, and will vary widely among MSs. The regulatory framework should be future-proofed by enabling a distinct regulatory framework for hydrogen networks at distribution level, facilitating a cost-efficient and coordinated hydrogen planning (incl. staged network sectorization). Establishing a separated model could only undermine a cost-efficient gradual development of necessary hydrogen infrastructure. The existing definition of DSOs should be broadened to entitle them to meet the eventual demands for the distribution of gases (both NG + H2), subject to the unbundling provisions in force. • Acknowledging the context of high volatile prices in the energy markets linked to our current exceptional period of instability, we should note that Internal Gas Market legislation will be implemented beyond that crisis. As highlighted in the REPowerEU Communication, regulated retail prices shouldn’t undermine wider objectives of EU energy policy such as competitive markets, consumer empowerment or greater energy efficiency. However, the current proposal just mirrors the Electricity Directive which lacks such necessary milestone. A deadline or verifiable criteria for an eventual abandonment of the transitional period of regulated gas prices should be clearly defined.
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Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

29 Mar 2022

Buildings are a hard-to-abate sector. o Huge heterogeneity (demand, building stock, disposable income, etc…) Multitude of technical, economical, and societal barriers, requiring millions of actions and actors involved. o Today, many inefficient appliances and processes use all kind of fuels. Many fossil fuel heating systems (butane gas bottles, coal, oil) aren’t connected to energy grids to get access to renewable energy. o 85-95% of the existing building stock will still stand in 2050, posing the most complex challenge jointly by the associated energy infrastructure. o No silver bullet: limits to electrification, biomass, DHC & renewable gas exist. A combination of all of them will be required, with large variations between MS. Optimizing the use of existing energy networks is the best way to ensure the overall cost efficiency of decarbonisation. o The assessment of costs and implications of energy policies (incl. energy efficiency) should cover energy but also infrastructure costs o Efficiency measures achieve well-designed gains toward the primary goal of reducing GHG emissions if infrastructure costs more aren’t larger than the energy savings obtained. o Even considering an increase of electrification, the necessity of thousands of kilometres of interconnected and operative gas networks will remain for millions of consumers. Gas grids will be used as a cost-efficient alternative to massive investments in new electricity networks. Renewable energy should be accountable to meet energy needs of buildings independently of the energy network and/or market player delivering it o All renewable energy (electricity or gas) used in buildings is valid. The Directive cannot discriminate against the delivery of renewable energy depending on the grid (district heating>electricity>gas grids), the market player (energy communities>suppliers) or the distance to the production (local > distant producers). The contribution of the gas distribution grids is threefold o Sustainability: integrating renewable energy, including electricity via the seasonal storage of hydrogen and helping to decarbonize other sectors (e.g. residues). o Security of supply: Robust and resilient to meet large peak demand and flexibility requirements. Large % of hydrogen compatible with distribution networks. It enables the connection of distant renewable gas production and consumers. o Affordability: The use of gases reduces the cost of renovating buildings and power grid expansion inherent to all-electric heating (on top of other electric needs such as EVs). The continued use of gases and grids would reduce the estimated capex for European power grid expansion by around 1.3 trillion euros until 2050*. *Source: DNV study for Eurogas (2020) Pathway to increase the energy performance of buildings: • 1. Improvement of the structural energy performance of buildings: structural changes increase the standard living conditions and reduce the renewable and decarbonized energy demand (all kind of fuels) • 2. Prioritizing the modernization of appliances + actions on buildings with heating systems not connected to energy grids (electricity, gas or district heating) as they would have low means to receive renewable or decarbonised energy (only biomass which isn’t suitable for use in urban areas due to air quality problems, as it releases particulate matter). • 3. Deployment of heating systems optimizing the use of existing energy networks (electricity, gas and district heating) leveraged on available resources. The use of modern and efficient gas heating systems together with renewable gases delivered from gas distribution grids will be critical to keep overall cost efficiency. • 4. Policy targets and instruments to decarbonise electricity and gas production. All technologies are compatible if they can use 100% renewable and decarbonized energy. Clear policies and targets to introduce renewable and low carbon gases remain a missing element in EU legislation.
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Meeting with Kadri Simson (Commissioner) and

21 Feb 2022 · Spike of energy prices and EC's toolbox, Fit-for-55 proposals and EU taxonomy.

Response to Review of Directive 2012/27/EU on energy efficiency

15 Nov 2021

Energy efficiency is a critical lever for decarbonizing the EU economy. The revision of the Directive is needed to adapt it to the new headline emission reduction target. Measures to promote energy efficiency should be coherent, proportionate and essentially market-driven, while avoiding policy overlaps. Otherwise it may have unintended consequences and risking undermining cost-effective decarbonisation. Furthermore, given the important role of consumers in the transition, there is a need for an objective assessment of the costs and implications of energy efficiency -covering not only energy but also infrastructure costs-. Energy Efficiency measures are an effective endeavour to achieve well-designed gains toward the primary goal of reducing greenhouse gas emissions -only if they do not involve infrastructure costs in excess of the energy savings obtained-. Optimizing the use of existing infrastructure leveraging on renewable energy sources would certainly contribute to the overall cost efficiency of decarbonisation policies. The fact is that the EED reached its targets only partially, as reported in the Progress report on energy efficiency. Member States refer to diverse reasons for this. Setting realistic targets requires acknowledging the difficulties to move from blueprint to the real implementation of energy efficiency policies. Regarding the energy saving obligations (Art. 8) and the energy efficiency obligation schemes (Art. 9 and Annex V) we would like to highlight the following issues: o The proposed target almost doubles by two after 2024, leading to a very challenging burden for obligated parties. The proposed target calculation might be unduly high as the period of reference to calculate the obligations a) considers an unreal energy consumption prior to the covid19 economic slowdown, and b) ignores the effects of the energy efficiency programs until 2022. o Obligated market parties orient their energy efficiency actions where they are deemed to be most cost efficient. Addressing many consumers with smaller energy consumptions, such as SMEs and vulnerable consumers, increases the complexity and might also impact on the cost efficiency of the scheme. Incentivizing market actors to establish public-private collaborations and to orient their actions to include vulnerable consumers or SMS is preferable to setting obligations. o The energy savings obligation should allow the use of all efficiency solutions, across all end uses based on cost efficiency independently of the fuel. A ban on the booking of certain energy savings is thus unacceptable and leads to maintain inefficient equipment. To encourage the deployment of renewables-ready and/or low-carbon solutions and fuels, a limit on the booking of energy savings based on fossil fuels through new equipment may be introduced. Its level shouldn’t unduly undermine the cost efficiency of the obligation scheme.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

15 Nov 2021

The development of RES is the key instrument for decarbonising the EU economy. The revision of the Directive 2018/2001 is thus needed to adapt it to the increased emission reduction target. To this extent, the provisions related to the revision of existing targets; the inclusion of new sub-targets (e.g. renewable hydrogen share in 2030 for hydrogen industry); the promotion of LT PPAs or the promotion of joint projects between MS are very appropriate. As for the missing elements, it should be stressed that gas systems are critical to embrace new forms of renewable and decarbonized gases which will progressively replace natural gas – even if the latter will remain as a key energy source in the path towards the climate neutrality-. As pointed by major long-term analysis, renewable gas will be largely needed in large scale to meet our targets, achieving significant emission reductions at an efficient cost. Therefore, the revision of the Directive must facilitate the transformation of the gas sector integrating new technologies and sources (renewable gas, hydrogen and mobility solutions): o Political and regulatory certainty to favour investments to deploy and to scale up new gas technologies is paramount, mirroring the experience and instruments deployed in the electricity sector. Many existing NECPs might lack of a sufficient perspective aligned to 2050 horizon, selecting and promoting short-term winners only, name renewable electricity. MS should establish 2030 renewable targets in the natural gas sector at the latest during the review of the PNIECs in 2024, as a way of facilitating a smooth decarbonization beyond 2030. o Renewable gases have numerous benefits, increasing social welfare: growth opportunities for EU employment (+1.7M jobs in 2050 according to studies); economic savings via the optimization of existing infrastructure and equipment; technology diversification and autonomy (vs. dependence of global supply chains); environmental benefits; security of supply; impact on vulnerable consumers or social acceptance (including consumer preferences and behaviour). The assessment of the potential of renewable energy sources for heating and cooling should include a cost-benefit analysis covering the positive externalities (environmental, economic, and social) and explore explicitly the potential of biogas/biomethane. o The integration of renewable gas requires tailor made instruments compatible with the functioning of the gas system and market. The extension of the Union Data Base, initially designed for liquid biofuels consumed in the transport sector only, has to be extended and implemented in a meshed pipeline system -where gases are mixed- for multiple uses (transport, H&C, industry, generation). For renewable gas injected into the grid, the use of a sound tradeable certificate system compatible with the gas market dynamics is paramount. o Renewable electricity production should be accountable once for target accountability, where it is effectively consumed. If converted into renewable hydrogen, the renewable energy content should be attributed to its end use sector.
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Response to Updating the EU Emissions Trading System

8 Nov 2021

Naturgy welcomes the opportunity to submit feedback to the European Commission's proposal to update the EU Emissions Trading System (ETS). The main takeaways of our response focus on the proposed establishment of an adjacent EU ETS for buildings and road transport: - An ETS for buildings and transport would not achieve its decarbonization goals since the price signals would be insufficient and volatile. - At least buildings should be maintained within the Effort Sharing Regulation with no double coverage from a new adjacent ETS. - A national price signal seems more appropriate for motorists and households in Europe to abate carbon emissions. Please find attached a more detailed explanation. We remain at your disposal to discuss any details on our feedback.
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Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

17 Mar 2021

Naturgy welcomes the opportunity to provide feedback on the inception impact assessment for the Energy Performance of Buildings Directive, within the context of the Renovation Wave. Conventional and new Gaseous solutions should be part of the solutions for decarbonising and increasing efficiency in the EU building sector, which represents 40% of total energy consumption. Nowadays, gas heating already provides comfort to consumers, decreases energy demand and reduces GHG emissions. Using gas heating instead of coal or oil heating has also contributed clearly to improve air quality. Two main barriers stand in the way of higher renovation rates: on the one hand the low awareness of consumers of the benefits of renovation, on the other, the costs they must face. Gaseous solutions can help consumers overcome these barriers and get access to efficient and affordable heating, and further reduce its emissions with the progressive penetration of decarbonized gases, including biogas (mainly from waste recovery) and hydrogen. The gas sector can progressively decarbonise buildings using existing infrastructure effectively. Moreover, gas grids’ guarantee the security of energy supply, during adverse meteorological events and allowing to address seasonal demand variations, such as demonstrated for instance during a severe cold spell occurred in January in Spain. The transformation of the natural gas sector and its evolution towards the use of modern equipment together with the integration of renewable and decarbonised gases (including hydrogen), will enable fast progress, provide energy savings, and ensure cost-efficiency of the decarbonization of energy consumption in buildings. The mere modernization of existing heating systems and the increase of renewable gases circulating through the energy grids would certainly contribute to reduce emissions in buildings. There are many inefficient appliances using all kind of fuels (e.g. electric heaters and radiators, non-condensing boilers) and many heating systems located in urban areas not connected to the energy grids (such as those using butane gas bottles or oil heating systems). Prioritizing the modernization of equipments and actions on buildings with heating systems not connected to energy grids could bring substantial emission reduction in buildings sector, rather than having to invest heavily in new infrastructures. The impact assessment should cover not only technical energy efficiency, but also economic principles. Cost efficiency, technology neutrality and a holistic view of energy policies are crucial (covering not only energy costs but also energy infrastructure and equipment costs) Like energy grids, it should be noticed that heating devices are neutral in terms of emissions. Similar to the increase of RES in electricity, natural gas is expected to be progressively replaced with renewable and decarbonized energy sources (including blending of hydrogen in urban areas). Many manufacturers are developing innovative systems that can be run with natural gas or hydrogen systems. Additionally, many experts and EU scenarios conclude that a full electrification of the heating sector would be largely inefficient, pointing to the necessity of gaseous fuels (fully gaseous or hybrid electrical-gaseous systems). Thus, it’s very important that the compatibility of new heating systems and equipment with renewable fuels is required, including gaseous energy fuels. Additionally, we support as part of the revision of the Energy Performance of Buildings Directive an update of the framework for Energy Performance Certificates. The increasing share of renewable gases in the energy mix and the compatibility of equipment with new gases such as hydrogen should be taken into account.
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Response to Revision of EU rules on Gas

5 Mar 2021

Our observations: • The introduction of binding renewable/decarbonisation gas targets should be assessed to meet the objectives and policies identified • Renewable gas should be encouraged to enter the system and the gas market, through existing gas infrastructure and platforms. It will enable producers and users to access to a larger market; it reduces dependence on captive producers/consumers; it avoids the emergence of fragmented markets; and it brings emission reductions in all sectors of consumption • Coordinated network planning should be promoted, across market areas, energy carriers, and between T&D levels. The optimization of existing energy infrastructure -reducing the risk for stranded assets & overinvestments- should be promoted. It should be considered, for instance, for the conversion of gas infrastructure to hydrogen, or for new electricity and gas investments at transmission level • The digitisation of the gas sector should be encouraged: roll-out of smart meters and smart grids • Given the high technological uncertainty and the level of the decarbonisation challenge, appropriate conditions of economic sustainability should apply for the maintenance of gas networks (e.g. for safety reasons). The preservation of the existing vast network of pipelines and storage facilities is in the general interest, considering its capability to storage and to carry large volumes of renewable gases to millions of consumers through thousands of kilometres of carbon-neutral infrastructure • The hydrogen market and infrastructure will likely grow and depart connected and from the existing gas system. The fragmentation of legal instruments differentiating between (renewable, natural or decarbonised) gas and hydrogen is not necessary nor desired. The existence of isolated or non-connected systems is not sufficient to require separate legislation • The Impact Assessment should address specifically the relevance of blending as a market-creating tool. Demand is wrongly projected to take off in transport and industry only, requiring dedicated hydrogen infrastructure. As for industry, the cost and status of the technology limit hydrogen demand to very specific European regions and activities. In transport sector, it’s aggravated by the lack of a basic and interconnected charging grid. Blending and injecting hydrogen into the gas grids will certainly be a necessary driver of large-scale projects to accommodate the production. It will be especially suitable for gas uses robust to variations on gas quality and where grids are largely compatible (e.g. polyethylene made distribution grids). The necessity of dedicated hydrogen infrastructure is rather reduced in the next decade • The definition of combined natural gas and hydrogen network operators should be included to realise efficiency gains and economies of scope. Combined gas network operators should be allowed at transmission and distribution level. It shouldn’t compromise transparency and cost-reflectiveness of grid tariffs • Non-discriminatory third-party access to hydrogen networks (and large-scale storage) should be guaranteed for all market operators • To raise the interest of consumers the system of guarantees of origin of gas should mirror the electricity GO system. As in the electricity sector, the gas system will cover a mixture of gases produced from different sources. Once that renewable energy is in the energy system, the sole function of GOs is showing to a final customer that a given share or quantity of energy was produced from RES. As in the electricity sector, GOs won’t be valid for target compliance. Likewise, its use in the market should be decoupled and won’t be precluded based on physical limits (e.g. blending limits, isolated/connected systems) like the electricity GO system (e.g. islands) • The regulatory framework should be aligned with the Renewable Energy Directive, the Waste and Landfill Directives or the Methane strategy and other EU policy instruments
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

18 Sept 2020

The revision of the Directive 2018/2001 should set an opportunity to bring untapped emissions considering that much of the legislation covering the 2021-2030 period is being implemented. Gas systems will be critical to embrace new renewable & decarbonized gases progressively replacing natural gas – which will remain as a key energy source- to facilitate the decarbonization of the economy. The RED Directive should facilitate the gradual transformation of the gas sector via the integration of new technologies and gas sources (renewable gas, hydrogen and mobility solutions). As pointed by major LT analysis, renewable gas will be largely needed in large scale to meet our targets, achieving emission reductions efficiently. We will thus need • Political & regulatory certainty to favor investments to deploy & to scale up new gas technologies, mirroring the experience and instruments deployed in the electricity sector. The revision of NCEPs should facilitate the uptake of subsequent decarbonization strategies beyond 2030. MS should establish 2030 renewable and decarbonized targets in the natural gas sector at the latest during the review of the PNIECs in 2023. • The impact assessment should consider all the positive externalities of renewable gases: impacts on EU employment; on technology diversification and autonomy (vs. dependence of global supply chains), environmental benefits; security of supply (e.g. resilience, cyberattacks risks); impact on vulnerable consumers or social acceptance (including consumer preferences). Employment factors will have to be closely considered, focusing on the creation of jobs in the EU. Global events such as the covid crisis stress the importance of fostering local employment without undermining the climate change agenda. Many decarbonization technologies depend on supply chains highly concentrated. The EU should assess local/foreign employment factors/impacts and technology dependence of technologies. Biomethane and renewable hydrogen might contribute significantly in terms of local employment (+ 1.7M jobs in 2050 according to studies). Further assessment of EU employment due to decarbonization gas strategies should be included. • A thorough analysis of infrastructure developments and raw materials associated to direct electrification. Optimizing the use infrastructure and materials, balancing direct and indirect electrification (through power-to-gas) and developing non-electrical renewable and decarbonized energy sources are necessary to achieve a least cost decarbonization. Other parts of the Directive deserving attention are: • Energy sector integration as an opportunity for renewable production. The production of electricity is increasingly expected to be above the demand in many times. Storing electricity would be an option to monetize electricity. However it is limits the access of renewable electricity to electrifiable consumption and for relatively low volumes of surplus. According to a recent EU analysis there might be a risk of overinvestments in electricity storage facilities compared to the forward looking perspectives which rely upon the existence of units converting renewable electricity mainly into hydrogen. The existence of infrastructure connecting electricity and gas systems, might facilitate trading, competition and market opportunities. As part of the upcoming revision of the internal gas market legislation, facilitating the planning and development of power-to-gas capacity will likely be crucial to facilitate the integration of large shares of renewable electricity production increasing market opportunities. • Clear and equal rules for guarantees of origin, sustainability certificates and target accountability for all fuels. Finally, links and the integration of bioenergy in horizontal policies should be considered, for instance in the modernization of the Common Agriculture Policy, the Circular Economy Action Plan –where it was barely addressed- or the State Aid Guidelines
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Naturgy urges biomethane integration into the European gas grid

31 Jul 2020
Topic — The European Commission is consulting on strategies to reduce harmful methane emissions.
Message — Naturgy calls for further incentives for methane capture and production of biogas. They propose upgrading biogas to biomethane for injection into the existing gas grid. The group also suggests mandatory anaerobic digestion for wastewater treatment.123
Why — Naturgy would benefit from utilizing its existing gas infrastructure for biomethane distribution.4
Impact — Wastewater treatment operators would face mandatory costs for required anaerobic digestion upgrades.5
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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 A EU hydrogen strategy

8 Jun 2020

Naturgy welcomes the opportunity to provide feedback and would like to highlight the following: 1. We suggest to open the scope of hydrogen potential as one of the main levers for the decarbonisation of the economy along the whole value chain: markets, infrastructure, from production to end-use of hydrogen. 2. To deploy renewable hydrogen as a priority to meet the 2030 and 2050 climate and energy goals in a timely and cost-effective way, we support a wide enough regulation of hydrogen and power-to-gas activities. 3. Clarity for investors is required. “Blending for the kick-start/transitional phases + but limitations in the medium and long term to blending” messages could discourage project developers, since the lifetime of P2G assets could be of 20 years or more. For instance, Transport and distribution assets have a technical life between 20 and 40 years, and metering and control equipment making blends possible of around 20 years; 4. Blending is critical to favor the scaling-up of renewable gas projects. Associating P2G projects to industrial demand only might limit the size of installations in many countries/regions. Taking advantage of the existing natural grids to accommodate hydrogen volumes mixed with natural gas will favor the deployment of larger projects. Moreover, 76% of existing EU building stock will remain in 2050. Decarbonizing energy supplies will be crucial to reduce building emissions. The blend of renewable hydrogen mixed with natural gas and biomethane will bring substantial emission reductions for years. 5.To foster development of hydrogen the EU we would propose the following: Setting up targets for renewable and decarbonised gases at EU level; provide funds towards R&D and innovation in key technologies (PtG); grant appropriate tariffs for gas and electricity to enhance sector coupling and hydrogen production; develop an EU system Guarantees of Origin framework for all renewable gases (hydrogen, biomethane, syngas) grids; establish a clear classification and recognition system for renewable, decarbonised and low carbon gases; set up end-use objectives for transport, heating & cooling 6. Long term storage is key for hydrogen. Salt caverns are an existing solution but are limited in volume. Further research is key to tackle the technical challenges: the EU should provide funds towards the development of pilot projects of storage in depleted gas fields. 7.To address the main barriers that currently prevent scaling-up the production and use of clean hydrogen, we propose assessing if a fully mandatory liberalized approach without the possibility of regulated component, could lead to the suboptimal development of power-to-gas (in cost, time and/or capacity). The existence of developers willing to invest in power-to-gas facilities is not the issue, but if the market appetite is large enough to trigger the optimal levels of power-to-gas capacity (in time and volume). 8.To enhance the regulatory framework for clean hydrogen as an energy carrier in connection with the strategy for smart sector integration, should avoid preempting the possibility that a regulated framework for power-to-gas could benefit the market fail to deliver on the spontaneous sizeable development of the technology. 9.If power-to-gas were to be considered as a regulated economic activity: • it wouldn’t exclude the participation of interested private investors. Regulated activity does not mean necessarily network activity. This model should allow the participation of any private market player to bid for becoming power-to-gas operators. • it could help to internalize some positive externalities which wouldn’t be considered by individual players in a liberalized model • it could be a effective approach for investments to take place in some MS 10.In short, there are reasonable doubts on the present and future need in some markets for the possibility of allowing a regulated P2G regime, thus commanding further assessment.
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Response to Commission Communication – "Renovation wave" initiative for the building sector

8 Jun 2020

El principal problema que se encuentra el propietario de un edificio a la hora de aplicar medidas de renovación o rehabilitación energéticas es el elevado coste de inversión de las mismas y los largos periodos de retorno de esas inversiones. Además de beneficios medioambientales, de confort y salud, los propietarios/usuarios necesitan ver retornos económicos efectivos. Proponemos: - Optimización del uso de las infraestructuras existentes: gran parte de los edificios tienen acceso a la red de distribución de gas natural, con gran capacidad de almacenamiento y transporte. La creciente penetración de gases renovables por estas redes, biometano e hidrógeno renovable (metanizado o inyectado directamente), darán acceso a una mayoría de edificios a una fuente de energía renovable complementaria a otros suministros. - Generalización de la producción e inyección a red de distribución de biometano y gases de origen renovable, que garantice su disponibilidad en edificios. Asimismo, se convertirán a hidrógeno excedentes y electricidad renovable dedicada, directamente inyectable o metanizado, optimizando el uso de la red de distribución de gas. - Fomentar el aprovechamiento máximo de los residuos de materiales orgánicos mediante digestión anaerobia para la producción de biometano y su inyección en las redes de distribución de gas. Su aprovechamiento energético previene las emisiones de metano a la atmósfera. - Optimizar los recursos económicos: Deben priorizarse aquellas actuaciones que ofrezcan la mejor relación coste/beneficio y que requieran menor intensidad de inversión. Por ejemplo, la sustitución de equipos de carbón y fuel, o equipos obsoletos de gas, por otros de gas natural de alta eficiencia. Combinados con medidas de regulaciones automáticas de temperaturas, de reparto de costes y de acceso a la información de los consumos del usuario. Son actuaciones de baja intensidad en inversión, permitiendo un gran número actuaciones y alcanzar a un mayor nº de consumidores y usuarios en edificios. Asimismo, serían elegibles un mayor número de empresas locales (instaladores, fontaneros, etc en su mayoría PYMEs). - Maximización del aprovechamiento de los recursos renovables disponibles in situ: En aquellos edificios (viviendas, residenciales, sanitarios, etc.) en los que la demanda de energía térmica sea importante, el aprovechamiento del recurso solar con fotovoltaica no alcanza el 20%, mientras que alcanza rendimientos superiores al 70% en los usos solares térmicos. Debe priorizarse el aprovechamiento térmico cuando sea posible. - Limitación del uso de combustibles sólidos procedentes de la biomasa en entornos urbanos. La combustión de biomasa debe alejarse de los núcleos poblados debido al detrimento de la calidad del aire que producen las emisiones asociadas a la misma. - Limitar el district heating a actuaciones con probada rentabilidad económica y medioambiental. En países como España, con demanda de calefacción concentrada en pocos meses, menor demanda media de energía por cliente y dados los costes de inversión no es una tecnología competitiva. Su instalación comporta grandes inversiones de difícil rentabilización, traduciéndose en mayor coste de la energía para los usuarios. Allí donde hay red de distribución de gas natural no parece conveniente su costoso reemplazo por una nueva red térmica. - Fomento del empleo de tecnologías de alta eficiencia en gas: bombas de calor aerotérmicas con motor de gas o la cogeneración o microcogeneración de alta eficiencia. Permiten aprovechar el recurso aerotérmico y la recuperación del calor de los motores para producción de ACS y/o calefacción. Existen barreras de tipo económico y regulatorio que limitan hoy estos sistemas. Fomento de la movilidad con gas natural y biometano. Los vehículos a GNCl reducen las emisiones contaminantes. Con la posibilidad de consumir biometano garantizaría la neutralidad en emisiones de CO2
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Response to 2030 Climate Target Plan

14 Apr 2020

“Action at EU level is indispensable and coordinated EU policies” have much a bigger chance to enhance climate action. The achievement of a new 2030 emission reduction target would be thus facilitated by European instruments. Much of the energy & climate legislation covering the 2021-2030 is in implementation phase, complicating its update simultaneously to the national transposition and definition of policies. There is a window of opportunity to bring untapped emission reductions by revising legislation not recently addressed. In particular, the EU should lever decarbonisation policies and instruments through the reform of the EU gas market rules; the revisions of the TEN-E Regulation and the Directive on alternative fuels infrastructure; and strengthening energy provisions in other horizontal regulations. As for the gas market legislation, significant emission reduction could be achieved by facilitating and incorporating renewable gases. The economic, social and environmental impacts that the revision of the legislation could offer should be analysed. Establishing 2030 targets in the natural gas sector would be crucial to grant political certainty to investors, mirroring the experience and instruments deployed in the electricity sector. Unfortunately, the gas sector has not been even mentioned in the inception assessment. Bioenergy should be integrated in horizontal policies such as the modernization of the Common Agriculture Policy, the Circular Economy Action Plan –where it has been barely addressed- or the State Aid Guidelines. The EU 2030 Climate Target Plan should be integrated and coherent with the forward-looking 2050 Strategy. Natural gas will remain a key energy source to facilitate the decarbonisation of the energy sector. The impact assessment should recognize the importance and contribution of the gas system, technologies and operators. Gas supports the deployment of intermittent RES in the electricity sector, provides irreplaceable firm energy to industry processes, affordable energy to households and SMEs and it also yields important energy savings (industrial CHP) and significant emission abatement replacing more carbon-intensive fossil fuels in all sectors. With a view to the future, the EU 2030 Climate Target Plan should set the grounds for the gradual transformation of the gas sector, in particular for the development of new technologies and gas sources (renewable gas, hydrogen and mobility solutions) making use of the existing infrastructure. Renewable gas will be inevitably needed in large scale to meet our LT targets. Stakeholders will thus need political and regulatory certainty to make investments, including through the support to I+D programs and help to the deployment and scaling up of new gas technologies. The 2030 Target Plan should assess if the 10-year NECPs submitted fit in a 2050 horizon. MS may not be sufficiently addressing a LT perspective and may be selecting and promoting short-term winners only, name renewable electricity. For instance, Spain has one of the largest renewable gas and P2G prospects in the EU but its NCEP lacks of concrete and quantified commitments in this regard. The revision of NCEPs should have a look to the way in which they facilitate the uptake of subsequent decarbonisation strategies beyond 2030. Employment factors will have to be closely considered, focusing on the creation of jobs in the EU. Global events such as the covid19 crisis stress the importance of fostering local employment without undermining the climate change agenda. Many decarbonisation technologies depend on supply chains highly concentrated (mainly in Asia). The EU should assess local/foreign employment factors/impacts and technology dependence of diverse technologies. To this extent, biomethane and hydrogen might contribute significantly in terms of local employment (+ 1.7M jobs in 2050 according to studies). Further assessment of EU employment of decarbonisation gas strategies should be include
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Meeting with Miguel Arias Cañete (Commissioner)

21 Nov 2019 · LTS

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

18 Oct 2019 · Long Term Strategy

Meeting with Daniel Calleja Crespo (Director-General Environment)

8 May 2019 · Energy transition and circular economy

Meeting with Miguel Arias Cañete (Commissioner)

22 Feb 2019 · Climate neutral strategy

Meeting with Miguel Arias Cañete (Commissioner)

17 Jan 2019 · Latest developments in Energy and Climate policies, in particular the Long-Term Strategy

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

14 Dec 2018 · Long Term Strategy

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

5 Oct 2018 · Long term strategy

Meeting with Miguel Arias Cañete (Commissioner)

3 May 2018 · Gas infrastructure and electricity markets

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

1 Dec 2017 · The amendment to the gas directive

Meeting with Miguel Arias Cañete (Commissioner)

30 May 2017 · the Energy Package and the objectives for 2030 on diffuse sectors

Meeting with Miguel Angel Sagredo Fernandez (Cabinet of Vice-President Miguel Arias Cañete)

3 May 2017 · Energy Union and Climate Change - General exchange of views

Meeting with Daniel Calleja Crespo (Director-General Environment)

14 Mar 2017 · NATURA 2000

Meeting with Miguel Ceballos Baron (Cabinet of Vice-President Cecilia Malmström)

8 Feb 2017 · Investments in the energy sector in Colombia

Meeting with Miguel Arias Cañete (Commissioner)

24 Jan 2017 · SITUATION OF ELECTRICARIBE

Meeting with Joachim Balke (Cabinet of Vice-President Miguel Arias Cañete), Maria Cristina Lobillo Borrero (Cabinet of Vice-President Miguel Arias Cañete) and Cleary Gottlieb Steen & Hamilton

12 Dec 2016 · Electricity market design

Meeting with Miguel Arias Cañete (Commissioner)

19 Sept 2016 · Electricity and gas markets

Meeting with Maria Cristina Lobillo Borrero (Cabinet of Vice-President Miguel Arias Cañete) and GEODE - The voice of local energy distributors across Europe

17 Mar 2016 · Electricity Market Design

Meeting with Miguel Arias Cañete (Commissioner) and ENEL SpA and

23 Feb 2016 · 2nd EU Energy Summit - breakfast roundtable

Meeting with Miguel Arias Cañete (Commissioner)

1 Feb 2016 · COP21 / Internal Market of Energy/ Energy diversification

Meeting with Dominique Ristori (Director-General Energy) and Eni S.p.A. and

6 Oct 2015 · European energy policies

Meeting with Miguel Arias Cañete (Commissioner)

5 Oct 2015 · Conference organised by GAS NATURAL FENOSA on natural gas and energy security of Europe

Meeting with Dominique Ristori (Director-General Energy) and ENEL SpA and

17 Sept 2015 · European energy policies

Meeting with Miguel Arias Cañete (Commissioner) and

17 Sept 2015 · Investment in Algeria

Meeting with Juraj Nociar (Cabinet of Vice-President Maroš Šefčovič)

22 Jul 2015 · Energy Union

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

22 Jul 2015 · Energy Union

Meeting with Joachim Balke (Cabinet of Vice-President Miguel Arias Cañete)

22 Jul 2015 · Energy Union

Meeting with Miguel Arias Cañete (Commissioner) and

23 Jun 2015 · Internal Electricity Market

Meeting with Miguel Arias Cañete (Commissioner) and

26 May 2015 · LNG Strategy and Gas Market in Europe and relations with 3rd countries

Meeting with Miguel Arias Cañete (Commissioner) and

27 Jan 2015 · Gas sector in the EU

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

15 Jan 2015 · Preparartory meeting

Meeting with Dominique Ristori (Director-General Energy) and ENEL SpA and

11 Dec 2014 · European Energy Policy priorities