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NET4GAS, s.r.o.

NET4GAS is the gas transmission system operator in the Czech Republic, ensuring economically efficient, safe and reliable transmission services for its customers.

Lobbying Activity

Response to Revision of the EU’s energy security framework

13 Oct 2025

NET4GAS supports the European Commissions initiative to revise the EU energy security framework in order to adapt to the evolving geopolitical, energy, and climate context, and to prepare for a more decarbonised, electrified, and integrated energy system. NET4GAS acknowledges that the transition of the energy sector towards decarbonisation will be characterised by increased electrification, the expansion of renewable energy sources, and the introduction of new energy carriers such as renewable and low-carbon hydrogen. Conversely, demand for natural gas in the EU is expected to decline, particularly in heating and cooling applications towards 2050. Nevertheless, it is important to emphasise that while overall natural gas demand may decrease, the required capacity of natural gas infrastructure during cold winter periods will not significantly diminish. This is primarily due to the limited photovoltaic output in winter and the current technological constraints in providing seasonal electricity storage. Batteries and pumped-storage hydropower can only address short-term storage needs on the scale of hours, whereas hydrogen can provide storage for days or weeks, but only in regions where salt caverns for hydrogen storage can be developed, which is not feasible in much of Central and Eastern Europe (CEE). Similarly, wind conditions in CEE are less favourable and unstable, limiting the contribution of wind power to winter energy demand. Consequently, NET4GAS stresses that natural gaspotentially combined with carbon capture, utilisation, and storage (CCUS)will remain essential, particularly for cogeneration of heat for district heating systems and electricity for electric heat pumps. The role of gas infrastructure, including natural gas, its blends, hydrogen, and CO2, will become increasingly important in ensuring the security of heat and electricity supply. At the same time, emphasis should be placed on diversifying sources and supply routes for natural gas, hydrogen, and their derivatives, for example by limiting reliance on a single supplier or region as a prerequisite for suppliers and traders. In addition to the above, NET4GAS proposes a specific revision of Article 5(4) of Regulation (EU) 2017/1938 to reduce unnecessary administrative burdens for operators and regulators. The current regulatory framework under Article 5(4) obliges transmission system operators or Member States to apply for an exemption from establishing permanent bi-directional gas capacity every four years, even when there is clear evidence of no market demand for reverse flow capacity. Each exemption request must include a cost-benefit analysis prepared in accordance with the methodology set out in TEN-E Regulation. This analysis must cover several elements, including an assessment of market demand, forecasts of demand and supply, the possible economic impact on existing infrastructure, a feasibility study, the costs of building bi-directional capacity, and the benefits for ensuring security of gas supply. This process is highly resource-intensive and repetitive, creating an unnecessary administrative burden. Therefore, an alternative approach should be considered. Existing documents that already address capacity demand forecasts could be utilised instead. For example, if the Ten-Year Network Development Plan does not indicate demand for reverse capacity, a mechanism should automatically apply whereby there is no obligation to submit an exemption application. This proposal is based on the principle that if there is no market demand for capacity, the exemption should be granted (or extended) without the need to prepare and process an extensive document confirming the absence of interest in transmission capacity in the considered direction.
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Response to Commission Regulation on inside information platforms and registered reporting mechanisms under REMIT

15 Sept 2025

Article 3 (Transactions to be reported on a continuous basis) Article 3(b)(i) and (ii) sets that transactions relating to the transportation of natural gas between entry-exit systems in the Union and between entry-exit systems in the Union and transmission systems outside of the Union shall be reported to the Agency. The explanatory memorandum to Article 3 reads that the amendments to the article are aimed at simplifying the existing legal text, without bringing about any significant changes in substance. The currently applicable Article 3 of the Commission Implementing Regulation (EU) No 1348/2014 (REMIT IR) sets obligation to report contracts relating to the transportation of natural gas in the Union between two or more locations or bidding zones. Entry-exit system has been defined by Article 2(57) of the Directive (EU) 2024/1788. Thus, while according to the REMIT IR contracts relating to the transportation of natural gas concluded both between two or more bidding zones or between the same bidding zone (between two locations within a single entry exit zone) shall be reported, the proposed wording suggests than only transactions relating to the transportation of natural gas between two or more entry-exit systems shall be reported. This is in contradiction to the explanatory memorandum, as per which the amendments do not bring any significant change. We therefore suggest the EU lawmaker clearly specifies in the legal text and its accompanying materials obligation which its addresses shall obey. Article 6 (Exposure reporting) The article 6 of the proposed implementing regulation introduces a provision on exposure reporting according to which market participants should report to the Agency, on a quarterly basis, in particular their forecasted volumes of consumption of electricity or natural gas. The explanatory memorandum to the article explains that as per the new provision market participants' forecasted sales of electricity and natural gas to final customers based on concluded customer contracts shall be reported to the Agency. With respect to this explanation and para. 2(c) of the provision, please make clear that the reporting as per Article 6 applies only to traders and suppliers and that the article shall not be applied to reporting of own consumption of transmission operators (such as consumption of gas compressor stations), which is driven solely by demand for their transmission services. Technological consumption of gas transmission operators can be predicted only with low reliability due to the difficulty of predicting flows through the transmission system over a long period of time and the prevalence of short-term fluctuations in transmission capacity.
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Response to Legislative initiative on CO2 transportation infrastructure and markets

10 Sept 2025

NET4GAS is in full support of Commission's intention to establish a framework enabling the emergence of CO2 infrastructure and a well-functioning market for CO2. Please find below the list of principles and mechanisms the proposal shall include. Regulatory Framework and Governance The regulation of CO2 transport infrastructure would depend on market maturity and size. CO2 pipeline networks are likely natural monopolies, requiring regulation to ensure fair access. Two models are possible: (i) regulated TPA, where a National Regulatory Authority defines terms and tariffs, and (ii) negotiated TPA, where operators set terms and conditions. A minimum baseline should include transparent, non-discriminatory access and independent operators. Governance must address standardization, regulatory alignment, and cross-border cooperation. CO2 transportation activities might be organised similarly to the natural gas or hydrogen transport business. Network Development Initial CO2 transport will likely start with point-to-point connections, gradually evolving into regional, national, and cross-border networks. Due to the technical requirements for the dense phase transport, new pipelines will be needed. However, repurposing existing gas pipelines might also be an option (for gaseous phase) as it offers cost and time advantages. Gas TSOs are well-positioned to operate CO2 networks due to their expertise and synergies with existing systems, e.g., if new pipelines are build allowing the use of existing corridors to keep the necessary interventions in the environment as low as possible. Gas TSOs benefit from their experience in stakeholder coordination, permitting, tenders, planning, construction and commissioning, and operations and maintenance. Market, De-risking and Public Funding Tariff model should use natural gas / hydrogen framework as a reference. However, stable revenue streams and long-term commitments are critical for investors to justify CO2 infrastructure. Emitters need certainty for long-term CO2 offtake, while infrastructure developers require predictable utilization. However, both face short-term volume uncertainty. ETS carbon pricing is insufficient and volatile. EU and national support mechanisms (e.g., CfDs, tax incentives, subsidies) are essential to launch CCUS. Long-term financial certainty is also essential. EU or Member States must implement de-risking measures to close funding gaps, as done for hydrogen. The ICM Forum WG CO2 Infrastructure recommends adapting funding to avoid the chicken and egg dilemma. Network operators need guarantees to build appropriately sized infrastructure, and early mover costs should be recovered via guaranteed revenue streams or dedicated funds. Public funds like the Innovation Fund, Modernisation Fund, CEF and state aid are crucial in covering a high level of CAPEX. Safety and Cross-Border Cooperation EU-wide interoperability rules are needed to enable cross-border flows. As CO2 transport resembles regulated gas transmission, EU-wide rules like an Interoperability Network Code are essential to support shared infrastructure and European CO2 network linking emitters and sinks. CO2 purity varies by source and transport mode, requiring flexible purification strategies at capture, transport, or end-use stages. Harmonized minimum EU-wide technical standards for pipeline design and equipment are desirable. Safety is paramount (as it is for gas and hydrogen) with measures adapted for CO2 properties. Gas TSOs have preventive measures in place to preserve pipeline integrity and ensure the high-pressure system safety. Correspondent measures should also be in place for CO2.
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Response to Greenhouse gas emissions savings methodology for low-carbon fuels

25 Oct 2024

NET4GAS welcomes the Commission's commitment to define the necessary rules for certification of GHG emission savings from low carbon fuels (LCF), with the aim of creating a clear regulatory framework. Due to the already achieved maturity of the production technology (e.g. SMR, pyrolysis), the partly existing infrastructure and the reliable supply sources (only part of the CO2 capture and storage is missing), the production of low carbon hydrogen (LCH) can ramp-up faster than renewable (RES) hydrogen. Moreover, due to regulatory barriers (additionality, temporal and geographical correlation) imposed on hydrogen production from RES, its production will increase more slowly and be more expensive than without these criteria. We, therefore, believe it is essential to allow the development of other clean gases (such as LCH) that can also contribute to successful decarbonisation in the Czech Republic and the EU. We understand decarbonisation as a process where emissions from industrial activities are reduced, rather than a consequence of a decline in activity levels or carbon leakage due to uncompetitiveness and inefficiency. NET4GAS welcomes the proposed ambition to have equivalent requirements for domestic and imported LCF. Creating a level playing field is an absolute necessity, as hydrogen (and its derivatives) will be a globally traded commodity, just like natural gas is today. However, we believe that besides detail definition of LCF and their carbon footprint, it is necessary to define its role in decarbonisation and their possible use in individual sectors. LCH is not incentivized enough in the EU regulations and directives. Without allowing LCH to contribute toward meeting GHG reduction targets (e.g. under the RED), the deployment of LCH is unlikely to occur. Therefore, it is essential to create an enabling policy environment that supports the inclusion of LCH in GHG reduction efforts. Finally, the proposed rules should be clear and stable. This means that the rules must be implemented in a way that ensures legal certainty for projects whose timeframe extends beyond the expected review in 2030 (Article 92 of Directive 2024/1788). Investors need to be assured that their products, now recognised as low carbon, will remain so throughout the lifetime of their investment and/or gas supply contract. However, the draft delegated regulation does not provide this certainty. For this reason, a grandfathering clause should be provided to avoid uncertainty caused by evolving rules and to enable FIDs in low carbon. In general, this Delegated Regulation should be simplified and give confidence to investors. We recommend the following: 1) Grandfathering should be provided to avoid regulatory uncertainty on evolving regulations (review in 2030, methane intensity methodology in 2027, hydrogen GHG potential) and thus have a stable regulatory framework allowing FIDs for low carbon. 2) LCF producers should also be able to demonstrate better GHG performance of the electricity they use. Therefore, PPAs should be allowed, otherwise only the average emissions in the member states/bidding zone would apply (i.e. only a few EU member states will be able to produce LCF). Another advantage of using PPAs is that they allow for stable and higher operating hours, thus avoiding cost volatility in the short-term electricity market and leading to lower average unit costs. The procurement of low-carbon electricity from nuclear power should also be included in the Delegated Act from its entry into force. 3) The Commission should update the RFNBO Delegated Act together with the LCH methodology Delegated Act on the day the LCH methodology is adopted. This is particularly important in view of the changes to the calculation of GHG emission intensity introduced by the LCH methodology, which need to be aligned with the provisions for RFNBOs.
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