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N.V. Nederlandse Gasunie

Gasunie

N.V. Nederlandse Gasunie is a European energy infrastructure company focused on gas transport and storage.

Lobbying Activity

Meeting with Jeannette Baljeu (Member of the European Parliament)

20 Nov 2025 · CCS and hydrogen

Meeting with Bart Groothuis (Member of the European Parliament)

20 Nov 2025 · CCS and hydrogen

Gasunie urges flexible storage targets and strategic cushion gas reserves

13 Oct 2025
Topic — The EU is updating its energy security laws to address geopolitical risks.
Message — Gasunie proposes using existing gas reserves to manage extreme supply disruptions. They recommend replacing rigid annual mandates with flexible, long-term target ranges.12
Why — Flexible targets and using existing gas would reduce infrastructure costs and market distortions.3
Impact — Other EU nations could face new financial burdens through proposed cost-sharing for storage.4
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Gasunie urges EU to prioritize hydrogen and CO2 infrastructure

5 Aug 2025
Topic — The consultation concerns measures to upgrade and expand European electricity and hydrogen grids.
Message — Gasunie urges a top-down, integrated Grid Strategy and streamlined permitting through parallel procedures. They request financial support for building oversize pipelines to avoid future infrastructure inefficiencies.12
Why — Guaranteed capacity bookings and permitting exemptions would ensure long-term returns for investors.3
Impact — Environmental groups lose the legal standing to challenge projects based on nitrogen emissions.4
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Meeting with Kamil Talbi (Cabinet of Commissioner Dan Jørgensen)

29 Jul 2025 · Grids

Meeting with Miguel Jose Garcia Jones (Cabinet of Commissioner Wopke Hoekstra)

30 Jun 2025 · Discussion on the bottlenecks green hydrogen development faces

Meeting with Wopke Hoekstra (Commissioner) and

17 Mar 2025 · Discussion on the role of Hydrogen for the Unions decarbonisation efforts.

Meeting with Mohammed Chahim (Member of the European Parliament)

3 Feb 2025 · Introduction meeting

Meeting with Tom Berendsen (Member of the European Parliament)

20 Nov 2024 · CCS

Gasunie warns EU overregulation threatens low-carbon hydrogen projects

25 Oct 2024
Topic — The consultation establishes a methodology to certify greenhouse gas emission savings for low-carbon fuels.
Message — Gasunie requests exemptions for projects from future regulatory changes through grandfathering or transition periods. They also urge the Commission to publish methane emission methodologies by 2025 to avoid investment delays.12
Why — Improved regulatory certainty would prevent delays in final investment decisions for major energy infrastructure projects.3
Impact — Environmental advocates may see slower emissions progress if projects are exempt from future stricter standards.4
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Meeting with Tom Berendsen (Member of the European Parliament)

18 Oct 2024 · Hydrogen and CCS

Meeting with Bart Groothuis (Member of the European Parliament)

16 Oct 2024 · Hydrogen

Meeting with Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans) and Shell Companies and

1 Jun 2023 · Hydrogen

Meeting with Stefano Grassi (Cabinet of Commissioner Kadri Simson), Tatiana Marquez Uriarte (Cabinet of Commissioner Kadri Simson)

19 Jan 2023 · EU international hydrogen strategy, offshore networks/electrolysers, hydrogen legislative developments

Meeting with Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans)

19 Jan 2023 · Hydrogen

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 Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans) and Koninklijke Vereniging van Gasfabrikanten in Nederland

13 Oct 2022 · Dutch energy house

Meeting with Mohammed Chahim (Member of the European Parliament)

6 Jul 2022 · Hydrogen

Response to Delegated Act on cross-border projects in the field of renewable energy

18 Nov 2021

Please find attached N.V. Nederlandse Gasunie's feedback to the consultation.
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Meeting with Kadri Simson (Commissioner) and

11 Nov 2021 · Round-table discussion on the regulation for the hydrogen market.

Meeting with Sarah Nelen (Cabinet of Executive Vice-President Frans Timmermans)

28 Apr 2021 · NortH2 Townhall meeting - intervention and Q&A on EGD and hydrogen

Response to Revision of EU rules on Gas

10 Mar 2021

Please find attached Gasunie's feedback on the revision to the Gas Directive and Regulation.
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Response to Revision of the guidelines for trans-European Energy infrastructure

8 Mar 2021

Gasunie is a European energy infrastructure company. We transport natural gas, green gas and hydrogen. In addition we offer a broad range of other energy services including LNG regasification and bunkering services and gas storage services. Gasunie is involved in numerous hydrogen, heat, biogas and CCUS projects in the Netherlands and Germany. For more information see www.gasunie.nl. We agree that the TEN-E regulation needs to be revised in order to facilitate the energy transition, however the proposed revision omits several important technologies and nuances which will encumber this transition. The priority offshore grid corridor excludes offshore H2 grids. The EU’s strategy on offshore renewable energy however states that offshore H2 production and pipelines will be needed to deliver offshore energy onshore, and should be considered in electricity and gas grid planning. Gasunie is helping develop the NSWPH and NortH2 projects, which may convert H2 offshore using offshore wind power. Including offshore H2 grids in this priority corridor will therefore help the scaling-up of offshore H2 networks. In terms of EU-wide development and support, the TYNDP is named as the instrument to ensure the integration of H2 into the wider energy system and to create an European H2 backbone. This raises questions regarding the application of the regulation of natural gas to H2. In our opinion, the direct application of existing TYNDP rules based on natural gas regulation is too restrictive for the development of H2 infrastructure, especially at the current stage of market development. At this stage H2 development requires a more separate and dedicated approach. When a market for H2 has developed, this could give rise to the need for an ENTSO-H type body. One option to complement the current TYNDP process would be for the EU to mandate Member States to prepare hydrogen infrastructure outlooks every two years which would include demand and conversion trends with a view to 2030, 2040 and 2050 and according to a new set of EU guidelines. Each Member State should have the flexibility to develop its outlook since H2 market development as well as infrastructure needs differ per country. The TYNDPs would integrate these national hydrogen outlooks at European level in order to help identify minimum capacity requirements for cross-border gas infrastructure. These could be coordinated by ENTSOG, in collaboration with ACER and the European Comission at EU level, to ensure climate goals are sufficiently guaranteed. For electrolysers, we welcome their inclusion as an energy infrastructure category, as well as their system integration role in providing a significant cross-border effect (especially when combined with storage). Through positive border spill-over effects for different Member States they allow and help to decarbonise the EU. However, the requirement that the production lifecycle emissions savings need to be 70% relative to a fossil fuel comparator would exclude substantial amounts of low-carbon H2 conversion by grid-connected electrolysers as most grids in the EU will still have a relatively high CO2-emission factor in 2030. This would hamper the required development in the H2 scale-up phase. Consistency needs to be ensured across legislation until sufficient renewable electricity penetration in the grid is reached to meet the criteria. Tools like PPAs and certification (GoOs) are thus needed to provide flexibility to meet the criteria. Funding from the Connecting Europe Facility should also be made available for electrolysers of at least 100 MW for works in order to ensure the upscaling of electrolysers and to be consistent with electricity storage being eligible in the revised TEN-E. The CO2 category should include CCU and CO2 storage facilities. Gasunie is a leading partner in the Porthos CCS project, which is an important step in decarbonising the EU economy, hence broadening the scope will speed-up the roll-out of this category.
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Response to Proposal for a legislative act on methane leakage in the energy sector

26 Jan 2021

Please find attached Gasunie's feedback.
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Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

H2 Manufacture: Under article 3.9. Manufacture of hydrogen, for consistency sake, if hydrogen was to be produced via water electrolysis supplied with electricity meeting the taxonomy criteria of significant contribution to climate change mitigation, then the hydrogen produced should also be compliant with the taxonomy. The CO2 criteria threshold (2,256 kgCO2/kgH2 which means that no low-carbon/blue H2 would be deemed sustainable) is indeed very different compared to the previous TEG (March 2020) threshold of 5.8 tCO2e/t Hydrogen. We recommend to change the threshold towards 5.8tCO2e/tH2 to ensure that projects are aligned with taxonomy. H2 Storage: Hydrogen storage, T&D activities may in the future fall under the same unbundling regulations (as applies on the EU natural gas markets). Those activities might be conducted by entities, obliged to provide third party access, with little control over the origin of the hydrogen and hence its carbon intensity. Therefore, even though the construction of hydrogen storage facilities is included, we would support the deletion of the following sentence: “operation of hydrogen storage facilities where the hydrogen stored in the facility meets the criteria for manufacture of hydrogen set out in Section 3.9. of this Annex” from the technical screening criteria for storage of hydrogen. SCW: Regarding our Super Critical Water gasification (SCW) project. This project focuses on creating biogas out of manure, green waste and sewage sludge. The new annex section ‘4.13. Manufacture of biogas and biofuels for use in transport’ is now only focused on transport usage of biogas, while we inject it into the natural gas grid. This differs from the scope stated in the Technical Annex from march 2020: under the technical annex section ‘4.13. Manufacture of Biomass, Biogas or Biofuels’ the scope was not only specified for the use in transport but also the injection into the natural gas grid. SCW does also not fall under the new annex section ‘5.6. Anaerobic digestion of sewage sludge’ given the fact that SCW uses a gasification process and not a digestion process. The difference in process is not a reason for exclusion in our opinion. SCW uses a 100% circular process where the end result gives green biogas which was eligible in the previously stated technical annex. We believe our biogas is sustainable and should fall under section 4.13. with a clear reference towards the injection into the gas grid. Now, only biogas for transportation is considered sustainable. We would like to recommend a change in scope to ensure that such SCW project is eligible for taxonomy. LNG Terminals: Chances are very small that LNG can be considered to be eligible for Taxonomy. However, If the LNG terminals are changed to receive H2 for instance then it could fall under section ‘4.14 Transmission and distribution networks for renewable and low-carbon gases (p.128).’ This section focuses on the repurposing of gas networks for transport of renewable energy. However, section 4.14 now focusses on converting existing Natural gas networks and the scope should be adapted to explicitly refer to LNG terminals under these circumstances. Electricity generation from gaseous and liquid fuels: The current version of the text leaves it unclear whether renewable and low-carbon gases are also included as a “transitional activity”. It seems to be the case as the draft reads: “Construction or operation of electricity generation facilities that produce electricity using gaseous and liquid fuels (not exclusive to natural gas, oil or other refined products).” Therefore, we would seek for the clarification between gases used (it also refers to the issue of consistency as mentioned above for the H2 manufacture being equal to 100). We believe it must be named a sustainable activity if it emits less than 100gCO2e/kWh and transitional if it takes into account the EIB position of 250gCO2e/kWh for the entire economic lifetime of the asset.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

21 Sept 2020

Please find attached Gasunie's feedback.
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Meeting with Kadri Simson (Commissioner) and

26 May 2020 · Development of European hydrogen markets, the future transport needs and options of hydrogen related infrastructural aspects.

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

17 Feb 2020 · Decarbonisation of the European Gas sector

Meeting with Dominique Ristori (Director-General Energy)

5 Sept 2018 · energy transition projects

Response to Strategy for long-term EU greenhouse gas emissions reductions

10 Aug 2018

Gasunie welcomes a renewed EU long-term greenhouse gas emissions reduction strategy and appreciates the opportunity to provide feedback. In order to achieve the Paris Agreement goal by 2050, the energy system has to be completely decarbonised. A decarbonised energy supply should be sustainable, reliable and affordable. Gasunie aspires to play a key role in achieving the climate goals in the Netherlands, Germany and beyond. Our assessments indicate that an interlinked energy system, which uses both electrons (electricity) and gases (e.g. methane or hydrogen) as energy carriers is the most cost-efficient path towards the emission reduction goals. As such, we believe that existing and new Gasunie infrastructure will be an integral part of the future energy system for our market area. Natural gas will, in the medium term, provide a considerable contribution to CO2 emission reductions by replacing more carbon intensive fuels. However, that role will become increasingly smaller and where possible, natural gas will be replaced by sustainable alternatives. In some cases the CO2 emitted will be captured and stored. Gasunie aims to facilitate the growth of these gases. We are further looking into the development of a heat network and CO2-infrastructure to support carbon capture and storage (CCS) and carbon capture and usage (CCU). Hydrogen and (synthetic) methane will be key energy carriers in our future energy system. Hydrogen provides our industry with a clean feedstock and alternative for natural gas. It is the solution of choice for seasonal electricity storage and can provide a positive market incentive for renewable electricity production growth. We believe it is critical to scale up hydrogen production now and develop the necessary infrastructure. To this end, Gasunie has partnered up in several projects. These include the joint development of electrolyzers and projects focused on blue hydrogen, an important stepping stone to create a large-scale backbone for hydrogen transport and storage in the Netherlands. Most of this backbone will be based on our current infrastructure, which significantly reduces costs and spatial impact. Already today we are in the process of converting an existing methane pipeline to the transport of hydrogen only. Biomethane is a second pillar towards decarbonizing our industry and households. To increase biomethane production, technology developments are necessary. Gasunie is facilitating the development of industrial-scale gasification technologies and enables the injection of biomethane into its GTS high-pressure gas network, contributing to a circular usage of natural resources. The EU should in their strategy for long-term EU greenhouse gas emissions reductions assess and promote the development of gas and electricity infrastructures in an interlinked approach; transport and storage of gases and electricity need to be better aligned to optimize security of supply while minimizing CO2 emissions in the most cost-efficient way. We see that our future energy supply will become less dependent on location, time and form. The EU Commission should ensure in its assessment a level playing field between energy carriers and infrastructures. Integrating different energy infrastructures and carriers in its strategy for long-term EU greenhouse gas emissions reductions is an important first step. Businesses, regulators and policy makers will work towards further interlinking planning and operation of energy infrastructures, ensuring that those infrastructures are developed and used which are most beneficial for the energy system, while meeting the CO2 emission reduction objectives in a cost efficient way.
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Response to Commission proposal for a Directive amending Directive 2009/73/EC

31 Jan 2018

Gasunie contributes actively to the continued integration of the EU gas market. We take note of the progress achieved since the 3rd Energy Package, towards a liquid, well-interconnected gas system in Europe. By contributing to this feedback form, Gasunie wants to add to informed policy decisions by legislators on the proposed amendment to Directive 2009/73/EC. However, we would like to underline that this feedback process does not substitute for an impact assessment, conducted prior to the development of any policy proposal. In the attached document Gasunie sets out its views on the proposed amendment to Directive 2009/73. Central points of this feedback are: • The proposal did not go through an impact assessment. As a result, legal and commercial questions remain open and stakeholders have not had the opportunity to provide input. • Gasunie is not convinced that a material need for the proposed amendment exists, given that all gas volumes which flow through an EU entry point are regulated under the provisions of the 3rd Energy Package. For transparency and security of supply concerns, dedicated EU legislation exists. • We underline the uncertainty that the proposal brings to existing and future pipelines. Exemptions and derogations limited in time do not serve to mitigate uncertainty and resulting unsteady regulatory framework by investors. This is particularly concerning in a context of rising gas import demand as predicted for the medium term. • It cannot be guaranteed that the EU Commission will successfully negotiate intergovernmental agreements for the operation of pipelines with third countries, especially if the aim is to align those agreements as closely as possible with the provisions of the 3rd Energy Package. This leads to more rather than less certainty. Please refer to the attached document for the entire Gasunie feedback on the proposal.
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Meeting with Bernardus Smulders (Cabinet of First Vice-President Frans Timmermans) and BUSINESSEUROPE and

14 Jun 2016 · Digital single market